Do I Have to Submit to OSHA’s ITA?
Enter your establishment’s size and industry to see whether you must electronically submit injury data to OSHA’s Injury Tracking Application — with the exact regulation behind the answer.
About Your Establishment
The maximum number of people who worked at this establishment at any point last year — including part-time, seasonal, and temporary workers (29 CFR 1904.41(b)(2)).
Your industry classification code. It’s on your establishment’s prior ITA submission, or look it up at census.gov/naics.
OSHA’s submission requirement is evaluated per establishment, not company-wide — each physical location is counted and classified on its own. If your company has multiple establishments, check each one separately.
This tool gives general information based on OSHA’s recordkeeping rules (29 CFR Part 1904) to help you understand your obligations. It is not legal advice and does not replace the current regulation or the judgment of a qualified safety professional. Rules can change and edge cases exist — verify results against the current text at osha.gov/recordkeeping and consult a professional before making a compliance decision.
Who Has to Submit Injury Data to OSHA Electronically?
Under 29 CFR 1904.41, certain employers must electronically submit their injury and illness records to OSHA’s Injury Tracking Application (ITA) each year. Whether you’re covered depends on two things about each establishment (a single physical location): how many people worked there at their peak during the year, and what industry it’s in, identified by its six-digit NAICS code.
There are three coverage groups. Establishments with 250 or more employees in any industry required to keep OSHA records must submit their Form 300A summary (1904.41(a)(1)(ii)). Establishments with 20 to 249 employees in a designated high-hazard industry (Appendix A to Subpart E) must also submit their 300A (1904.41(a)(1)(i)). And establishments with 100 or more employees in the highest-hazard industries (Appendix B to Subpart E) must submit detailed Form 300 and Form 301 case data on top of the 300A (1904.41(a)(2)).
300A Summary vs. Detailed 300/301 Case Data
The Form 300A is the annual summary — total case counts, days, and hours worked, with no individual case details. Most covered establishments submit only this. The 300 and 301 forms carry case-level detail about each recordable injury and illness. Only the largest, highest-hazard establishments (100+ employees in an Appendix B industry) submit that detailed data, and the ITA processes it only after the establishment’s 300A has been accepted.
Partially exempt low-hazard industries (Appendix A to Subpart B under 1904.2) are outside routine recordkeeping entirely, so they have nothing to submit — regardless of size. Establishments below the 20-employee electronic-submission floor still may need to keep records; the recordkeeping exemption is a separate 10-employee test under 1904.1.
Size Is Measured at Peak, Not Average
This is the detail that most often produces a wrong answer. Under 1904.41(b)(2), the employee count is the number who worked at the establishment at any point during the year — the peak, not a headcount on December 31 and not a twelve-month average. It includes part-time, seasonal, and temporary workers.
A landscaping company that runs 14 people through the winter and 32 through the summer is a 32-employee establishment for this test, not a 14- or 23-employee one. Seasonal employers who reason from their average headcount routinely conclude they are under the 20-employee floor when they are not.
Three Separate Tests, Easily Confused
Part 1904 contains several size and industry thresholds that people tend to collapse into one. They are independent, and an establishment can land differently on each:
- Do you keep records at all? The 10-employee test under 1904.1, measured company-wide, plus the partially exempt low-hazard industry list in Appendix A to Subpart B (1904.2).
- Do you submit the 300A electronically? The 250+ any-industry test and the 20–249 Appendix A to Subpart E test, measured per establishment at peak.
- Do you submit 300/301 case detail? The 100+ Appendix B to Subpart E test, again per establishment at peak.
So a 15-person establishment in a covered industry keeps a log but submits nothing. A 300-person establishment in a partially exempt industry keeps no routine records and submits nothing. Neither is excused from reporting severe injuries under 1904.39, which applies to every employer regardless of size or industry. The recordkeeping exemptions are worth reading separately from this tool’s answer.
When Is the ITA Submission Deadline?
Covered establishments must submit the prior calendar year’s data by March 2 each year (29 CFR 1904.41(c)), through OSHA’s Injury Tracking Application. Because coverage is evaluated per establishment, a company with several locations may owe different submissions for each one — and each location keeps its own log feeding its own submission.
March 2 sits inside the February 1–April 30 window during which the 300A must be posted at the workplace. Posting and submitting are different obligations — doing one does not satisfy the other, and the 300A must be certified by a company executive before either.
Missing an ITA deadline is a recordkeeping violation carrying the same exposure as other other-than-serious violations — up to $16,550 per violation — so it’s worth confirming your obligation well ahead of the date. Walking through the ITA portal covers account setup, the CSV upload path, and what a successful submission looks like — and if you’re uploading a CSV, the ITA CSV validator pre-flights the file before the portal sees it.
Common Questions
- What if my establishment closed or was sold during the year?
- Per OSHA’s ITA FAQ, an establishment that has permanently closed does not have to submit the prior year’s data. After a sale, the former owner does not submit — only the current owner submits, for the portion of the year they owned the establishment.
- Do I submit if I had no recordable injuries?
- Yes. Coverage depends on size and industry, not on your injury count. A covered establishment with zero recordable cases submits a 300A showing zeros — omitting the submission because there was nothing to report is itself the violation.
- What exactly is an “establishment”?
- A single physical location where business is conducted or operations are performed. Two facilities across town are two establishments even under one payroll; a single site with several departments is one. For mobile workforces, the establishment is generally the base of operations employees report to.
- Which NAICS code should I use?
- The six-digit code describing what that specific establishment does — not necessarily your parent company’s code. A manufacturer’s standalone corporate office and its plant can carry different codes and therefore different obligations.
- Does the state I operate in change this?
- The thresholds above are the federal floor. State Plan states may impose additional or stricter requirements, and some cover public-sector employers that federal OSHA does not. Check your state plan if you operate in one.
More on electronic submission and recordkeeping practice on the LogStead blog. If this checker says you must submit, the ITA CSV validator is the natural next step — or see all four free tools.