Three groups of establishments must submit injury data electronically through OSHA's Injury Tracking Application (ITA) by March 2 each year, covering the prior calendar year (29 CFR 1904.41): establishments with 20 to 249 employees in designated industries (construction is one), establishments with 250 or more in any industry that keeps records, and establishments with 100 or more in a shorter high-hazard list, which submit case detail too. For most small construction companies the duty is one 300A summary per establishment, once a year.
The three coverage categories
| Your establishment | What you submit | Rule |
|---|---|---|
| 20 to 249 employees, in a designated industry (Appendix A: construction, manufacturing, agriculture, utilities, warehousing, and more) | Form 300A summary data | 1904.41(a)(1) |
| 250 or more employees, any industry required to keep records | Form 300A summary data | 1904.41(a)(1) |
| 100 or more employees, in a shorter high-hazard list (Appendix B) | Form 300 and 301 case data, plus the 300A | 1904.41(a)(2) |
Two construction-specific notes. First, the whole construction sector (NAICS 23) is on the Appendix A designated list, so a construction establishment with 20 or more employees is in. Second, Appendix B mostly covers industries like logging, slaughtering, hospitals, and trucking, but it does include NAICS 2381, foundation, structure, and building exterior contractors. A roofing, framing, masonry, or siding contractor that grows past 100 employees at one establishment graduates to submitting case-level 300 and 301 data, not just the summary.
OSHA can also tell any employer in writing to submit, regardless of size or industry (1904.41(a)(3)).
How employees are counted
The thresholds are per establishment, not per company, and the count is everyone employed there at any time during the calendar year: full-time, part-time, seasonal, and temporary workers all count as one each (1904.41(b)(2)). A trades contractor that runs 15 in winter and staffs to 24 for the summer push is a 24 for this rule. If you crossed 20 at any point last year, plan on filing this March 2.
How the submission actually works
- Finish the 300A first. The e-file is the same data as the posted summary: totals, employment average, and hours. Get those right once and both obligations are done.
- Sign in to the ITA at osha.gov/injuryreporting. Accounts authenticate through Login.gov, so leave time for that setup the first year.
- Submit one of three ways: type it into the web form (fine for one establishment), upload a CSV in OSHA's format (multiple establishments), or push it through the API (software like ours). Include your legal company name; submissions require it (1904.41(b)(10)).
- Do it by March 2. The reporting window for a calendar year's data closes March 2 of the following year (1904.41(c)). For 2026 data, that's March 2, 2027.
What OSHA does with it
Submitted data feeds OSHA's enforcement targeting and public data files. Establishment-level injury data is published, which means your rates are visible to anyone who looks, including GCs and insurers. One more reason the recordable decision deserves rigor all year: the totals you certify in February become the TRIR the market sees.
The e-file, prepped and validated
SiteSafetyHQ builds your ITA export from the log to OSHA's own CSV spec, with every cross-field check applied before you upload, so it doesn't bounce. Deadline reminders start in January, per establishment, and the March 2 date can't sneak up on you.
No card, no demo call. Flat $39 to $199/mo by company size.
Quick answers
We're a 12-person shop. Do we e-file anything?
No. Under 20 employees at every point in the year means no ITA duty. You still keep the 300, 301, and 300A and post the summary each February unless you're exempt.
Does e-filing replace posting the 300A on the wall?
No. They're separate obligations with separate dates: paper on the wall February 1 through April 30, data through the ITA by March 2. Same numbers, both required if you're covered by both rules.
Do employee names go to OSHA in the submission?
The 300A contains no names, so the common 20-to-249 submission sends totals only. For the 100-plus Appendix B establishments submitting 300/301 case data, OSHA's collection is designed to omit identifying fields like the employee name from what's published.
Can my software or consultant file for us?
Yes. Third-party submission on an employer's behalf is an ordinary part of the ITA, including by API. The obligation stays yours; the typing doesn't have to be.
Primary sources (checked August 4, 2026): 29 CFR 1904.41 (electronic submission) · Appendix A to Subpart E (20 to 249 designated industries) · Appendix B to Subpart E (100 plus case-data industries) · osha.gov/injuryreporting (ITA)
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