OSHA Recordkeeping for Manufacturing: Forms, DART, and Electronic Submission

Manufacturing is on Appendix A, so every plant with 20 or more employees submits its 300A, and many with 100 or more submit case data too. The recordkeeping pressure points are restricted work, day counts, and keeping hours worked accurate across shifts.

Manufacturing sites often combine recordable injuries, DART pressure, and electronic filing obligations.

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.

Use a monthly case review to keep the log, the 300A totals, hours worked, and ITA data aligned. 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.

Whatever you use should make these easy to keep and retrieve:

• 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

1. Review cases monthly.
2. Reconcile hours by shift.
3. Classify outcomes consistently.
4. Prepare ITA-ready exports per plant.

Plant managers are often the certifying executive, so the monthly review is also how you make sure you can sign in January with confidence.

Keep these in mind when you compare approaches:

• Teams rely on year-end cleanup after months of restrictions, transfers, and medical updates.
• Multiple production lines or shared staffing can complicate establishment and supervision facts.
• For 300 and 301 case data, OSHA excludes employee names and addresses and health care provider details from the submission (1904.41(b)(9)).

Spreadsheets fail quietly: a sort that renumbers rows, a tab copied for the new year, a formula that misses a new column. None of that shows on the printed form, which is why any system, including a spreadsheet, should be tested on real historical cases before it is trusted.

A 220-person plastics plant (3261, on Appendix B) runs three shifts. Its monthly review closes restricted-work day counts, and payroll's hours report is split by shift so overtime is not double counted. In February it submits 300A data plus 300 and 301 case data for its 14 recordable cases.

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.

• NAICS Codes for OSHA Electronic Submission: How to Check Coverage
• OSHA ITA CSV Template for 300A Data: Field Prep Guide
• How to Upload OSHA 300A Electronically Through the ITA
• Temporary Workers and OSHA 300 Logs: Who Records the Case?