A January afternoon with three closed logs and one open summary
At 4:10 p.m. on January 28, an operations manager at a three-site distribution business opens the shared drive. Two sites have closed their OSHA 300 Logs for the year. The third has two cases where the count of days away still has to be checked against attendance records.
The HR manager who normally builds the annual summary is on leave. The operations director who will sign it is traveling and wants one page she can review on a phone. Hours worked sit in three different payroll exports, and nobody wrote down how last year's average headcount was calculated.
Nothing here is exotic. The summary looks like a short form, but it depends on every decision made on the log during the year, plus two figures that come from payroll rather than from injury cases.
This guide walks the close-out in order: case totals, hours, average employees, certification, posting and electronic submission. By the end you will be able to build the summary for each establishment, name who may sign it, and tell which dates apply to which site.
Reference material with citations, not legal advice. You decide recordability and compensability, and you file.
What the OSHA 300A rules say: dates, units and recipients
The OSHA 300A is the annual summary of the work-related injuries and illnesses you recorded on the OSHA 300 Log. It is arithmetic on decisions already made, so it is only as reliable as the log underneath it. Four clocks touch it, and each has its own trigger, unit and recipient.
| Duty | Trigger | Unit and limit | Recipient | Source |
|---|---|---|---|---|
| Enter each recordable case on the 300 Log and 301 Incident Report | Receiving information that a recordable injury or illness has occurred | Within seven calendar days | The employer's own records; nothing is sent to OSHA at this step | 29 CFR 1904.29 (checked 2026) |
| Post the annual summary | End of the calendar year the records cover | No later than February 1 of the following year; kept posted until April 30 | Employees at the establishment | 29 CFR 1904.32(b)(6) (checked 2026) |
| Submit summary data through the ITA | A covered establishment's calendar year has ended | By March 2 of the following year | OSHA | ITA user guide (checked 2026) |
| Retain the summary | End of the calendar year the records cover | Five years following that year | The employer keeps it; nothing is sent | 29 CFR 1904.33(a) (checked 2026) |
Two of these dates are easy to confuse because they are separate duties. The February 1 posting duty runs to your employees at each establishment that keeps the records. The March 2 submission runs to OSHA and applies only to covered establishments. An establishment can owe the first without owing the second.
Certification is a separate step with its own rule about who may sign. OSHA's blank forms are free, so the work is in the preparation, not the paper.
Building the totals from decided cases
If you are working out how to fill out OSHA 300A, start with the decisions, not the totals. The summary adds up what the log already says and re-decides nothing. Each log entry reflects an employer decision: whether the case is work-related, whether it meets the recording criteria, whether treatment went beyond first aid, and whether work was restricted.
The tests are in 29 CFR 1904.7 (checked 2026), including the first-aid list in 1904.7(b)(5)(ii), which 1904.7(b)(5)(iii) calls "a complete list." That is what the rule says. How the tests apply to your facts is your decision, and the summary inherits it. If a total looks wrong, the correction usually belongs on the log first.
To build the summary you "total the columns on the OSHA 300 Log," entering zeros if you had no recordable cases (29 CFR 1904.32(b)(2)(i)). The case columns are the ones 1904.7 tells you to check: death, days away, job transfer or restriction, and medical treatment while the employee remained at work, plus the day counts. Check the current 300A form for its exact layout. Several rules in 1904.7 shape the day totals. Employers may cap the count of days away or days of restriction at 180 calendar days on the log. A case that starts in one year and causes days away in the next is recorded only once, in the year it occurred.
You "begin counting days away on the day after the injury occurred," and you count calendar days whether or not the employee was scheduled to work. If the employee is still away when you prepare the summary, estimate the total days you expect, use that for the summary, and update the log entry later (29 CFR 1904.7(b)(3)(i), (iv), (ix)).
The total hours worked calculation
Hours worked is the first of two figures that come from payroll. The rule asks for "the total hours worked by all employees covered by the OSHA 300 Log" (29 CFR 1904.32(b)(2)(ii)). For incidence rates, BLS describes the figure as "the number of hours all employees actually worked" and says to use payroll or other time records (BLS, Appendix C). The 300A form carries its own worksheet and instructions, including for paid time off and salaried staff; follow the current form and write down what you did.
Workers you supervise day to day count within your recordkeeping. OSHA's 2018 interpretation says employers must record the recordable injuries and illnesses of employees they supervise on a day-to-day basis, including temporary workers who are not on their payroll. Ask whether those workers' hours sit in your export or only in the staffing agency's, and check the form's instructions before you count them.
The annual average number of employees
The annual average number of employees covered by the log is the second payroll figure the rule requires (1904.32(b)(2)(ii)). The rule itself does not set out the method. The 300A worksheet does, including which employees to include and how to round, so take the method from the current form rather than from memory.
Worked example (round numbers for illustration, not benchmarks). Payroll exports for three departments show 100,000, 75,000 and 45,000 hours actually worked by employees covered by the log, so the site's total hours worked is 220,000. The average-employee figure is worked out separately, on the form's worksheet.
Save both worksheets with the summary. These two figures are the denominators people use to compare establishments, so an estimate nobody documented tends to be repeated year after year.
Certification, posting and electronic submission
Who certifies the summary
A company executive certifies the summary. Under 29 CFR 1904.32 (checked 2026), that executive must be one of four people: an owner (for a sole proprietorship or partnership only), an officer of the corporation, the highest-ranking company official working at the establishment, or that official's immediate supervisor. Which person at your company fits is your decision, and our guide to company-executive certification covers the common cases.
The executive certifies "that he or she has examined the OSHA 300 Log" and reasonably believes, based on knowledge of how the information was recorded, "that the annual summary is correct and complete" (29 CFR 1904.32(b)(3)). The signer should read the log before signing.
Posting from February 1 to April 30
You must post a copy of the annual summary "in each establishment in a conspicuous place or places where notices to employees are customarily posted," and make sure it is not altered, defaced or covered (29 CFR 1904.32(b)(5)). The timing, in the regulation's own words:
“You must post the summary no later than February 1 of the year following the year covered by the records” — 29 CFR 1904.32(b)(6), eCFR (checked 2026), which also requires the posting to stay up until April 30
Anyone searching for the OSHA 300A deadline of February 1 is looking at this posting duty, not at electronic submission. Our posting requirements guide covers the details.
Electronic submission by March 2
A covered establishment must submit its summary data to OSHA electronically through the Injury Tracking Application (ITA) by March 2 of the year after the covered year. For calendar-year 2025 data, the ITA user guide gives March 2, 2026 (checked 2026).
Coverage turns on establishment size and industry. Under 29 CFR 1904.41, establishments with 20–249 employees in designated higher-hazard industries (Subpart E, Appendix A) must submit 300A data by that March 2 date, and establishments with 100 or more employees in Appendix B industries must also submit 300 and 301 data (OSHA interpretation, 2024-04-16). OSHA's ITA data page also describes collecting 300A data from establishments with 250 or more employees in non-exempt industries (checked 2026). The industry lists sit in the regulation's appendices and are not reproduced here, so check your establishment's industry against them and confirm with OSHA if unsure. Our guide on who must submit electronically goes further.
The employer submits; no software does it for you, including ClaimsIntake. OSHA's injury reporting page is the starting point. For calendar year 2023, OSHA reported receiving Form 300A data on more than 1.5 million work-related injuries and illnesses from more than 385,000 establishments (OSHA, 2023 data), and it publishes establishment-specific ITA data.
OSHA also checks. A memo dated March 23, 2026 sets up a non-responder program in which area offices match open inspections against establishments that may have failed to submit calendar-year 2025 300A data, and valid matches are handled under April 2024 enforcement procedures (OSHA memo). OSHA's 2024 guidance tells compliance officers to check the ITA database during all inspections (OSHA, 2024). OSHA adjusts its maximum civil penalties for inflation each year, including for posting violations, so check the current amounts on OSHA's penalties page. State Plans set their own penalties.
Edge cases: multi-site, small employers, State Plans and temp workers
Multi-site employers
A separate 300 Log must be kept for each establishment expected to operate for one year or longer (29 CFR 1904.30, checked 2026). The summary follows the log: the rule has you enter the establishment name and address on it and post a copy in each establishment (1904.32(b)(2)(ii), (b)(5)), and the ITA thresholds above apply establishment by establishment, not to the company as a whole. A company with ten small sites can therefore have no covered establishment, or several. For sites that will exist for less than a year, "you may keep one OSHA 300 Log that covers all of your short-term establishments" (1904.30(b)(1)).
Small employers and exemptions
If your company had 10 or fewer employees at all times during the last calendar year, "you do not need to keep OSHA injury and illness records unless OSHA or the Bureau of Labor Statistics informs you in writing that you must keep records" (29 CFR 1904.1(a)(1), checked 2026). It must still report a work-related fatality to OSHA within 8 hours, and an in-patient hospitalization, amputation or eye loss within 24 hours (29 CFR 1904.1(a)(1), 1904.39; OSHA's reporting page). Some industries are also partially exempt under 1904.2. That list is not reproduced here, so check yours against Appendix A to Subpart B. Smaller single-state employers can use the workbook route described below.
State Plan states
California, Michigan and North Carolina run their own OSHA-approved State Plans, and OSHA counts 22 State Plans covering both private sector and state and local government workers (OSHA State Plans, checked 2026). State Plans set their own penalties, and their requirements for the annual summary and its submission may differ in detail. Confirm with your State Plan agency.
Temporary and contract workers
If your site hosts staffing-agency workers, the day-to-day supervision test described above decides whose log carries a case. Agree with the agency, in writing, who supervises those workers day to day. Allocation detail beyond that test is outside this guide, so confirm it with OSHA.
Keeping the summary defensible, and what to do next
A summary has to be reproducible. Keep the version of the log it was built from, the hours and average-employee worksheets, the name and role of the certifier, and the date it was posted. Under 29 CFR 1904.33(a) (checked 2026), the summary must be kept for five years following the end of the calendar year it covers. Retention is the employer's responsibility, whatever tools you use.
When an authorized government representative asks for Part 1904 records, the employer must provide copies within four business hours (29 CFR 1904.40, checked 2026). Records spread across personal drives are hard to produce in that window.
Many teams run the close-out in Excel or Google Sheets plus email, and some have built those workbooks carefully. A spreadsheet holds dates and totals, but it rarely records which rule version applied or what was known when. OSHA's ITA and blank forms are free and authoritative; the work is in the preparation.
A practical order for the next close-out:
- List each establishment with its average employee count, then check it against the 1904.41 thresholds and appendices, confirming with OSHA where unclear.
- Close each log: settle open cases and check day counts under 1904.7.
- Build and save the hours-worked and average-employee worksheets.
- Name the certifying executive from the four permitted categories.
- Calendar February 1 (post), March 2 (submit, if covered) and April 30 (end of posting), and set the five-year retention date.
For a smaller single-state establishment, the annual close-out and submission workbook computes 300A totals from the case-level log and works through the hours-worked and average-employee calculations. It is a reference tool: you decide recordability, certify the summary and submit it yourself. ClaimsIntake's app is being built to roll decided cases into a 300A with certification, posting and ITA reminders, plus an append-only audit trail. It will not submit anything to OSHA for you, and you remain responsible for retaining your records for the required five years.
To hear when the app opens, join the waitlist.
Reference material with citations, not legal advice. You decide recordability and compensability, and you file.
