OSHA ITA Employee Count Thresholds: 20, 100, and 250 Explained
ITA thresholds use peak establishment headcount: 20 to 249 in Appendix A industries, 250 or more if the establishment keeps records, and 100 or more for Appendix B.
The short answer
ITA thresholds use peak establishment headcount: 20 to 249 in Appendix A industries, 250 or more if the establishment keeps records, and 100 or more for Appendix B. Every individual counts, including part-time, seasonal, and temporary workers.
ITA coverage depends on establishment size and industry category, not just total company headcount.
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.
ITA coverage at a glance
- 250 or more employees at any time last year, and the establishment keeps records: submit 300A data.
- 20 to 249 employees and an industry on Appendix A to Subpart E (for example agriculture, utilities, construction, manufacturing, wholesale trade, and many retail, transportation, warehousing, healthcare, and hospitality codes): submit 300A data.
- 100 or more employees and an industry on Appendix B (for example many food, metal, and furniture manufacturing codes, hospitals, nursing homes, warehousing, and grocery and department stores): submit 300 and 301 case data as well as 300A data.
- Partially exempt under 1904.1 or 1904.2: no routine submission unless OSHA notifies you in writing.
- Deadline: March 2, 2027 for 2026 data. OSHA's ITA Coverage Application gives an official answer for a specific NAICS code.
How it plays out on site
Check 20 to 249 employee establishments, 250+ establishments, and 100+ designated-industry establishments separately. 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.
The common mistake
Teams apply one headcount rule to every submission category.
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
- Peak employment during the previous calendar year can change the answer.
- Partially exempt establishments under 1904.1 or 1904.2 do not submit routinely, but must if OSHA notifies them in writing.
Worked example
A distribution center averages 90 employees but hires 30 seasonal workers every December, reaching 120. Because the thresholds use peak headcount (every individual employed at any time), it counts as a 100+ establishment, and warehousing is on Appendix B, so it submits 300 and 301 case data as well as the 300A.
Checklist
- Find each establishment's peak headcount.
- Check its industry lists.
- Decide which data set applies.
- Document the coverage 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]29 CFR 1904.41: Electronic submission requirementsOccupational 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]OSHA NAICS codes for electronic submissionOccupational 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.