Electronic injury record submission

Yes — establishments that had 20–249 employees at any time during the previous calendar year and are in an industry listed in Appendix A must submit Form 300A once a year. See 1904.41(a)(1)(i).

• Submit the OSHA Form 300A information electronically to OSHA or OSHA’s designee.
• The requirement applies if the establishment met the 20–249 threshold at any point during the previous calendar year.

Yes — any establishment that had 250 or more employees at any time during the previous calendar year and is required by Part 1904 to keep records must submit the OSHA Form 300A information once a year. See 1904.41(a)(1)(ii).

• The 250-employee threshold counts any individual employed at the establishment (full-time, part-time, seasonal, or temporary).
• The submission is electronic and must be made to OSHA or OSHA’s designee.

Yes — establishments that had 100 or more employees at any time during the previous calendar year and are in an industry listed in Appendix B must submit information from OSHA Forms 300 and 301 (in addition to Form 300A) once a year. See 1904.41(a)(2).

• This applies to the industries specifically listed in Appendix B to Subpart E.
• Submit the required Forms 300 and 301 information electronically to OSHA or OSHA’s designee.

You must submit the required information by March 2 of the year after the calendar year covered by the form(s). See 1904.41(c).

• Example: records for calendar year 2023 must be submitted by March 2, 2024.
• The rule has been amended over time; always check the cited paragraph for current reporting dates.

Yes — each individual employed in the establishment at any time during the calendar year counts as one employee for the submission thresholds, including full-time, part-time, seasonal, and temporary workers. See 1904.41(b)(2).

• Count every worker who worked at the establishment at any point during the year when determining whether you meet the 20–249, 100+, or 250+ thresholds.

No — if your establishment is partially exempt from keeping injury and illness records under 1904.1 and/or 1904.2, you do not have to routinely submit information under paragraphs (a)(1) and (a)(2); however, you must submit if OSHA notifies you to do so for an individual data collection. See 1904.41(b)(6).

• If OSHA issues a written notification under paragraph (a)(3), you must comply and submit the requested records.

Yes — an enterprise or corporate office that had ownership of or control over one or more establishments required to submit information may collect and electronically submit the information for those establishments. See 1904.41(b)(8).

• The corporate submission must include required data elements for each establishment as specified by OSHA’s submission system.

Yes — when you must submit information under paragraph (a)(2), you are required to submit all information from the forms except certain employee-identifying fields: the employee name on OSHA Form 300 (column B) and several fields on OSHA Form 301 (employee name, employee address, name of physician or health care professional, and facility name/address if treatment was given away from the worksite). See 1904.41(b)(9) and its subsections 1904.41(b)(9)(i) and 1904.41(b)(9)(ii).

• All other required fields must be submitted electronically unless excluded by the cited paragraphs.

Yes — for each establishment that is subject to the electronic submission requirements, you must provide the Employer Identification Number (EIN) used by that establishment. See 1904.41(a)(4).

• Include the EIN for each establishment in your electronic submission so OSHA can correctly identify and process the data.

Yes — you may use numbers or codes as the establishment name in your submission, but the submission must also include a legal company name either as part of the establishment name or separately as the company name. See 1904.41(b)(10) and 1904.41(c).

• This lets companies maintain internal numbering systems while ensuring OSHA can match data to the legal entity.

OSHA will notify you by mail if you must submit information as part of an individual data collection, and OSHA will provide a secure website for electronic submission. See 1904.41(b)(3) and 1904.41(b)(5).

• OSHA also announces individual data collections in the Federal Register and through other OSHA communications.
• For individual collections, the notification will include the web location for submissions.

Yes — the requirements to submit injury and illness information electronically apply to employers located in State Plan States. See 1904.41(b)(7).

• State Plans are required to have programs at least as effective as OSHA’s, so employers in those states must comply with the federal submission rules described here.

You must electronically submit the requested information from your Part 1904 records to OSHA or OSHA’s designee as directed in the notification. See 1904.41(a)(3).

• Follow the specific submission instructions, deadline, and format specified in the OSHA notification.

You must submit the information as specified in OSHA’s notification for that individual data collection; routine annual submissions for categories in (a)(1) and (a)(2) must be submitted by the date in paragraph (c). See 1904.41(b)(4).

• The notification will provide a deadline and web address for electronic submission for the individual collection.

OSHA uses the Injury Tracking Application (ITA) database to identify employers who were required to submit Form 300A but failed to do so, and Area Offices should refer to that database during inspections. See OSHA’s enforcement memorandum titled "Electronic injury record submission enforcement" (April 16, 2024) at https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16.

• The memorandum explains enforcement priorities and that OSHA may issue citations for non-submission (example: submissions due March 2; six-month citation window until September 2).

OSHA may issue a citation for failure to submit Form 300A up to six months after the March 2 submission deadline; for example, data due March 2, 2024, could be cited through September 2, 2024. See the April 16, 2024 enforcement memorandum at https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16.

• The memo provides this six-month example and instructs Area Offices on enforcement procedures.

OSHA’s current enforcement procedures primarily focus on employers’ failures to submit required Form 300A data, although Area Offices may identify and cite employers for failing to submit Forms 300 and 301 in appropriate circumstances. See the April 16, 2024 enforcement memorandum at https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16.

• Employers in the 100+ Appendix B category should still ensure Forms 300 and 301 are submitted when required.

Yes — software-generated forms can be used as substitutes for OSHA Forms 300 and 300A if they meet the requirements for equivalent forms in the recordkeeping regulation (they must contain the same information, be as readable and understandable, and be completed using the same instructions). See OSHA’s Letter of Interpretation "Software-generated OSHA recordkeeping forms" (April 29, 2025) at https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29.

• Employers who keep electronic records must be able to produce equivalent forms for employee access and government inspection per the recordkeeping rules described in the interpretation.

The electronic record system must be able to produce equivalent forms that have the same information, are as readable and understandable, and are completed using the same instructions as the OSHA forms; the forms must also be available for inspection, copying by government representatives, and access by employees as required. See OSHA’s Letter of Interpretation "Software-generated OSHA recordkeeping forms" (April 29, 2025) at https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29.

• Employers may keep records in various file formats (Excel, CSV, etc.) if they meet the equivalence requirements described in the interpretation.

Generally no — establishments with fewer than 20 employees at all times during the year do not have to routinely submit information electronically to OSHA; however, they must submit if OSHA notifies them as part of an individual data collection. See 1904.41(b)(1) and related explanation in the standard text.

• If OSHA sends a written notification under paragraph (a)(3), the establishment must submit the requested records even if it is normally exempt from routine submission.

Count an establishment if it met the applicable employee threshold (e.g., 20–249, 100+, or 250+) at any time during the previous calendar year — meeting the threshold for any period during the year triggers the electronic submission requirement for the following year. See 1904.41(a)(1) and 1904.41(a)(2).

• Include part-time, seasonal, and temporary workers when determining whether the threshold was met (see 1904.41(b)(2)).

Include the legal company name in your submission either as part of the establishment name or separately as the company name, even if you use numbers or codes as establishment identifiers. See 1904.41(b)(10) and 1904.41(c).

• This practice allows employers to maintain internal coding while ensuring OSHA can match submissions to the correct legal entity.

You are not required to submit the employee name on OSHA Form 300 (column B) and the following OSHA Form 301 fields: employee name (field 1), employee address (field 2), name of physician/health care professional (field 6), and facility name/address if treatment was given away from the worksite (field 7). See 1904.41(b)(9)(i) and 1904.41(b)(9)(ii).

• All other required fields from Forms 300 and 301 must be submitted electronically when your establishment falls into the category requiring those forms.

Yes — if you receive a notification to submit records under 1904.41(a)(3), you must keep the injury and illness records required by Part 1904 and submit the requested information as directed. See 1904.41(b)(1) and 1904.41(a)(3).

• Maintaining accurate Part 1904 records is a prerequisite to responding properly to an OSHA data collection notice.

Yes — equivalent electronic or software-generated forms must be available for inspection and copying by authorized government representatives and must be provided to employees, former employees, and their representatives per the access-to-records requirements. See OSHA’s Letter of Interpretation "Software-generated OSHA recordkeeping forms" (April 29, 2025) at https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29.

• Employers must be able to produce the equivalent forms on request to comply with 1904.35 and 1904.40 access provisions referenced in the interpretation.