High-Hazard Industries and OSHA Electronic Reporting: What 20 to 249 Employee Establishments Need to Know

A 20 to 249 employee establishment submits its 300A if its industry is on Appendix A, which covers construction, manufacturing, and wholesale trade. It also includes many retail, transportation, warehousing, healthcare, and hospitality codes, so check the establishment's own code rather than the company's main line of business.

Mid-size establishments can be covered because of industry even when the company is not large.

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.

Check whether the establishment's NAICS code appears on OSHA's Appendix A list for electronic 300A submission. 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.

Operations leaders rarely make the recordkeeping call, but they control the schedules, postings, and site managers that make the deadlines work.

Teams sometimes assume only establishments with 250 or more employees file electronically.

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.

• Industry classification should be reviewed when operations change materially.
• Partially exempt establishments under 1904.1 or 1904.2 do not submit routinely, but must if OSHA notifies them in writing.

A 65-person hotel (7211) and a 65-person accounting office (5412) are the same size. The hotel is on Appendix A and submits its 300A; the accounting office is partially exempt and keeps no routine records at all.

1. Find the establishment's peak headcount.
2. Validate its NAICS code against Appendix A.
3. Prepare the 300A data.
4. Submit before 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

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.

• OSHA 300 and 301 Electronic Reporting for 100+ Employee Establishments
• EIN in OSHA ITA Submissions: Why the Field Matters
• OSHA ITA API vs CSV Upload: Which Submission Method Fits Your Team?
• OSHA ITA 2027 Planning: Build the Filing Calendar Before January