Brian Baumler
Director of Risk Control
300A posting requirements
Many employers with more than 10 employees are required to keep a record of work-related injuries and illnesses (OSHA Logs). All establishments subject to this requirement must complete and post the OSHA Annual Summary Form 300A by February 1, even if no work-related injuries or illnesses occurred during the calendar year. By February 1 each year, you must:
- Review the 300 Log to verify that case entries are complete and accurate.
- Complete the Summary Form 300A using the information recorded on the 300 Log.
- Compile the Total Hours Worked and Annual Average Number of Employees.
- Certify and date the 300A Summary Form.
- Post the Annual Summary from February 1 to April 30 of the year following the year covered.
- Post a copy in each establishment in a conspicuous place or places where notices to employees are customarily posted.
- Ensure the posted 300A is not altered, defaced, or covered by other material.
Electronic submission requirements
The electronic filing requirement applies to the establishments listed below:
- Establishments with 20 to 249 employees in specific industries with higher instances of injuries or illnesses must submit the information from Form 300A electronically. Review the full list of covered industries.
- Establishments with 250 or more employees that are required to keep OSHA injury and illness records must submit the information from Form 300A electronically.
- Upon notification, you must electronically submit the requested information from your OSHA injury and illness records to OSHA or OSHA's designee.
Note: Employers can find instructions for registering and recording the 300A data on OSHA’s Injury Tracking Application webpage. Establishments must submit the required information by March 2 of the year following the calendar year covered.
Partial exemptions
Employers in certain low-risk industries are exempt from these requirements unless OSHA, the BLS, or the Division of Occupational Safety and Health asks them to do so. Review the ITA Coverage Application to determine if your establishment is required to electronically submit data to OSHA.
Follow these steps to determine if you qualify for the partial exemption:
- Determine your NAICS and identify the first four numbers.
- Review the Exception Table. If your first four numbers appear on the table, your company is exempt unless otherwise required.
Requirements for employers with over 100 employees
Certain employers in designated high-hazard industries must electronically submit additional injury and illness information beyond what is currently required, but employers are already required to keep:
- Establishments with 100 or more employees in certain high-hazard industries must electronically submit information from their Form 300, Log of Work-Related Injuries and Illnesses, and Form 301, Injury and Illness Incident Report, to OSHA once a year. Review the full list of covered industries. These submissions are in addition to the submission of Form 300A, Summary of Work-Related Injuries and Illnesses.
- Establishments are required to include their legal company name when making electronic submissions to OSHA from their injury and illness records to improve data quality.
Small employer exemptions
If you had 10 employees or fewer in 2024, you are exempt from maintaining these logs unless requested by OSHA or the Bureau of Labor Statistics (BLS).
If you would like to discuss further, please contact an MMA representative today.
Resources
OSHA Recordkeeping - Overview | Occupational Safety and Health Administration
Injury & Illness Recordkeeping Forms – 300, 300A, 301
Read the Full OSHA Recordkeeping Regulation (29 CFR 1904)
Video Tutorial on Completing the Recordkeeping Forms
