Designated industries for 300A submission

Establishments with 20–249 employees in the industries listed in Appendix A to Subpart E of Part 1904 must electronically submit OSHA Form 300A each year. See 1904.41(a)(1)(i) and OSHA’s enforcement guidance on electronic submissions in the memorandum Electronic injury record submission enforcement. The Appendix A list includes specific NAICS codes and industry categories (for example, 23 Construction; 31-33 Manufacturing; 4451 Grocery Stores) that trigger the 20–249 employee submission requirement.

Employers must submit the previous calendar year’s Form 300A data electronically to OSHA by March 2 of the following year. See 1904.41 and the enforcement memorandum Electronic injury record submission enforcement which restates the March 2 submission deadline and the six-month citation issuance window.

No—establishments with fewer than 20 employees at all times during the year do not have to routinely submit Form 300A electronically. See 1904.41(a) and OSHA’s enforcement memo Electronic injury record submission enforcement, which explicitly states that establishments with fewer than 20 employees at all times during the year are exempt from routine electronic submission requirements.

The NAICS range '31-33' means all manufacturing industries with NAICS codes in the 31, 32, or 33 series are included in Appendix A and therefore subject to the 20–249 employee Form 300A submission requirement. See the Appendix A industry listing in Part 1904 and the electronic submission guidance in the Electronic injury record submission enforcement memorandum. If your establishment’s six-digit NAICS code starts with 31, 32, or 33, it falls under that manufacturing grouping.

For recordkeeping and submission, OSHA treats each physical establishment (a single physical location where business is conducted) as a unit for determining whether it meets the employee thresholds and NAICS designation. See 1904 and the Appendix A industry listing in Part 1904 Subpart E. If you operate multiple separate locations, each location’s employee count and NAICS code are evaluated separately for the submission requirement.

Yes—establishments with 250 or more employees must electronically submit Form 300A data regardless of industry, while establishments with 20–249 employees must submit only if they are in the designated industries listed in Appendix A. See 1904.41(a)(1) and the enforcement memorandum Electronic injury record submission enforcement which summarizes these different thresholds.

No—establishments with 20–249 employees in Appendix A are required to submit only OSHA Form 300A data electronically; submission of Forms 300 and 301 is not required for that size/industry group unless other rules apply. See the enforcement memorandum Electronic injury record submission enforcement which explains that only certain larger establishments (for example, 100+ employees in Appendix B industries) must also submit Forms 300 and 301.

Yes—grocery stores are included; the Appendix A listing explicitly includes NAICS code 4451 (Grocery Stores) as a designated industry for the 20–249 employee submission requirement. See the Appendix A listing in Part 1904 and the electronic submission guidance in Electronic injury record submission enforcement.

Employers should evaluate each establishment separately: determine the NAICS code and employee count for each physical location and submit Form 300A for those establishments that meet the Appendix A industry listing and have 20–249 employees (or 250+ employees regardless of industry). See 1904.41 and OSHA’s enforcement memo Electronic injury record submission enforcement for the per-establishment submission approach.

You should confirm the six-digit NAICS code for the establishment and compare it to the Appendix A industry listings to see if it’s included; NAICS lookup tools (for example, from the U.S. Census or your business filings) can help. See 1904.41(a)(1)(i) and the Appendix A listings summarized in Part 1904. If you need additional clarification about an industry’s inclusion, OSHA’s recordkeeping guidance and enforcement memo Electronic injury record submission enforcement can help explain how OSHA applies the NAICS designations.

Yes—Appendix A includes specific six-digit NAICS codes and broader NAICS ranges; when a range is listed (for example, 31-33), all NAICS codes that begin with those digits fall within the covered industry group. See Part 1904 and the Appendix A list; treat a range as inclusive of all industry codes in that range for determining submission obligations.

OSHA may issue a citation for failure to submit Form 300A; the agency may identify non-responders through its Injury Tracking Application and pursue enforcement consistent with its procedures, including issuing citations up to six months after the March 2 deadline. See 1904.41 and the enforcement memorandum Electronic injury record submission enforcement which describes enforcement timing and agency practice.

Yes—several health care and residential care NAICS codes are included in Appendix A (for example, 6219 Other Ambulatory Health Care Services; 6221 General Medical and Surgical Hospitals; 6222 Psychiatric and Substance Abuse Hospitals; 6231 Nursing Care Facilities). See the Appendix A industry listing in Part 1904 and the enforcement memorandum Electronic injury record submission enforcement. If an establishment’s NAICS code matches one of the listed codes, the 20–249 employee submission requirement applies.

The recordkeeping and submission thresholds are generally evaluated based on whether the establishment had 20 or more employees at any time during the calendar year; employers should check their staffing records to determine if the establishment met the 20–249 range during the year. See 1904.41 and the enforcement guidance in Electronic injury record submission enforcement which discusses how OSHA applies employee thresholds for submissions.

Yes—employers may use software-generated forms or electronic records that are equivalent to OSHA Form 300A to meet recordkeeping requirements so long as those forms meet the equivalency criteria described in the regulations and are available for inspection. See 1904.41 and OSHA’s interpretation Software-generated OSHA recordkeeping forms, which explains that equivalent electronic forms are acceptable if they contain the same information, are as readable and understandable, and comply with the access-to-records provisions in 1904.29 (see the interpretation for details).

Use the primary NAICS code that best describes the main activity of the establishment (the activity that generates the most revenue or is the primary business function) to determine whether the establishment is in Appendix A and therefore must submit Form 300A. See Part 1904 and consult the Appendix A listings; if in doubt, document the rationale for selecting the primary NAICS code and refer to the Electronic injury record submission enforcement guidance for how OSHA evaluates such situations during enforcement.

Not necessarily—establishments with 100 or more employees are required to submit Forms 300 and 301 electronically only if their industry is listed in Appendix B to Subpart E of Part 1904; Appendix A (20–249 employees) typically requires Form 300A only. See 1904.41 and the enforcement memorandum Electronic injury record submission enforcement which clarifies that Form 300 and 301 electronic submissions apply to Appendix B industries for establishments with 100+ employees.

If your establishment’s six-digit NAICS code falls within a listed range or category in Appendix A (for example, the 31-33 manufacturing range), treat it as included and follow the submission requirement; if you remain uncertain, determine and document the establishment’s six-digit NAICS code and consult OSHA guidance or contact OSHA for clarification. See Part 1904 and the enforcement memo Electronic injury record submission enforcement for how OSHA applies ranges and categories.

Yes—count all employees who worked at the establishment during the year, including temporary, seasonal, and part-time workers, when determining whether the establishment meets the 20–249 or 250+ employee thresholds for electronic submission. See 1904.41 and OSHA’s enforcement memorandum Electronic injury record submission enforcement which relies on the standard recordkeeping definitions and practices for determining employee counts.

Yes—warehousing and storage (NAICS 4931) is listed in Appendix A and is a designated industry for the 20–249 employee Form 300A submission requirement. See the Appendix A industry list in Part 1904 and the enforcement memorandum Electronic injury record submission enforcement.