OSHA Injury Posting Requirements
It's that time of year again when employers need to post and submit last year's injury and illness data.
It’s that time of year again when employers need to post and submit last year’s injury and illness data. Here is a list of timeframes and more information about which companies this affects:
⚡ TL;DR: All employers maintaining OSHA injury logs must post the OSHA 300A form from February 1–April 30 each year in a common visible area, signed by company executive. Employers with 250+ employees and employers with 20–249 employees in high-hazard industries must submit electronically to OSHA’s Injury Tracking Application by March 2. Even if injury count is zero, submission is required. Missing the deadline means non-compliance even if you submit later.
Posting Injury and Illness Data
All employers who are required to maintain OSHA logs must post a copy of their OSHA 300A log from February 1 through April 30. This needs to be placed in a common area where an employee can easily see it. Make sure you have a company executive sign and certify it before posting.
Electronic Submittals to OSHA
Employers with more than 250 employees and employers with 20-249 employees under certain NAICS codes are required to submit their 300As to OSHA’s Injury Tracking Application (ITA) website. Here’s a list of those special industries covered by the recordkeeping rule: Covered Industries.
⚠️ The Pain Frame: Missing the March 2 deadline for electronic submission does not mean “submit later at no penalty.” OSHA treats recordkeeping violations as separate citations. A company three months late on submission faces a recordkeeping violation citation (serious violation, $16,550+), plus any underlying injury recordability issues that triggered the delayed data. Additionally, OSHA’s increased scrutiny of electronic submission accuracy has revealed widespread errors in recordability determinations — companies misclassifying injuries as non-recordable discover during an audit that they should have submitted them, incurring penalties for both misclassification and non-reporting. A single submission error (recording a 10-day restricted duty case as non-recordable) multiplies into audit findings across multiple years if the error pattern isn’t identified and corrected immediately.
In order to post to the website, you’ll need two separate accounts. First is an account with the Injury Tracking Application website. The other, new as of October 2022, you’ll have to have an account at Login.gov, a secure website the federal government uses for many different applications. You need to make sure you use the same email address for both so that the records can be connected.
Information can be manually uploaded, uploaded via a CSV file (available as a template from the OSHA ITA website), or transmit it electronically through an API.
If your company has multiple locations, or establishments as they are referred to, you need to report for each establishment, but can use the same ITA account to do it. A third party can help do this for you, but accuracy and completeness of data is still your company’s responsibility.
Even if you have 0 recordables, you still need to report, and if you miss the March 2 deadline, you can still submit at any time of the year. Just be aware you’re not compliant until you do. If you submit early and find out there was an injury last year that became recordable, they would like for you to update the information, but it’s not required.
Many companies mistakenly believe that recordkeeping compliance ends with March submission. It doesn’t. OSHA audits the data for three years after submission. If an employee reports a work-related injury six months after the deadline that should have been recorded in the prior year, OSHA can cite the original misclassification. Building a culture where all work-related injuries are properly classified — not just submitted — is the foundation of defensible recordkeeping. iSi Environmental helps facilities assess their recordability practices and update training so supervisors understand which injuries qualify for recording. Preventing misclassification errors prevents penalties.
What’s Recordable, What’s Not?
If you have questions or need help in determining what’s recordable and what’s not, iSi can help. We can advise on a case-by-case basis, and we have conducted presentations that cover some of the trickier examples that we can provide through our training program. Contact us for pricing on either of those.
💰 Dollar Anchor: A recordkeeping violation (submitting late or misclassifying injuries) carries a serious violation penalty of approximately $16,550 per error. Manufacturing facilities with multiple establishments often have multiple recordability misclassifications discovered during audits, resulting in penalties of $50,000–$100,000+ across all locations. Facilities with accurate, timely submissions and proper supervisory understanding of recordability face zero penalties. The cost of training and process audit is a few thousand dollars; the cost of penalties is exponentially higher.
Frequently Asked Questions
Q: What is the deadline for posting the OSHA 300A form and submitting electronic data?
A: The OSHA 300A form must be posted from February 1 through April 30 each year in a visible common area and signed by a company executive. For electronic submission to OSHA’s Injury Tracking Application (ITA), the deadline is March 2 for companies with 250+ employees or 20–249 employees in high-hazard industries. Missing the March 2 deadline results in a recordkeeping violation citation, even if you submit the data later.
Q: If we submit injury data and later discover an injury we misclassified as non-recordable was actually recordable, do we have to update it?
A: OSHA requests updates but does not legally require them. However, this is a critical compliance risk. If the employee reports the injury to OSHA or if an auditor discovers the misclassification, OSHA can cite the original underreporting. Companies should prioritize accuracy over timely submission — a corrected submission is better than a timely inaccurate submission. Many facilities build quality gates into their recordkeeping process specifically to catch misclassifications before submission.
Q: What counts as a recordable injury under OSHA standards?
A: Recordable injuries include work-related injuries or illnesses resulting in: lost work time beyond the day of injury, job transfer or restricted duty, medical treatment beyond first aid, loss of consciousness, significant injuries (fractures, amputations), or occupational illnesses. Heat-related illness, needlestick injuries, and return-to-work restrictions after off-site medical evaluation are all recordable. iSi Environmental can help your facility audit recent injuries to ensure correct classification.
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Frequently Asked Questions
Q: What are OSHA’s injury and illness posting requirements?
OSHA requires all employers maintaining injury and illness logs to post an annual summary (OSHA 300A form) from February 1 through April 30 of the following year. The form must be posted in a common area visible to employees and must be signed and certified by a company executive. The posting requirement applies to all covered employers regardless of size.
Q: Which employers must submit electronic injury and illness data to OSHA?
Employers with more than 250 employees must submit injury and illness data electronically to OSHA’s Injury Tracking Application (ITA) website. Additionally, employers with 20-249 employees in certain high-hazard industries specified in OSHA’s recordkeeping standard must also submit electronic reports. Covered industries are identified by NAICS codes published by OSHA.
Q: What is required for electronic submission of injury and illness data to OSHA?
Electronic submission requires two separate accounts: (1) an Injury Tracking Application (ITA) website account and (2) a Login.gov federal government account using the same email address. Data can be submitted manually through a web form, uploaded as a CSV file, or transmitted electronically through an application programming interface (API) for automated systems.
Q: What counts as a recordable injury under OSHA’s injury and illness recordkeeping standard?
Recordable injuries include work-related injuries and illnesses resulting in lost work time, job transfer or restricted duty, medical treatment beyond first aid, loss of consciousness, significant injuries (such as fractures or amputations), or occupational illnesses. Determining recordability can be complex, and iSi Environmental can provide guidance on case-specific recordability determinations.
Need help with osha compliance? Contact iSi Environmental for a same-day quote, or explore our osha services to see how we can help your facility.