How to Electronically Submit OSHA 300, 300A, and 301 Forms

Summary of OSHA Reporting Submission Requirements

For many years, OSHA has required certain employers to submit summaries (Form 300A) of their workplace injury and illness incidents for baseline data on the health and safety of America’s workforce.

A new rule, effective January 1^st, 2024 requires many businesses to also submit additional OSHA forms (300 log and 301 incident reports) electronically to OSHA by March 2^nd of each year.  This enables the agency to dig deeper into workplace injury or illness data for insights that improve enforcement or drive new regulations to protect workers.

To comply with this new electronic submission rule, we recommend using OSHA’s ITA Coverage Tool to determine if your organization must submit reports.

If you are required to submit these forms, use the Injury Tracking Application tool to submit them.

What is worrisome for many companies is that these forms will be made publicly available with the company name which further emphasizes the need for a comprehensive safety program to avoid being seen as an unsafe employer.

Lastly, according to a 2018 OSHA Memorandum, if a company is inspected by OSHA and it failed to submit these forms if required to, it may result in an Other-Than-Serious citation and fine, even if no specific safety violation was found.

We strongly encourage everyone to comply with their specific OSHA recordkeeping and reporting requirements in addition to having a strong safety program in place.

OSHA requires many employers to keep injury and illness records.

OSHA has long required many employers to create and maintain Injury and Illness Records consisting of forms 300, 300A, and 301 for a period of 5 years.

Per OSHA Standard 1904.29(a):

You must use OSHA 300, 300-A, and 301 forms, or equivalent forms, for recordable injuries and illnesses. The OSHA 300 form is called the Log of Work-Related Injuries and Illnesses, the 300-A is the Summary of Work-Related Injuries and Illnesses, and the OSHA 301 form is called the Injury and Illness Incident Report.

These forms are expected to be accurate and OSHA rules prevent employers from retaliating against any employee who wishes to accurately report on workplace-related injury and illnesses.

Moreover, Form 300A must be certified by a company executive for accuracy.

Also, it’s important to note that many states have their own state agencies with additional rules to follow beyond what is required by Federal OSHA.

Lastly, while these forms are simple to understand, there are complicated rules for understanding who must keep these records as well as who must submit them to OSHA.

Certain employers must create and maintain OSHA records.

The requirements for which employers must create and maintain these records depends on employee size and their industry they work in (based on NAICS codes).

All employers are required to keep OSHA Forms 300, 300A, and 301 unless they have 10 or fewer employees at all times during the year or are in a ‘partially exempt industry’. 

Counting your employees is a little more difficult than it seems.  For example, if your industry is not exempt and for just a single day you add an extra employee and have 11, but the rest of the year you have 10 employees or fewer, your organization is now required to keep these records for the entire year.

However, regardless of size or industry, all employers must report to OSHA work-related fatalities, in-patient hospitalizations, amputations, or losses of an eye.

Certain employers must also submit these records electronically to OSHA.

Requirements for which employers must electronically submit records to OSHA are complicated due to company size and specific industries being outlined for inclusion for different forms.

For several years, employers in certain high-risk industries with 20-249 employees or any employer with more than 250 employees, who was not partially exempt from recordkeeping, must electronically submit Form 300A to OSHA.

The new rule, in effect starting January 1^st, 2024, requires employers with 100 or more employees in certain industries to also electronically submit their 300 and 301 forms (source: OSHA.gov).

The deadline for electronic submission is March 2^nd of each year for the previous year’s reports.

PRO TIP: Use OSHA’s ITA Coverage Tool to easily understand your electronic submission requirements.  You will answer a few questions about your employee size and industry, and it will list your requirements.

The following diagram helps illustrate which employers are required to submit specific forms.

OSHA has a specific web application for submitting 300, 300A, and 301 Forms.

Because of the volume of records submitted to OSHA, they have a web-based application to enable electronic submission.

The application is called the Injury Tracking Application (ITA).

Last year, OSHA switched to using the public’s one account access login.gov. You’ll need an account with both the ITA and login.gov with the same email address to submit your forms. Create accounts using these two reference guides:

• ITA account
• login.gov account

Then, because OSHA Forms 300, 300A, and 301 are maintained for each establishment of the company, you must create establishments in the tool.

Per OSHA’s ITA instructions:

An establishment is a single physical location where business is conducted or where services or industrial operations are performed. You must provide separate injury and illness records for each establishment that meets the industry and size reporting criteria. For activities where employees do not work at a single physical location, the establishment is represented by main or branch offices, terminals, stations, etc., that either supervise such activities or are the base from which personnel carry out these activities.

Once establishments are created, you can then add the data from your forms.  This can be done in three ways: manually typing the data in the tool, uploading your Excel-based forms as a CSV file, or using an API to upload the data.

Next steps to comply with OSHA’s electronic reporting submission requirements:

1. Understand what is required for your company based on employee size and industry.
2. If required, create and maintain OSHA forms 300, 300A, and 301.
3. If required, use the Injury Tracking Application (ITA) to submit the forms as required.
4. If necessary, seek out a third-party safety consulting firm like Lancaster Safety to help.

We understand OSHA rules can get complicated very fast!

Lancaster Safety has experienced professionals to help you comply with all OSHA regulations, including the recordkeeping requirements and much, much more!

If you have any questions, please call at 888-403-6026 us or fill out the contact form below.