Electronic Injury Data: Who Must Submit 300A, 300, And 301 By March 2 And How To Avoid Last Minute Headaches

Electronic reporting is now a standing requirement rather than a pilot. The rule that expanded submissions to include case specific data for many larger establishments took effect with the 2024 collection year, and OSHA now publishes parts of that data for researchers and the public. That transparency raises the stakes for accuracy and timeliness. The short version is straightforward. Many establishments submit only the OSHA Form 300A summary. Establishments with one hundred or more employees in certain high hazard industries submit the 300A and selected fields from the 300 Log and 301 Incident Reports. Everything flows through the Injury Tracking Application, and the deadline is March 2 each year for the prior calendar year. OSHA’s ITA information page explains the requirements and points to the coverage tool that tells you exactly which forms apply to your NAICS code and size.

The mechanics of access trip up more employers than the rules themselves. The ITA requires a Login.gov account, and the email must match the address on your ITA account. OSHA’s user guide is blunt about this. If the addresses do not match, you will lose time untangling credentials. That is why a dry run in the portal during January is smarter than a panic in late February. The ITA page links to the login screen and FAQs and places the most common questions in plain view, including how to link accounts and what to do if the person who used to submit data has left your company. If you run multiple establishments, assign clear ownership for each location and require a short peer review before anything is uploaded. You want a second set of eyes on case classifications and day counts, because those are the fields that most often drive corrections later.

There is a larger transparency story that is easy to miss. OSHA now posts portions of the case level data for covered establishments, and it releases high level summaries of the 300A submissions. The remainder of the case data continues to be reviewed to protect personally identifiable information before public release. That means you should assume your numbers will be visible to outside audiences. It also means you can use the public data to benchmark yourself and to explain risk in more nuanced ways to your own teams and to insurers. OSHA publishes a data users guide that explains how to analyze the ITA data responsibly. If you want to turn compliance into a learning tool, start there.

The simplest way to prepare is to treat recordkeeping as a routine, not a scramble. Set a monthly cadence for updating logs, not a year end rush. Encourage supervisors to report cases with enough narrative detail that someone who was not on shift could understand what happened and why you counted it the way you did. Align your posted 300A with the totals in your log before you post it in February, then make sure the posted summary and the ITA numbers match exactly. Store the ITA submission confirmation with your logs. None of this requires software. It requires attention and a calendar invite.

If you are not sure whether you fall into the category that must submit case level data, the coverage application is your friend. It walks you through NAICS codes and employment size and tells you which forms to submit. The rule of thumb is that one hundred or more employees in designated high hazard industries triggers the 300 and 301 submission requirement in addition to the 300A. Everyone else who is covered generally submits the 300A only. When in doubt, check the coverage tool and save a copy of the result for your files. If you are in a state plan, the usual answer is that you still submit to federal OSHA through the ITA, but the information pages spell out the details.

There is an argument for caring about this that has nothing to do with avoiding a citation. Data accuracy is a safety tool. If you misclassify strains and sprains or undercount days away, your trend lines will lie to you and your money will go to the wrong hazards. If you capture incidents and then close the loop with changes on the floor, you reduce harm and give yourself a stronger story in any inspection or renewal conversation with your insurer. In a year when OSHA is using electronically submitted data to target inspections, that story is not a luxury. It is a necessity.

Sources and further reading: OSHA Injury Tracking Application info at osha.gov/injuryreporting. OSHA recordkeeping modernization page. ITA Coverage Application. OSHA ITA user guide explaining Login.gov linkage and account management.