OSHA 300 and 301 Electronic Reporting for 100+ Employee Establishments
Establishments with 100 or more employees in Appendix B industries submit case data from the 300 and 301 each year, in addition to the 300A.
Quick answer
Establishments with 100 or more employees in Appendix B industries submit case data from the 300 and 301 each year, in addition to the 300A. OSHA excludes names, addresses, and health care provider details from what you submit.
Some establishments now need more than 300A summary data.
The rule in plain English
Covered establishments submit injury data to OSHA's Injury Tracking Application (ITA) by March 2 each year for the previous calendar year; for 2026 data that is March 2, 2027 (29 CFR 1904.41). Three groups must submit: establishments with 250 or more employees that must keep records (300A data); establishments with 20 to 249 employees in an industry listed in Appendix A to Subpart E (300A data); and establishments with 100 or more employees in an industry listed in Appendix B (300A data plus 300 and 301 case data). Headcount means every individual employed at any time in the prior year, including part-time, seasonal, and temporary workers, and every submission includes the establishment's EIN.
Fields OSHA excludes from case data submissions
Under 1904.41(b)(9), establishments that submit 300 and 301 data leave out:
- OSHA 300: the employee's name (column B)
- OSHA 301: the employee's name (field 1) and address (field 2)
- OSHA 301: the name of the physician or other health care professional (field 6)
- OSHA 301: the facility name and address, if treatment was given away from the worksite (field 7)
Everything else on the forms, including the free-text answers about the case, is submitted, so review it for identifying details first.
What this looks like in practice
Establishments in designated industries with 100 or more employees submit 300 and 301 data electronically. Most ITA problems are establishment data problems: an old NAICS code, a parent-company EIN, or a headcount measured at the wrong level. The fix is to decide coverage per establishment in the fall, clean the EIN, NAICS, and address data then, and leave only validation and submission for February.
At the director level the question is less about one case and more about whether every site applies the rule the same way, with evidence you could show an inspector.
The mistake to avoid
Teams often sanitize internal case notes too late for detailed electronic reporting.
The ITA submission is built from the certified 300A (and, for Appendix B establishments, the 300 and 301), so every correction to the log has to be reconciled with what was submitted.
Edge cases worth checking
- Privacy and PII controls matter more when detailed data leaves the internal system.
- For 300 and 301 case data, OSHA excludes employee names and addresses and health care provider details from the submission (1904.41(b)(9)).
Example
A 140-employee poultry processing plant (3116, on Appendix B) had 11 recordable cases. Its submission includes the 300A totals and, for each of the 11 cases, the 300 entry (without the name) and the 301 details (without the employee's name and address or the provider's details). The team reviews the free-text answers first and removes a coworker's name mentioned in one of them.
Step by step
- Confirm Appendix B coverage and peak headcount.
- Prepare case-level 300 and 301 data.
- Review free-text fields for privacy.
- Submit with the 300A by March 2, 2027.
What to keep in the case file:
- The coverage decision for each establishment: peak headcount, NAICS code, and which appendix applies
- The EIN used by each establishment
- The submitted file or payload and the ITA confirmation
- Notes on any corrections made after submission
Where 300log helps
300log validates EIN and NAICS formats, produces ITA-ready CSV files for the 300A and for case data, and can authorize auto-filing of 300A data once you connect an ITA API token.
For a quick answer without an account, use the free ITA coverage checker.
Frequently asked questions
How can we submit to the ITA?
Through the ITA by entering data in the web form, uploading a CSV file, or sending it through the ITA's API. OSHA publishes CSV and API documentation.
Who has to submit to the OSHA ITA?
Establishments with 250 or more employees that keep records, establishments with 20 to 249 employees in Appendix A industries, and establishments with 100 or more employees in Appendix B industries (which also submit 300 and 301 case data).
When is the ITA deadline for 2026 data?
March 2, 2027.
Do temporary and part-time workers count toward the thresholds?
Yes. Each individual employed in the establishment at any time during the year counts as one employee, including part-time, seasonal, and temporary workers (29 CFR 1904.41(b)(2)).
Sources
Primary regulation and agency guidance this article relies on.
- [1]29 CFR 1904.41: Electronic submission requirementsOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [2]OSHA Injury Tracking Application informationOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [3]OSHA Injury Tracking Application frequently asked questionsOccupational Safety and Health Administration · osha.gov(opens in a new tab)
Written and reviewed by the 300log Editorial Team. Guidance, not legal advice: confirm edge cases with OSHA or counsel.