Designated industries for reporting

Yes. Under 1904.41(a)(2) establishments with 100 or more employees in the industries listed in Appendix B must electronically submit OSHA Forms 300, 301, and 300A. Appendix B includes NAICS code 3111 (Animal Food Manufacturing), so an establishment in that NAICS with 120 employees must submit all three forms. See also OSHA's enforcement guidance on electronic submittal requirements in the April 16, 2024 memorandum at https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16.

Consult Appendix B to Subpart E of Part 1904—the designated industries list—because 1904.41(a)(2) requires establishments in those NAICS codes with 100+ employees to submit Forms 300, 301, and 300A. The Appendix B list is published with the Part 1904 materials at https://www.osha.gov/laws-regs/regulations/standardnumber/1904 and contains the NAICS codes (for example, 3111, 3211, 6221, etc.) that trigger the requirement. OSHA's April 16, 2024 enforcement memorandum (https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16) summarizes these submission obligations.

The employee-count threshold is measured at the establishment level. 1904.41(a) and the Appendix B requirement apply to establishments (not the entire company) that have 100 or more employees; the enforcement memorandum dated April 16, 2024 also explains that obligations apply to establishments meeting the NAICS and size criteria (https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16).

Yes. An establishment that had 100 or more employees at any time during the calendar year meets the size threshold for submission under 1904.41(a)(2); therefore, if it reached 102 employees on December 31, it must submit the required Forms 300, 301, and 300A for that calendar year. OSHA's April 16, 2024 memorandum explains the annual submission timing and the requirement to submit data for the preceding calendar year (https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16).

Yes. Appendix B lists NAICS code 6221, so establishments in General Medical and Surgical Hospitals with 100 or more employees must electronically submit OSHA Form 301 (in addition to Forms 300 and 300A) under 1904.41(a)(2). See the Appendix B list at https://www.osha.gov/laws-regs/regulations/standardnumber/1904 and OSHA's enforcement guidance at https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16.

Generally no. Establishments that had fewer than 20 employees at all times during the year are not required to routinely submit OSHA Form 300A electronically. 1904.41 and OSHA's April 16, 2024 memorandum explain that establishments with fewer than 20 employees do not have to routinely submit information electronically, though other rules or targeted initiatives could still apply (https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16).

Each physical establishment must evaluate its own NAICS code and employee count to determine its submission obligations under 1904.41(a)(2). If an individual establishment’s NAICS is listed in Appendix B and that establishment had 100+ employees during the year, that establishment must submit Forms 300, 301, and 300A irrespective of other company locations. See Appendix B at https://www.osha.gov/laws-regs/regulations/standardnumber/1904 and OSHA's enforcement memorandum at https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16.

Use the NAICS code that accurately describes the establishment's primary business activity for the calendar year when determining submission requirements under 1904.41(a)(2). If the primary activity and NAICS change during the year, make a good-faith determination of the code that best represents the establishment's operations for the period covered and document that determination. OSHA's Appendix B list at https://www.osha.gov/laws-regs/regulations/standardnumber/1904 and the April 16, 2024 memorandum (https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16) support relying on NAICS to decide which establishments must report.

Yes, states with OSHA-approved State Plans must have injury and illness recordkeeping and reporting programs that are at least as effective as federal OSHA's, so State Plans generally follow the same NAICS-based submission approach in Appendix B for establishments meeting the thresholds under 1904.41(a)(2). Employers should check their State Plan's specific guidance, and see federal Appendix B at https://www.osha.gov/laws-regs/regulations/standardnumber/1904 and OSHA’s enforcement memorandum at https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16 for the federal baseline.

Yes. NAICS 4841 (General Freight Trucking) appears in Appendix B, so an establishment in that industry with 100 or more employees must submit Forms 300, 301, and 300A electronically under 1904.41(a)(2). See the Appendix B NAICS listing at https://www.osha.gov/laws-regs/regulations/standardnumber/1904 and OSHA's April 16, 2024 guidance on submission responsibilities at https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16.

Yes. Under 1904.41(a)(2) establishments in Appendix B with 100+ employees are required to submit the Log (Form 300), the Incident Report (Form 301), and the Summary (Form 300A) as specified. OSHA’s April 16, 2024 memorandum explains that establishments meeting the Appendix B criteria must submit Forms 300 and 301 in addition to Form 300A, and that Area Offices may review submissions during inspections (https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16). If you use equivalent or electronic formats, ensure they meet the equivalency requirements described in OSHA guidance (see also https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29).

Yes—if they are equivalent. OSHA allows employers to use software-generated documents in place of OSHA Forms when those documents meet the equivalency requirements in 29 CFR 1904.29 and 1904.32. The April 29, 2025 Letter of Interpretation (https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29) explains that electronic or alternative forms are acceptable provided they contain the same information, are as readable and understandable, and are completed using the same instructions as the OSHA forms. Employers must also meet access and inspection obligations described in 1904.40 and related recordkeeping provisions.

The annual submission deadline for the preceding calendar year's OSHA Form 300A data is March 2. OSHA's April 16, 2024 memorandum on enforcement clarifies that Forms 300A, 300, and 301 for the preceding year must be submitted by March 2, and that employers who fail to submit may be cited within six months (https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16). See 1904.41 for the regulatory requirement.

Yes. NAICS 4931 is listed in Appendix B; therefore, establishments in Warehousing and Storage with 100 or more employees must electronically submit Forms 300, 301, and 300A under 1904.41(a)(2). See the Appendix B listing at https://www.osha.gov/laws-regs/regulations/standardnumber/1904 and OSHA's April 16, 2024 memorandum for enforcement details (https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16).

No. An establishment only triggers the Appendix B submission requirement if it had 100 or more employees at any time during the calendar year. If a seasonal establishment never reaches 100 employees during the year, it does not meet the size threshold under 1904.41(a)(2) and therefore is not required to submit Forms 300 and 301 for that year. See OSHA’s enforcement guidance at https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16.

Yes. Establishments with 100 employees meet the regulatory threshold. Under 1904.41(a)(2) establishments in Appendix B NAICS codes such as 6231 with 100 or more employees must submit Forms 300, 301, and 300A electronically. OSHA’s April 16, 2024 memorandum provides enforcement timing and submission expectations (https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16).

The official Appendix B list is published as part of Part 1904 materials; you can find the designated-industry list for electronic submissions at https://www.osha.gov/laws-regs/regulations/standardnumber/1904 which contains Appendix B to Subpart E. That Appendix B shows the NAICS codes (for example, 3211 Sawmills and Wood Preservation and 3361 Motor Vehicle Manufacturing) that trigger the 1904.41(a)(2) submission requirement. See OSHA’s April 16, 2024 memorandum (https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16) for enforcement context.

Yes, if the non-OSHA layouts are equivalent. OSHA permits employers to maintain and produce equivalent forms as long as they include the same information, are as readable and understandable, and follow the same instructions as the OSHA forms under 29 CFR 1904.29 and 1904.32. The April 29, 2025 Letter of Interpretation explains that software-generated or alternative forms are acceptable when they meet those equivalency requirements (https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29). Employers must still meet access and submission obligations under 1904.41.

Yes. NAICS 4413 is listed in Appendix B; therefore an establishment in that NAICS with 100 or more employees must electronically submit OSHA Forms 300, 301, and 300A pursuant to 1904.41(a)(2). See the Appendix B list at https://www.osha.gov/laws-regs/regulations/standardnumber/1904 and the April 16, 2024 enforcement memorandum for details (https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16).

Keep records that show the software-generated documents are equivalent to OSHA Forms and that the submission was completed for the required reporting period. Specifically, retain copies of the submitted Forms 300, 301, and 300A (or their equivalent), the software output demonstrating the required data fields, submission receipts or confirmations, and any internal documentation showing the establishment’s NAICS and employee counts. OSHA’s April 29, 2025 Letter of Interpretation explains equivalency requirements for software-generated forms (https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29), and 1904.41 and the April 16, 2024 memorandum cover submission duties and enforcement (https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16).

Yes. NAICS 5621 appears in Appendix B, so establishments in Waste Collection with 100 or more employees must submit OSHA Form 300 along with Forms 301 and 300A electronically under 1904.41(a)(2). See the Appendix B listing at https://www.osha.gov/laws-regs/regulations/standardnumber/1904 and OSHA’s enforcement memorandum dated April 16, 2024 (https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16).

Determine the establishment’s primary activity and corresponding NAICS code and apply the Appendix B requirement to that establishment. If a single physical establishment legitimately operates multiple activities, use the NAICS that best describes the primary business activity at that location; if that NAICS is in Appendix B and the establishment had 100+ employees, submit Forms 300, 301, and 300A for that establishment under 1904.41(a)(2). Document the rationale for the chosen NAICS. See Appendix B at https://www.osha.gov/laws-regs/regulations/standardnumber/1904 and the April 16, 2024 OSHA memorandum for submission expectations (https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16).