OSHA Electronic Injury and Illness Reporting Due March 2

OSHA Electronic Injury and Illness Reporting Due March 2

OSHA's final rule on electronic injury and illness reporting that passed in 2023 took effect on January 1, 2024.

OSHA’s final electronic injury and illness reporting rule took effect January 1, 2024, expanding the categories of employers required to submit detailed injury reports and creating new reporting obligations for mid-size facilities. Reports for 2023 injuries and illnesses were due March 2, 2024. This rule represents a significant increase in reporting scope compared to previous years.

In short: As of January 1, 2024, OSHA created a new Appendix B requiring employers with 100 or more employees in designated high-hazard industries to submit detailed OSHA Forms 300, 301, and 300A (not just 300A summaries). The largest employers (250+) must still submit 300A regardless of industry. Six industries were moved from Appendix A to Appendix B due to high fatality or DART rates: logging, hunting/trapping, furniture manufacturing, merchant wholesalers, taxi/limousine services, and transportation support. Reports for prior-year data must be submitted electronically by March 2 each year.

New Reporting Tier: Appendix B (100+ Employees in High-Hazard Industries)

OSHA created Appendix B to capture mid-size employers (100-249 employees) in high-hazard industries that were previously not required to report detailed injury data. Appendix B covers employers with 100 or more employees in industries with elevated fatality or Days Away, Restricted work, or Transferred (DART) rates.

Employers in Appendix B industries with 100+ employees must submit:

  • OSHA 300: Complete log of work-related injuries and illnesses (detailed incident data)
  • OSHA 301: Individual injury and illness incident reports
  • OSHA 300A: Annual summary

This is a significant increase in reporting burden compared to the prior requirement (300A only).

Industries Newly Moved to Appendix B

Six industries were moved from Appendix A to Appendix B due to elevated injury and fatality rates:

  1. Logging (SIC 0811)
  2. Hunting and Trapping (SIC 0971)
  3. Other Furniture Related Product Manufacturing (SIC 2599)
  4. Miscellaneous Durable Goods Merchant Wholesalers (SIC 5099)
  5. Taxi and Limousine Service (SIC 4121)
  6. Other Support Activities for Transportation (SIC 4889)

If your facility operates in any of these industries and employs 100 or more people, your reporting obligations increased effective January 1, 2024.

Unchanged: Large Employer Requirements (250+)

Employers with 250 or more employees continue to submit OSHA 300A summaries regardless of industry. This requirement has not changed and applies across all sectors.

All electronic submissions must now include your company’s legal name (as registered with the IRS) along with your Employer Identification Number. This helps OSHA verify submissions are from the correct legal entity and prevent duplicate reporting.

Understanding Your Reporting Obligation

To determine your obligation under the 2024 rule:

  1. Count your employees: How many people did you employ in 2023?
  2. Identify your NAICS code: What is your primary industry classification?
  3. Check the requirements:
    • 250+ employees: Submit 300A (all industries)
    • 100-249 employees in Appendix B industries: Submit 300, 301, and 300A
    • Fewer than 100 employees: No electronic submission required (but maintain records for OSHA inspection)
    • In OSHA-approved state programs: Report to state agency, not federal OSHA

OSHA provides a NAICS code lookup tool to help identify your industry classification. If you are uncertain whether your industry is in Appendix B, verify now — the March 2 deadline will not extend for late entrants.

The Reporting Deadline and Process

Electronic reports for prior-year data must be submitted by March 2 of each year through OSHA’s Injury Tracking Application (ITA) portal at osha.gov/injuryreporting. The deadline is firm; extensions are not available. Submission methods include manual data entry, CSV file upload, or API integration for automated systems. Verify your submission status after March 2 — the ITA portal shows whether your submission was received and processed.

Action Items for Affected Facilities

If your facility is in one of the six newly-moved industries with 100+ employees, your reporting obligation changed effective January 1, 2024. Immediately: Organize your complete OSHA 300 injury log for 2023; verify that all injuries for 2023 are recorded with full detail (worker name, date of birth, injury date, body part injured, treatment); ensure your company’s legal name and EIN are current in your records; and prepare to submit 300, 301, and 300A data by March 2 for the current reporting cycle.

💰 What a reporting violation looks like: OSHA serious violations for failure to submit detailed reports run $8,000–$16,550 per violation. Willful violations (knowing failure to maintain or submit required injury data) can reach $165,514. A facility in an Appendix B industry that fails to submit detailed 300 and 301 forms instead of just a 300A summary is not compliant and will be cited if audited. The cost of organizing your injury data and submitting complete reports is far less than a citation.

Frequently Asked Questions

Q: What is OSHA’s electronic injury and illness reporting rule that took effect January 1, 2024?

The 2024 rule requires covered employers to submit injury and illness data electronically. Employers with 250+ employees submit OSHA 300A summaries (all industries). Employers with 100-249 employees in Appendix B industries (high-hazard sectors) must submit detailed OSHA 300, 301, and 300A forms. Reports for prior-year data are due March 2 annually.

Q: What is the difference between Appendix A and Appendix B under OSHA’s electronic reporting rule?

Appendix A historically covered certain high-hazard industries required to submit electronic reports. Appendix B (created by the 2024 rule) covers employers with 100+ employees in industries with elevated fatality or DART rates. Six industries were moved from Appendix A to Appendix B effective January 1, 2024: logging, hunting/trapping, furniture manufacturing, merchant wholesalers, taxi/limousine services, and transportation support services.

Q: Why did OSHA move certain industries to Appendix B?

OSHA moved industries with elevated workplace fatalities or DART (Days Away, Restricted, Transferred) incident rates to Appendix B. These industries had demonstrated higher injury severity and frequency compared to other sectors, indicating greater occupational risk. The reclification increased reporting requirements for mid-size employers in these sectors to enhance data visibility on high-hazard occupations.

Q: What information must employers submit under the 2024 electronic reporting rule?

Employers with 250+ employees submit OSHA 300A summaries (annual totals). Employers with 100-249 employees in Appendix B industries submit detailed OSHA 300 logs (complete injury records), OSHA 301 forms (individual incident reports), and OSHA 300A summaries. All submissions must include the company’s legal name and Employer Identification Number.

Q: If I have 100+ employees in one of the newly-moved industries, what changed for my company?

If your facility has 100 or more employees and operates in logging, hunting/trapping, furniture manufacturing, merchant wholesaling, taxi/limousine, or transportation support services, your reporting obligation changed effective January 1, 2024. You must now submit detailed OSHA 300 and 301 forms (not just 300A summaries) by March 2 each year. This is a significant increase in data submission and documentation requirements.


Need help organizing detailed injury records, preparing for 300/301/300A submission, or auditing your recordkeeping for Appendix B compliance? iSi Environmental provides recordkeeping consultation and submission support for facilities in high-hazard industries. Get recordkeeping help →

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Frequently Asked Questions

Q: What is OSHA’s electronic injury and illness reporting rule that took effect January 1, 2024?

OSHA’s electronic reporting final rule, effective January 1, 2024, requires covered employers to submit injury and illness data electronically. The rule creates new requirements for employers with 100 or more employees to submit OSHA 300, 301, and 300A forms. Employers with 250 or more employees submit 300A forms regardless of industry classification. Reports for 2023 injuries and illnesses were due March 2, 2024.

Q: What is the difference between Appendix A and Appendix B under OSHA’s electronic reporting rule?

Appendix A historically covered certain high-hazard industries required to submit electronic reports, while Appendix B (created by the 2024 rule) now covers employers with 100+ employees in specified industries. OSHA moved six industries from Appendix A to Appendix B due to increased fatality or DART (Days Away, Restricted, Transferred) incident rates, including logging, taxi services, and certain manufacturing sectors.

Q: Why did OSHA move certain industries to Appendix B?

OSHA moved industries like logging, hunting and trapping, furniture manufacturing, merchant wholesaling, taxi and limousine services, and transportation support services to Appendix B due to increases in workplace fatalities or DART rates in these sectors. These industries with elevated injury and illness rates now require larger employers (100+ employees) to submit detailed injury and illness reports electronically.

Q: What information must employers submit under the 2024 electronic reporting rule?

Employers covered under the new rule must submit OSHA 300 logs (detailed injury records), 301 forms (individual injury reports), and 300A summaries (annual totals). Submissions must include the company’s legal name and other identifying information. The electronic submission system helps OSHA monitor injury trends and identify industries with elevated occupational safety risks.


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