Do I need to submit to OSHA's ITA?

Who has to submit to the ITA

OSHA’s Injury Tracking Application (ITA) collects injury data from three groups of establishments under 29 CFR 1904.41, as amended in 2023:

• 250 or more employees at an establishment that must keep OSHA records: submit the Form 300A summary.
• 20 to 249 employees in an industry listed in Subpart E Appendix A: submit the 300A.
• 100 or more employees in an industry listed in Appendix B: also submit case data from the 300 log and the 301 incident reports.

OSHA can also require any establishment to submit by notifying it in writing (29 CFR 1904.41(a)(3)), and every submission must include the company’s EIN.

How to count employees

Coverage turns on the establishment’s peak headcount during the previous calendar year: the most individuals employed at any one time. Count full-time, part-time, seasonal and temporary workers as individuals, not full-time equivalents (29 CFR 1904.41(b)(2)). An establishment is one physical location, so a company with a 300-person plant and a 40-person depot checks each one separately.

Two exemptions come first

A company with 10 or fewer employees at all times last year is partially exempt from routine recordkeeping (29 CFR 1904.1). So are establishments in the industries listed in Subpart B Appendix A, such as banks, insurance carriers, law firms and software developers (29 CFR 1904.2). Neither group submits unless OSHA asks in writing. Both still report fatalities within 8 hours, and hospitalizations, amputations and eye loss within 24 hours.

Why the NAICS code needs four digits

Appendix A covers whole sectors such as construction (23), manufacturing (31–33) and wholesale trade (42), plus specific four-digit industries like general freight trucking (4841), warehousing (4931) and hospitals (6221–6223). Appendix B is narrower. Both use 2017 NAICS codes, while the partially exempt list uses 2007 codes, so look up the code for the specific establishment rather than the company’s headline code. A 2022 code works too: where 2022 renumbered an industry, the checker reads it as the 2017 code it replaced.

A worked example

A nursing home (NAICS 6231) peaked at 140 employees last year. 6231 is on Appendix A, so at 20 or more employees it submits the 300A. It is also on Appendix B, and at 100 or more it submits 300 and 301 case data too. The same company’s 60-person warehouse (4931) submits only the 300A, because Appendix B case data starts at 100 employees.

Common mistakes

• Using FTEs or an annual average. The test is the peak number of individuals at one time.
• Testing the company instead of the location. Apart from the 10-employee exemption, coverage is decided per establishment.
• Stopping at two digits. Outside the fully covered sectors, the lists work at the four-digit industry level.
• Waiting for Monday. March 2 doesn’t roll over when it falls on a weekend. See the deadline calendar for the exact day.
• Forgetting the EIN. The ITA asks for it with every submission (29 CFR 1904.41(a)(4)).