NAICS Codes for OSHA Electronic Submission: How to Check Coverage
Your establishment's NAICS code decides whether a 20 to 249 employee site submits its 300A (Appendix A) and whether a 100+ site submits 300 and 301 data (Appendix B).
The answer up front
Your establishment's NAICS code decides whether a 20 to 249 employee site submits its 300A (Appendix A) and whether a 100+ site submits 300 and 301 data (Appendix B). Use the code for the establishment's actual activity, not an old code from accounting, and confirm it with OSHA's ITA Coverage Application.
NAICS code cleanup is boring until it blocks an ITA decision on February 28.
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.
Applying it to real cases
Use OSHA's listed industries to decide whether 20 to 249 employee establishments submit 300A data. 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.
Compliance managers are judged on whether the records hold up later, so focus on the basis for each decision and a clean history of changes.
Where teams go wrong
Teams reuse an old accounting NAICS code without confirming the establishment's actual industry.
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.
Situations that change the answer
- Acquisitions and mixed operations can change the practical classification conversation.
- 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
A company's tax filings use 5416 (management consulting) for all sites, but one site actually runs a distribution center. Under the right code (4931, warehousing and storage), its 85 employees put it on Appendix A, so it must submit 300A data. The consulting code would have hidden the obligation.
A checklist you can reuse
- Confirm what the establishment actually does.
- Find its NAICS code.
- Check Appendix A and Appendix B to Subpart E.
- Keep the basis for the decision.
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
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)).
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.
Sources
Primary regulation and agency guidance this article relies on.
- [1]OSHA NAICS codes for electronic submissionOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [2]OSHA ITA Coverage ApplicationOccupational 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.