OSHA Electronic Recordkeeping (ITA): Who Must Submit 300/301/300A in 2026

Under 29 CFR 1904.41, covered establishments must electronically submit their prior-year injury and illness data to OSHA through the Injury Tracking Application (ITA) by March 2. The key question is which forms you submit. There are three triggers: establishments with 100 or more employees in an Appendix B industry submit the OSHA 300, 301, and 300A; establishments with 250 or more employees that keep records submit only the 300A; and establishments with 20–249 employees in an Appendix A industry also submit only the 300A. Critically, Appendix B lists one construction code — NAICS 2381, Foundation, Structure, and Building Exterior Contractors — so a qualifying 2381 establishment submits all three forms, while building construction (236), heavy and civil engineering (237) and the other specialty trades are not listed. This guide breaks down the tiers, the deadline, and exactly what to file — and how to actually submit it.

At a glance: ITA submission is due March 2 (1904.41), counted per establishment by peak employment. 100+ in an Appendix B industry (from construction, NAICS 2381 only) → file 300 + 301 + 300A (case-level detail). 250+ in any recordkeeping industry → 300A only. 20–249 in an Appendix A industry → 300A only. OSHA's electronic recordkeeping rule requires establishments with 100 or more employees in an Appendix B industry — from construction, that is NAICS 2381 only — to submit Forms 300, 301, and 300A through the Injury Tracking Application by March 2; establishments with 250 or more employees, and those with 20 to 249 employees in an Appendix A industry, submit only the 300A.

The Three Submission Tiers in Plain English

OSHA's electronic recordkeeping rule sorts covered employers into tiers based on establishment size and industry. The triggers are easy to mix up, so here is the clear breakdown.

The deadline for all three tiers is March 2 each year, covering the prior calendar year's data, per 29 CFR 1904.41(c). Note the two appendices are different lists: Appendix A is the broader set of designated industries whose establishments file the 300A at the 20–249 size; Appendix B is the set whose 100+ establishments must also file the case-level 300 and 301.

Why Construction Employers Must Pay Attention

A common misconception is that the full 300/301 submission only applies to manufacturing or other "high-hazard" sectors. In fact, Appendix B to Subpart E of Part 1904 does reach construction — but only NAICS 2381, Foundation, Structure and Building Exterior Contractors. A 2381 establishment with 100 or more employees must electronically submit all three forms — the detailed Form 300 log, the individual Form 301 incident reports, and the Form 300A annual summary.

This is a meaningful data exposure: the 300 and 301 contain case-level detail, not just the summary counts on the 300A. Construction firms that previously submitted only the 300A based on the 250-employee rule may now have a broader obligation if they hit the 100-employee Appendix B threshold.

What Each Form Contains

• OSHA Form 300 — Log of Work-Related Injuries and Illnesses. The running log of each recordable case for the establishment, including classification (days away, restricted/transfer, other) and case details.
• OSHA Form 301 — Injury and Illness Incident Report. A separate, detailed report for each individual recordable case describing how the incident occurred.
• OSHA Form 300A — Summary of Work-Related Injuries and Illnesses. The annual summary of totals that must be posted at the worksite from February 1 through April 30 and submitted electronically by covered establishments.

How to Determine Your Obligation

Work through these questions for each establishment (not company-wide — the rule is establishment-based):

• Is the establishment partially exempt from recordkeeping (low-hazard industry or small size under 1904.1/1904.2)? If yes, it generally has no ITA submission duty.
• Does the establishment have 100+ employees AND fall in an Appendix B industry (from construction, NAICS 2381 only)? If yes, submit 300, 301, and 300A.
• Does the establishment have 250+ employees and keep records? If yes, submit at least the 300A (and 300/301 if it also meets the 100+ Appendix B trigger).
• Does the establishment have 20–249 employees AND fall in an Appendix A industry? If yes, submit the 300A.
• Confirm employee counts using the peak employment during the calendar year.
• Submit through the ITA by March 2.

Key Dates and Citation

How to Actually Submit Through the ITA

Knowing your tier is half the job; the other half is getting the data into OSHA's system. The mechanics:

1. Create an ITA account at osha.gov/injuryreporting/ita to access the application.
2. Set up an establishment profile for each establishment you report — the rule is establishment-based, so a multi-site company creates one profile per covered site. New users must create the establishment before any data can be entered.
3. Provide the establishment's EIN. Since the 2024 rule, 1904.41(a)(4) requires you to submit the Employer Identification Number used by the establishment. Have it ready.
4. Choose how to enter the data — OSHA supports three methods:
   • Manual web-form entry — best for a small number of establishments or cases.
   • CSV batch upload — one file for many establishments/cases.
   • API — for automated recordkeeping systems; requires an ITA API token.
5. Submit by March 2 (1904.41(c)) for the prior calendar year, and keep your confirmation.

A clean 300 log all year makes this an export rather than a data-entry marathon — the CSV and API paths only work if your underlying records are already accurate and complete.

Get Your 300/301/300A Right Before March 2

Accurate logs make ITA submission painless. Build clean, audit-ready records first, then submit through the ITA before the March 2 deadline.

The hub & related: OSHA recordkeeping — 300, 300A & 301 · OSHA 300/300A/301 Recordkeeping Guide · When Is an Injury Recordable? · 300A: Posting vs. Electronic Submission · 1904.41 Electronic Reporting (standard)

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Sources & verification (verified 2026-07-18): OSHA electronic submission rule, 29 CFR 1904.41, read from the standard text on osha.gov — March 2 annual deadline (1904.41(c)); 100+ establishments in an Appendix B industry (from construction, NAICS 2381 only) submit 300/301/300A (1904.41(a)(2)); 250+ establishments submit 300A (1904.41(a)(1)(ii)); 20–249 establishments in an Appendix A industry submit 300A (1904.41(a)(1)(i)); EIN required (1904.41(a)(4)); submission by manual entry, CSV upload, or API through the ITA. Verify your establishment's size and industry classification against the current ITA coverage list at osha.gov/injuryreporting/ita. Not legal advice.