Correcting an OSHA ITA Submission After You Find an Error
Fix the source records first, then update the submitted data in the ITA so it matches, and keep a note of what changed, when, and why.
The short version
Fix the source records first, then update the submitted data in the ITA so it matches, and keep a note of what changed, when, and why. Check the ITA's current guidance on editing a submission, and save the confirmation of the corrected version.
Submission confirmation does not mean the source data was perfect.
What you need before you start
Gather these first, and keep them with the record afterward:
- 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
The rule behind the steps
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.
Step by step
- Identify the error and its source.
- Correct the log or the summary.
- Update the ITA record to match.
- Keep the correction notes and confirmations.
Tip: Use a correction workflow that preserves the original basis and updates the submitted record when appropriate.
Where this usually goes wrong
Teams quietly fix spreadsheets without reconciling the ITA record.
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.
Special situations
- Errors discovered after March 2 still need a controlled correction decision.
- An establishment may use a number or code as its name in the ITA, as long as the submission includes a legal company name.
A worked example
In April an analyst finds that one site's hours worked included 18,000 hours of paid leave. The payroll figure is corrected, the 300A worksheet is updated, the ITA submission for that establishment is edited to the new hours, and the note in the 2026 folder records both figures and the reason.
How it affects the rest of your records
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.
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
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)).
Does electronic submission replace posting the 300A?
No. Posting the certified 300A from February 1 to April 30 is a separate duty under 29 CFR 1904.32.
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).
Sources
Primary regulation and agency guidance this article relies on.
- [1]OSHA Injury Tracking Application informationOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [2]OSHA Injury Tracking Application frequently asked questionsOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [3]29 CFR 1904.41: Electronic submission requirementsOccupational 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.