EIN for OSHA ITA: Multi-Establishment Filing Questions

Give each covered establishment the EIN it actually uses; if all sites operate under one legal entity they may share it, but confirm rather than copy. Reorganizations and payroll provider changes are the usual source of mismatches from one year to the next.

EIN cleanup can block ITA readiness even when injury totals are complete.

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

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.

1. Inventory the establishments.
2. Verify each EIN at the source.
3. Validate the exports.
4. Keep the basis for each EIN.

Tip: Provide the EIN used by each covered establishment and reconcile changes before upload.

Teams copy one corporate EIN across every location without confirming the establishment 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.

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.

• Reorganizations and payroll changes can create year-over-year identifier mismatches.
• For 300 and 301 case data, OSHA excludes employee names and addresses and health care provider details from the submission (1904.41(b)(9)).

A company with 20 stores under one corporation uses one EIN for all of them. After it acquires 5 stores that keep their own legal entity for a year, those 5 use the acquired company's EIN for that year's submission.

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.

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 ITA Employee Count Thresholds: 20, 100, and 250 Explained
• OSHA ITA Submission Confirmation: What Proof to Keep After Filing
• OSHA Recordkeeping for Manufacturing: Forms, DART, and Electronic Submission
• Multi-Establishment OSHA Tracking Software: What to Require Before Buying