Federal injury and illness reporting

Each agency must submit all of the data entered on the OSHA Form 300, OSHA Form 301, and OSHA Form 300A (or equivalent) for the previous calendar year by May 1.

• This means every field and record your agency put on the OSHA Form 300, Log of Work-Related Injuries and Illnesses, OSHA Form 301, Injury and Illness Incident Report, and OSHA Form 300A, Summary of Work-Related Injuries and Illnesses, or an equivalent format, must be included in the submission.

See the requirement in 1960.72(a).

Yes — an agency may use equivalent forms, but the submission must include all data entered on the OSHA forms (or their equivalents).

• The regulation explicitly allows use of "equivalent" forms but requires that the information submitted include all data entered on OSHA Form 300, OSHA Form 301, and OSHA Form 300A (or equivalent).

See 1960.72(a).

The Secretary must provide the electronic submission format and guidelines to each agency by January 15 of each year.

• Agencies should expect to receive the specified format and instructions by that date so they can prepare their May 1 submissions.

See 1960.72(b).

The May 1 submission covers the agency's previous calendar year's occupational injury and illness records.

• For example, the May 1, 2025 submission would include all data from calendar year 2024.

See 1960.72(a).

The establishment list must include department/agency affiliation, NAICS code, street address, city, state, and zip code for each establishment.

• Agencies first had to submit this list by May 1, 2014 and must update it annually thereafter.

See 1960.72(c).

Agencies were required to submit the list of all establishments to the Secretary by May 1, 2014.

• After the initial submission, agencies must update the list annually by May 1 when they submit their annual injury and illness report.

See 1960.72(c).

An agency must update its list of establishments annually and submit the updated list to the Secretary by May 1 of each year when it submits the annual report required by 1960.71(a)(1).

• This annual synchronization ensures the Secretary has current establishment addresses, NAICS codes, and department/agency affiliations.

See 1960.72(c) and the cross-reference to 1960.71(a)(1).

Yes — agencies are expected to submit their occupational injury and illness recordkeeping information electronically using the format and guidelines the Secretary provides.

• The Secretary is required to provide the electronic format and submission guidelines by January 15 each year, which agencies then use to prepare their May 1 electronic submissions.

See 1960.72(b) and 1960.72(a).

Yes — agencies must include all data entered on OSHA Form 301 (or an equivalent), which includes the detailed incident information captured on that form.

• The regulation makes no exemption for descriptive fields, so agencies should be prepared to submit the full set of fields present on Form 301 or equivalent records.

See 1960.72(a).

An agency may keep its own internal recordkeeping format, but when reporting to the Secretary it must submit all of the data required (i.e., the data entered on OSHA Forms 300, 301, and 300A or their equivalents) in the electronic format and according to the guidelines the Secretary provides.

• Make sure your internal fields map to the Secretary's required fields so nothing is omitted in the May 1 submission.

See 1960.72(a) and 1960.72(b).

Yes — the list of establishments must include all establishments, which covers satellite offices and remote worksites, with their department/agency affiliation, NAICS code, and full street address information.

• If a remote worksite functions as a distinct establishment for your agency, include it on the list submitted by May 1.

See 1960.72(c).

The requirement in 1960.72(c) to update the establishment list is tied to the annual report submission required by 1960.71(a)(1); agencies must update their establishment list by May 1 when they submit that annual report.

• In short, the May 1 reporting obligation for injury and illness data and the annual establishment list update are coordinated with the report required under 1960.71(a)(1).

See 1960.72(c) and 1960.71(a)(1).

The regulation states that each agency must submit the required information to the Secretary, so the agency (through its designated safety/OSH program office or responsible official) is responsible for making the submission.

• Agencies should follow their internal assignment of responsibility for OSHA reporting and ensure the designated office uses the format and timelines in 1960.72(b).

See 1960.72(a) and 1960.72(b).

Yes — federal agencies are required to submit the data described in 1960.72, and OSHA has issued enforcement guidance and memoranda on recordkeeping and reporting practices that inform compliance expectations.

• For general recordkeeping enforcement and employee reporting protections (in the private-sector context and as guidance for enforcement practices), see the Recordkeeping enforcement procedures memorandum.

See 1960.72(a) and the 2016 recordkeeping enforcement procedures interpretation.

If a NAICS code for an establishment changes, the agency should reflect the updated NAICS code on the next annual establishment list update submitted by May 1.

• Keep internal records current and ensure the annual submission to the Secretary includes the then-current NAICS code for each establishment.

See 1960.72(c).

Yes — each agency must submit all information included on the agency's previous calendar year's occupational injury and illness recordkeeping forms, which means agencies should submit the required forms (including a Form 300A summary or equivalent) even if the year shows zero recordable cases.

• Submitting a completed set of the required fields (with zeroes where appropriate) satisfies the requirement to report the prior year's records.

See 1960.72(a).

The regulation requires the Secretary to provide the format and guidelines for electronic submission by January 15, but it does not spell out specific privacy safeguards in the text of 1960.72; agencies should follow the format and guidance the Secretary issues and applicable federal privacy rules.

• When the Secretary issues the format and guidelines, they will provide the official instructions agencies must follow for electronic submissions.

See 1960.72(b) and the general reporting requirements in 1960.72(a).

If records are maintained in a database, the agency must export or map the database fields so the submission includes all of the data entered on OSHA Forms 300, 301, and 300A (or equivalents) in the electronic format and according to the guidelines the Secretary provides.

• Confirm field mapping to the Secretary's required fields after the January 15 format/guideline release to avoid omissions.

See 1960.72(a) and 1960.72(b).

Submitting an accurate establishment list supports the Secretary's and agency's ability to monitor workplace injury and illness trends, which helps agencies meet their broader duty to provide workplaces free from recognized hazards under 1960.8.

• While 1960.72 focuses on reporting, 1960.8 imposes the agency obligation to furnish employment and workplaces free from recognized hazards; accurate data and establishment information facilitate that oversight.

See 1960.72(c) and the agency responsibility discussed in 1960.