Recordkeeping (29 CFR Part 1904, all covered employers)

Electronic Submission of Injury and Illness Data (ITA)

Verified vs OSHA sources · 2026-10-05

29 CFR 1904.41

29 CFR 1904.41 requires certain employers to electronically submit their injury and illness records to OSHA through the Injury Tracking Application (ITA). Establishments with 250 or more employees, and those with 20–249 employees in designated higher-hazard industries, must submit their OSHA Form 300A summary data by March 2 each year; the largest high-hazard establishments must also submit their 300 Log and 301 Incident Report data.

29 CFR 1904.41 at a glance

What it requires: Electronic submission of injury/illness data to OSHA via the ITA
Who: 250+ employee establishments; 20–249 in designated industries
What: OSHA Form 300A (and 300/301 for the largest high-hazard sites)
Deadline: March 2 of the year after the covered year
How: OSHA's Injury Tracking Application (ITA)
Max penalty (2026): Other-than-serious $16,550; willful $165,514

What 29 CFR 1904.41 requires (plain English)

29 CFR 1904.41 is the electronic-submission rule of OSHA recordkeeping. Separate from keeping the records (§§1904.4–1904.33) and from reporting fatalities and severe injuries by phone (§1904.39), it requires certain establishments to electronically submit their injury and illness data to OSHA through the Injury Tracking Application (ITA).

Coverage is by establishment size and industry. Establishments with 250 or more employees at any time during the previous year that are required to keep records must electronically submit their OSHA Form 300A summary; establishments with 20–249 employees in industries designated in the rule's appendix (higher-hazard sectors) must also submit their 300A. Under the 2024 expansion, establishments with 100 or more employees in certain high-hazard industries must additionally submit their more detailed OSHA Form 300 Log and 301 Incident Report data. Submissions are due by March 2 of the year following the year the records cover.

1904.41 exists because the aggregated data is valuable: OSHA uses it to identify establishments and industries with high injury rates, to target inspections and emphasis programs, and (for portions of the data) to make establishment-specific information available. For employers, the obligation is to determine coverage correctly by size and industry and to submit the required forms through the ITA on time: an obligation distinct from, and in addition to, keeping the underlying records.

The regulatory text

“If your establishment had 250 or more employees at any time during the previous calendar year, and this part requires your establishment to keep records, then you must electronically submit information from OSHA Form 300A.”

29 CFR 1904.41(a)(1)(ii)

Key facts about 29 CFR 1904.41

1904.41 requires electronic submission of injury/illness data via the ITA (1904.41(a)).
Establishments with 250 or more employees must submit their 300A.
Establishments with 20–249 employees in designated industries must submit their 300A.
The largest high-hazard establishments (100+ in certain industries) also submit 300/301 data.
The deadline is March 2 of the following year.
Submission is through OSHA's Injury Tracking Application (ITA).
It is separate from keeping records and from §1904.39 severe-event reporting.

Scope: who 29 CFR 1904.41 applies to

Regulatory framework: Recordkeeping (29 CFR Part 1904, all covered employers)
Citation reference: 29 CFR 1904.41
Enforcement status: In force and enforced
Jurisdiction: Federal OSHA (29 State-Plan jurisdictions may be stricter)

State-Plan states (e.g. California, Washington, Michigan) operate OSHA-approved programs that must be at least as effective as federal OSHA and frequently impose higher penalties or additional requirements. Confirm the rule as adopted in your state.

Key requirements of 29 CFR 1904.41

#	Employer obligation
1	Submit 300A data electronically by March 2 annually
2	Establishments with 250+ employees submit 300A electronically
3	Establishments with 20-249 employees in designated industries submit 300A
4	Submit through OSHA's Injury Tracking Application (ITA)

Summarized from the text of 29 CFR 1904.41. Always read the full regulation for the binding language.

Common Electronic Submission (ITA) violations

Deficiencies OSHA cites under 29 CFR 1904.41 include the ones below, in no particular order. Distinct deficiencies can be cited as separate items, and each serious item carries up to $16,550 (2026). Broader per-instance stacking exists but is a discretionary, case-by-case OSHA enforcement policy, not an automatic multiplier.

Covered establishment not electronically submitting its 300A through the ITA (1904.41(a)).
Missing the March 2 submission deadline (1904.41(c)).
Largest high-hazard establishments not submitting required 300/301 data (1904.41(a)).
Misjudging coverage by size or industry and not submitting (1904.41(a)).
Confusing electronic submission (§1904.41) with fatality reporting (§1904.39): 1904.41.

Electronic submission (§1904.41) is not the same as reporting a fatality (§1904.39)

Two recordkeeping duties get confused because both involve "reporting to OSHA." Section 1904.41 is ELECTRONIC SUBMISSION: covered establishments send their annual 300A (and, for the largest high-hazard sites, 300/301) data to OSHA through the Injury Tracking Application by March 2 each year. Section 1904.39 is REPORTING SEVERE EVENTS: any employer must phone OSHA within 8 hours of a work-related fatality, or within 24 hours of an in-patient hospitalization, amputation, or loss of an eye. They are entirely different: one is an annual electronic data submission by covered establishments, the other is an immediate phone report of a specific severe event by any employer. Confusing them (thinking the annual ITA submission covers a fatality, or vice versa) leaves one duty unmet.

What OSHA inspectors look for

Electronic-submission compliance is largely tracked by OSHA through the ITA itself rather than on-site, but a compliance officer may verify that a covered establishment determined its obligation correctly (by size and industry) and submitted the required 300A data by the deadline. Non-submission by a covered establishment is the issue.

Example: how a violation is cited

A 300-employee manufacturer keeps its 300A but never electronically submits it through the ITA. As a covered establishment (250 or more employees), it was required to submit by March 2. OSHA cites 1904.41 for the failure to electronically submit, typically as other-than-serious, up to $16,550.

Illustrative example, not a specific OSHA case.

Electronic Submission (ITA) compliance checklist

Use this to evaluate your compliance with 29 CFR 1904.41. Each item is a key requirement OSHA may verify during an inspection.

Determine whether your establishment is covered by size (250+, or 20–249/100+ in designated industries).
Submit the required OSHA 300A (and 300/301 where required) electronically.
Use OSHA's Injury Tracking Application (ITA) to submit.
Meet the March 2 deadline for the prior year's data.
Keep the underlying records (§§1904.4–1904.33) accurate, since the submission draws from them.
Do not confuse this with the §1904.39 severe-event reporting duty.

2026 penalties for 29 CFR 1904.41

Maximums set by 29 CFR 1903.15(d). 2026 amounts unchanged from 2025 (no CPI adjustment; OMB M-26-11). Not an increase. The 2025 OSHA penalty levels remain in effect for 2026; OSHA made no inflation adjustment for 2026. 29 CFR 1903.15 identifies January 15, 2025 as the effective reference for these amounts, while OSHA's public penalties page currently references penalties assessed after Jan. 15, 2026.

Violation type	Minimum	Maximum	When it applies
Serious	$1,085	$16,550	Substantial probability of death or serious physical harm.
Other-Than-Serious	$0	$16,550	Relates to safety/health but unlikely to cause death or serious harm.
Willful	$11,823	$165,514	Intentional, knowing, or voluntary disregard of the requirement.
Repeated	$4,256	$165,514	A substantially similar violation cited within the last 5 years.
Failure to Abate	None	$16,550/day	up to $16,550 per day; total capped at 30x the daily amount (FOM Ch.6)

Electronic-submission failures are recordkeeping violations, typically cited as other-than-serious, up to $16,550 each; willful non-submission reaches $165,514.

Maximums and the willful minimum are set by 29 CFR 1903.15(d); the serious and repeated minimums are OSHA policy floors from its annual penalty adjustment memo. OSHA applies gravity-based and size, good-faith and history reductions (FOM CPL 02-00-164 Ch.6). Estimates only, not legal advice.

The business case for Electronic Submission (ITA) compliance

Electronic submission turns covered establishments' injury data into a national dataset OSHA uses to target inspections, run enforcement programs, and (for some data) publish establishment-level information. 1904.41 is what feeds that system: covered employers must send their 300A (and, for the largest high-hazard sites, 300/301) data through the ITA. Beyond compliance, the data drives where OSHA looks, so accurate, timely submission matters.

Free compliance tools for 29 CFR 1904.41

ITA Reporting Checker OSHA 300A Auto-Filler OSHA Recordability Decision Tree

Electronic Submission (ITA) penalties by state

Penalties and enforcement vary by state. State-Plan states may impose higher penalties and additional requirements beyond federal 29 CFR 1904.41.

Alabama Arkansas Colorado Connecticut Delaware District of Columbia

View all 50 states + DC →

Frequently asked questions about 29 CFR 1904.41

Who must electronically submit injury data to OSHA?

Under 1904.41, establishments with 250 or more employees that keep records must electronically submit their OSHA Form 300A, and establishments with 20–249 employees in designated higher-hazard industries must submit their 300A as well. Under the 2024 expansion, establishments with 100 or more employees in certain high-hazard industries must also submit their 300 Log and 301 Incident Report data. Submissions are due by March 2 each year.

What is the Injury Tracking Application (ITA)?

The Injury Tracking Application (ITA) is OSHA's online system for electronically submitting injury and illness records under 1904.41. Covered establishments create an account and upload or enter their 300A summary (and, where required, 300/301) data. OSHA uses the submitted data to target inspections and enforcement programs and, for some data, to make establishment-level information available.

When is the electronic submission due?

Under 1904.41, covered establishments must electronically submit their prior year's data by March 2. So the 300A (and any required 300/301 data) for a given calendar year must be submitted through the ITA by March 2 of the following year.

How is 1904.41 different from 1904.39?

1904.41 is the annual ELECTRONIC SUBMISSION of injury data (300A, and 300/301 for the largest high-hazard sites) to OSHA through the ITA by covered establishments. 1904.39 is the IMMEDIATE PHONE REPORT of a work-related fatality (within 8 hours) or an in-patient hospitalization, amputation, or eye loss (within 24 hours) by any employer. They are separate duties: one an annual electronic filing, the other an urgent report of a severe event.

Regulatory history of 29 CFR 1904.41

OSHA issued the electronic-submission rule (1904.41) in 2016 (81 FR 29624), creating the Injury Tracking Application. It was amended in 2019 (84 FR 380) and expanded by the July 21, 2023 final rule, 29 CFR 1904.41 (88 FR 47346, Jul 21 2023), which added the requirement that establishments with 100 or more employees in certain high-hazard industries also submit their 300 Log and 301 Incident Report data. That expansion took effect on 2024-01-01.

Related glossary terms

Key terms that appear in 29 CFR 1904.41, each with a full plain-English explainer.

Recordable Injury National Emphasis Program Industrial Hygiene Job Hazard Analysis

Related guides & articles

OSHA Forms 300, 300A & 301 Recordkeeping Guide OSHA Recordkeeping: When Is an Injury Recordable?

Related OSHA standards

29 CFR 1910.1020

Exposure & Medical Records

29 CFR 1904.4

Recording Criteria

29 CFR 1904.5

Work-Relatedness

29 CFR 1904.7

General Recording Criteria

Primary sources

OSHA figures on this page are imported from HazComFast's verified regulatory module (verified 2026-10-05 against eCFR, OSHA.gov, and the Federal Register).

This page is an educational summary, not legal advice. OSHA standards and penalty amounts change; confirm requirements against the current regulation and your applicable State-Plan before acting.

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