OSHA ITA Filing With No Injuries: What to Submit for Zero Cases
A covered establishment with no recordable cases still submits its 300A to the ITA, with zero case totals plus real employee and hours figures.
Quick answer
A covered establishment with no recordable cases still submits its 300A to the ITA, with zero case totals plus real employee and hours figures. Coverage depends on size and industry, not on whether anyone was hurt.
No injuries can still require a complete submission for covered establishments.
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.
What this looks like in practice
Submit the required 300A information with zero case totals when the establishment is covered. 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 mistake to avoid
Teams confuse no recordable cases with no ITA obligation.
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 worth checking
- Employer size, industry, and establishment coverage still control the electronic submission question.
- For 300 and 301 case data, OSHA excludes employee names and addresses and health care provider details from the submission (1904.41(b)(9)).
Example
A 30-person metal fabrication shop (3323) had a year with no recordable cases. It is on Appendix A with more than 20 employees, so it submits a 300A with zeros in the case and day totals, 31 average employees, and 61,500 hours worked.
Step by step
- Confirm the establishment is covered.
- Complete the 300A with zero totals.
- Submit it to the ITA.
- Document why any site is not covered.
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
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).
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)).
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]29 CFR 1904.32: Annual summary certification and postingOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [3]29 CFR 1904.29: OSHA Forms 300, 300A, and 301Occupational 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.