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Back to Part 1904
OSHA 1904SubpartEAppA

Designated industries for 300A reporting

Subpart E

20 Questions & Answers
10 Interpretations
Official OSHA text

Questions & Answers

Under 1904 Subpart E App A, which industries (NAICS codes) require establishments with 20–249 employees to electronically submit OSHA Form 300A?

Yes — Appendix A to Subpart E lists the industries whose establishments with 20–249 employees must submit OSHA Form 300A electronically. The Appendix includes broad NAICS sectors (for example, 11 Agriculture; 22 Utilities; 23 Construction; 31–33 Manufacturing; 42 Wholesale Trade) and many specific 4-digit and 6-digit NAICS industries such as 4413 Automotive Parts, 4451 Grocery Stores, 4841 General Freight Trucking, 6221 General Medical and Surgical Hospitals, 7211 Traveler Accommodation, and others. See the full list in [Appendix A to Subpart E of Part 1904] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppA) and the electronic submission requirement in 1904.41(a)(1)(i).

  • Primary references: [Appendix A to Subpart E of Part 1904] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppA) and 1904.41(a)(1)(i).

Under 1904.41(a)(1)(i), does an establishment not listed in Appendix A need to submit OSHA Form 300A if it has 20–249 employees?

No — an establishment with 20–249 employees must submit OSHA Form 300A electronically only if its industry is listed in [Appendix A to Subpart E of Part 1904] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppA). If the establishment’s NAICS code is not included in Appendix A, the 20–249 employee threshold in 1904.41(a)(1)(i) does not require electronic submission for that establishment.

  • Reference: 1904.41(a)(1)(i) and [Appendix A] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppA).

Under 1904.41(a), do establishments with 250 or more employees have to submit OSHA Form 300A electronically regardless of industry?

Yes — establishments with 250 or more employees that are subject to OSHA recordkeeping must electronically submit OSHA Form 300A regardless of industry. OSHA’s enforcement guidance reiterates that establishments with 250+ employees must submit Form 300A data each year. See [1904.41] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904) and OSHA’s enforcement memorandum on electronic submission requirements (April 16, 2024) at https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16.

Under 1904.41(a)(1)(i), what size thresholds trigger the different electronic submission requirements for OSHA injury and illness records?

The thresholds are: establishments with 250 or more employees must submit OSHA Form 300A (and in some cases Forms 300 and 301) electronically regardless of industry; establishments with 20–249 employees must submit OSHA Form 300A electronically only if their establishment’s NAICS is listed in [Appendix A] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppA). Employers with fewer than 20 employees generally are not required to submit electronically. See 1904.41(a) and OSHA’s electronic submission enforcement guidance at https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16.

Under 1904 Subpart E App A, does the NAICS range 31–33 (Manufacturing) require 20–249 employee establishments to submit Form 300A?

Yes — the NAICS range 31–33 (Manufacturing) is explicitly included in [Appendix A to Subpart E of Part 1904] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppA), so manufacturing establishments with 20–249 employees must electronically submit OSHA Form 300A per 1904.41(a)(1)(i).

  • Reference: [Appendix A] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppA) and 1904.41(a)(1)(i).

Under 1904.41(a)(1), how do I determine whether the electronic-submission requirement applies to a specific establishment of a multi-establishment employer?

You must evaluate the requirement at the establishment level — the electronic-submission obligation applies based on each establishment’s employee count and NAICS classification, not the overall company totals. If an individual establishment has 20–249 employees and its NAICS is listed in [Appendix A] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppA), that establishment must submit its Form 300A data electronically under 1904.41(a)(1)(i). OSHA’s enforcement guidance also treats compliance on an establishment-by-establishment basis. See 1904.41(a)(1) and [Appendix A] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppA).

  • Reference: 1904.41(a)(1) and [Appendix A] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppA).

Under 1904, what is the annual electronic submission deadline for OSHA Form 300A and when can OSHA issue a citation for failing to submit?

OSHA requires establishments to submit the previous calendar year’s Form 300A data electronically by March 2 each year, and OSHA’s guidance states it may issue a citation for failure to submit within six months after the March 2 deadline. For example, data for 2023 were due by March 2, 2024, and citations could be issued through September 2, 2024. See OSHA’s enforcement memorandum at https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16.

Under 1904.41(a)(1)(i), do establishments with 100 or more employees ever have additional submission obligations beyond Form 300A?

Yes — OSHA’s guidance explains that establishments with 100 or more employees in certain industries (listed in a separate Appendix B) must submit not only Form 300A but also Form 300 and Form 301 data electronically. See OSHA’s electronic submission guidance at https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16 and the general electronic submission requirements in [1904.41] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904).

Under 1904 Subpart E App A, does NAICS 4413 (Automotive Parts, Accessories, and Tire Stores) require establishments with 20–249 employees to submit Form 300A electronically?

Yes — NAICS 4413 is specifically listed in [Appendix A to Subpart E of Part 1904] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppA), so establishments with 20–249 employees in NAICS 4413 must submit OSHA Form 300A electronically under 1904.41(a)(1)(i).

  • Reference: [Appendix A] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppA) and 1904.41(a)(1)(i).

Under 1904, can I use software-generated equivalents of OSHA Form 300A to maintain records and meet recordkeeping requirements?

Yes — you can use software-generated forms as substitutes for OSHA Forms 300 and 300A if the electronic or paper forms are equivalent to the OSHA forms (contain the same information, are as readable and understandable, and are completed using the same instructions). However, electronic submission to OSHA must be done using OSHA’s required electronic submission process (for example, the Injury Tracking Application). See OSHA’s interpretation on software-generated forms at https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29 and the electronic submission requirements in [1904.41] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904).

Under 1904 Subpart E App A, are grocery stores (NAICS 4451) included in the list that requires 20–249 employee establishments to submit Form 300A electronically?

Yes — NAICS 4451 (Grocery Stores) appears in [Appendix A to Subpart E of Part 1904] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppA), so grocery-store establishments with 20–249 employees must submit OSHA Form 300A electronically according to 1904.41(a)(1)(i).

  • Reference: [Appendix A] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppA) and 1904.41(a)(1)(i).

Under 1904, if my establishment had fewer than 20 employees for the entire calendar year, am I required to submit Form 300A electronically?

No — establishments that had fewer than 20 employees at all times during the calendar year are generally not required to routinely submit injury and illness records electronically to OSHA. OSHA’s electronic-submission guidance confirms that establishments with fewer than 20 employees do not have routine electronic submission obligations. See OSHA’s guidance at https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16 and the general Part 1904 rule at [1904] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904).

Under 1904.41(a)(1)(i), if an establishment has exactly 20 employees at any point in the year and its NAICS is listed in Appendix A, must it submit Form 300A electronically?

Yes — the requirement applies to establishments with 20–249 employees, so if an establishment has 20 or more employees (up to 249) during the year and its NAICS is listed in [Appendix A] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppA), it must submit OSHA Form 300A electronically under 1904.41(a)(1)(i).

  • References: 1904.41(a)(1)(i) and [Appendix A] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppA).

Under 1904 Subpart E App A, are hospitals (NAICS 6221) included among the industries that require 20–249 employee establishments to submit Form 300A electronically?

Yes — NAICS 6221 (General Medical and Surgical Hospitals) is listed in [Appendix A to Subpart E] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppA), so hospital establishments with 20–249 employees must submit OSHA Form 300A electronically pursuant to 1904.41(a)(1)(i).

  • References: [Appendix A] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppA) and 1904.41(a)(1)(i).

Under 1904, does OSHA enforce electronic submission requirements and identify non-responders for possible citation?

Yes — OSHA actively enforces the electronic-submission requirements, uses its Injury Tracking Application database to identify employers who failed to submit required Form 300A data, and may direct inspections or issue citations for non-submission. See OSHA’s enforcement memorandum at https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16 for details on enforcement procedures and timelines.

Under 1904 Subpart E App A, does NAICS 7211 (Traveler Accommodation) require 20–249 employee establishments to submit OSHA Form 300A electronically?

Yes — NAICS 7211 (Traveler Accommodation) is included in [Appendix A to Subpart E] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppA), so establishments in that industry with 20–249 employees must submit OSHA Form 300A electronically under 1904.41(a)(1)(i).

  • References: [Appendix A] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppA) and 1904.41(a)(1)(i).

Under 1904, if my software produces OSHA Form 300A-equivalent output, can I rely on those records during an OSHA inspection?

Yes — software-generated equivalents of OSHA Forms 300 and 300A are acceptable as long as they meet the equivalence requirements (contain the same information, be as readable and understandable, and be completed using the same instructions) and are made available to authorized government representatives. OSHA’s software-forms interpretation explains that equivalent electronic forms can be used to satisfy Part 1904 recordkeeping requirements, and those records must be accessible during inspections. See OSHA’s interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29 and the general recordkeeping rules in [1904] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904).

Under 1904 Subpart E App A, are NAICS in transportation and warehousing (for example, 4841 General Freight Trucking and 4931 Warehousing and Storage) included for the 20–249 employee submission requirement?

Yes — several transportation and warehousing NAICS appear in [Appendix A] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppA), including 4841 General Freight Trucking and 4931 Warehousing and Storage; establishments in those industries with 20–249 employees must submit OSHA Form 300A electronically under 1904.41(a)(1)(i).

  • References: [Appendix A] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppA) and 1904.41(a)(1)(i).

Under 1904 Subpart E App A, where can I find the official, complete table of designated industries?

You can find the official list of designated industries in [Appendix A to Subpart E of Part 1904] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppA), which contains the NAICS codes and industry titles that trigger the 20–249 employee electronic submission requirement under 1904.41(a)(1)(i).

  • Reference: [Appendix A] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppA) and 1904.41(a)(1)(i).

Under 1904 Subpart E App A, have there been recent updates to the list of designated industries and where are those updates recorded?

Yes — Appendix A shows Federal Register citations indicating updates (for example, 81 FR 29693-29694 May 12, 2016, and 88 FR 47346, July 21, 2023) and the appendix itself is the official source for the current designated industries. See [Appendix A to Subpart E of Part 1904] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppA) for the table and update notes, and refer to [1904.41] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904) for the underlying submission requirement.

  • References: [Appendix A] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartEAppA) and [1904] (https://www.osha.gov/laws-regs/regulations/standardnumber/1904).

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