The Week Before March 2
It is February 24, a little after four in the afternoon. The HR manager for a regional parts distributor is closing out the year's records for two warehouses in different states. One site's 300A is totaled and already posted. The other is still in draft. Then a colleague asks a question nobody has answered: who is preparing the submission for OSHA's website, and for which sites?
The posted 300A and the electronic submission are different obligations. The first is a posting duty at every covered establishment. The second applies only to establishments that meet size and industry tests, and it goes to OSHA, not to a wall. The manager now has to work out which warehouse is covered, which forms go in, and by when.
By the end of this article you will be able to say whether an establishment falls under electronic submission, where the March 2 date comes from, and how an employer with several establishments organizes the work.
What the OSHA Injury Tracking Application Is and What It Receives
Reference material with citations, not legal advice. You decide recordability and compensability, and you file.
The OSHA Injury Tracking Application, usually called the ITA, is OSHA's online channel for injury and illness data. OSHA's injury reporting page describes it as the route for 300A data, and for 300 and 301 data from covered establishments. It is a government channel and the authoritative one. The employer makes the submission. No software vendor does it for you, and ClaimsIntake never submits anything to anyone.
The channel handles real volume. OSHA reported that it received Form 300A data on more than 1.5 million work-related injuries and illnesses from more than 385,000 establishments for calendar year 2023. Those cases accounted for more than 18 million days away from work and 22 million days of job transfer or restriction (OSHA 2023 summary, 2023 data).
Who submits what
Coverage under 29 CFR 1904.41 depends on the establishment's size and its industry. OSHA's 2024 interpretation letter and its ITA data page describe the groups below. Each covered establishment submits to OSHA through the ITA, and the date is March 2 of the year after the covered year.
| Establishment | Data submitted | Source |
|---|---|---|
| 20–249 employees in designated higher-hazard industries (Appendix A to Subpart E) | Form 300A | OSHA interpretation, 2024-04-16 |
| 100 or more employees in Appendix B industries | Form 300A, plus Form 300 and Form 301 data | OSHA interpretation, 2024-04-16 |
| 250 or more employees in non-exempt industries | Form 300A, as OSHA's data page describes its collection | OSHA ITA data page (checked 2026) |
The 300 and 301 requirement is newer than the 300A requirement. OSHA states that beginning in 2024, for the 2023 reporting period, 29 CFR 1904.41 requires establishments with 100 or more employees in designated high-hazard industries to submit Form 300 and 301 data, not only the 300A (OSHA 2023 summary, 2023 reporting period).
The industry lists sit in Appendices A and B to Subpart E of Part 1904 on the eCFR (checked 2026). We do not reproduce them here. Look up your establishment's industry code against the current lists, because they decide which row of the table applies. The detail is in our guide to who must submit the OSHA 300A electronically.
A separate point concerns very small employers. A company with 10 or fewer employees at all times during the last calendar year qualifies for the partial exemption for size in 29 CFR 1904.1 (eCFR, checked 2026). It must still report fatalities and severe injuries to OSHA under 1904.39.
What goes into the data is your decision
What appears in the 300A totals depends on which cases were recorded. Recordability follows Part 1904, and you make that decision, not the ITA and not any tool. The 300A the ITA receives is a summary of the cases you decided to record. For the relationship between the three forms, see OSHA 300 vs 300A vs 301.
The OSHA ITA Deadline: March 2
For a covered establishment, the employer must submit the prior calendar year's required injury and illness data to OSHA through the ITA by March 2 of the following year. The calendar year is the trigger, March 2 is a fixed calendar date and OSHA is the recipient. The source is the ITA user guide (checked 2026), which gives an example:
"for submission of calendar year 2025 data, that date is March 2, 2026"
— OSHA, ITA user guide
That date is easy to confuse with the posting dates. The 300A summary must be posted no later than February 1 of the year following the year the records cover, and kept posted until April 30. NCDOL reproduces the posting text of 29 CFR 1904.32 on its recordkeeping page (February 2026). Posting runs to every covered employer's workplace. The March 2 date applies only to establishments covered by 1904.41. Our guide to 300A posting requirements covers the posting side.
Certification comes first
A company executive certifies the 300A, and 29 CFR 1904.32 limits who qualifies. The executive must be an owner (in 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 (eCFR 1904.32, checked 2026). One practical observation: the figures you key into the ITA should match the 300A your executive certified and you posted. When the numbers diverge, you have to explain why. The 300A annual summary guide walks through the totals.
Why the date matters in practice
OSHA tells its compliance officers to refer to the ITA database during all inspections to identify employers that were required to submit records but did not (OSHA interpretation, 2024). In March 2026, OSHA also issued an ITA Non-Responder Enforcement Program memo. It has area offices match open inspections against establishments that may have failed to submit calendar-year 2025 Form 300A data, and handle valid matches under the April 2024 enforcement procedures (OSHA memo, 2026-03-23). These are descriptions of OSHA's procedures. For what a missed submission means for your establishment, confirm with OSHA.
OSHA ITA Multiple Establishments Submission
The unit of recordkeeping is the establishment, not the company. A separate OSHA 300 Log must be kept for each establishment expected to operate for one year or longer (29 CFR 1904.30, checked 2026). OSHA's data is likewise collected from establishments. For a company with several sites, that has three consequences.
First, each site gets its own coverage test. Two warehouses in one company can fall on different sides of the size and industry thresholds, so one may submit while the other only posts. Second, each covered site has its own 300A totals, its own certification and its own entry in the ITA. Third, the data has to be consolidated before submission, which is where most multi-site employers lose time.
Workers supervised day to day count at the host site. OSHA's interpretation states that 29 CFR 1904.31 "requires employers to record the recordable injuries and illnesses of employees they supervise on a day-to-day basis" (OSHA, 2018). That includes temporary, leased and contract workers who are not on the host's payroll. A site that leaves them out has a 300A that is too low.
OSHA's ITA pages explain how to add establishments and which submission methods are available. Review them before the due date and confirm the current steps there, since we do not restate mechanics that OSHA can change. For the log side of multi-site work, see OSHA 300 log for multiple locations.
A workflow observation, with no number attached: a spreadsheet with one tab per site holds the dates and totals but not the reasoning behind them. Before March 2, someone has to confirm each site's totals tie to its log, each certification is in place and each site has been counted against the coverage tests. If one person owns all of that, that person is a single point of failure.
Keeping the Submission Defensible
The ITA receives your data. It does not keep your records for you. Employers must keep OSHA 300 Logs, 300A summaries and 301 Incident Reports for five years following the end of the calendar year they cover (29 CFR 1904.33, checked 2026). That duty stays with the employer, whatever tools it uses.
For each establishment and year, a defensible file holds a few things. It has the log entries behind the 300A totals, the certification and who signed, the posting dates, and the date and content of the ITA submission. It also records the reasoning for any recordability call that was close. If an inspector asks for Part 1904 records, the employer must provide copies within four business hours (29 CFR 1904.40, checked 2026). That is a short window to be hunting through email threads.
Where tools fit
OSHA's blank forms and the ITA itself are free, authoritative and one channel at a time. Many employers build careful spreadsheets around them, and those work. A spreadsheet holds dates and totals, but it does not hold the rule that produced them or a record of which version was in force. A chat answer with no citation or verification date is not a defensible deadline.
Our OSHA 300A annual close-out and submission workbook is an Excel workbook that computes the 300A totals from the log entries you make, including days-away and restricted counts, so the figures you key into the ITA tie to the log. You still decide recordability, certify the 300A and submit through OSHA's application. The workbook submits nothing. If you run one site in one state, the workbook is the more natural fit than anything built for multi-site use.
Before March 2: What to Check
Work through this list for each establishment:
- Confirm its industry code against the current Appendix A and B lists, and its headcount against the size tests in 1904.41.
- Reconcile the 300A totals to the log, then confirm the certifying executive is one of the four categories 1904.32 allows.
- Check the current OSHA Injury Tracking Application pages for how to add each establishment and for the submission methods available.
- Keep a copy of what you submitted, with the date, in the five-year file.
If you want the totals computed from your log rather than re-keyed, the annual close-out and submission workbook does that part. For anything about coverage or timing, confirm with OSHA or your State Plan agency, because you make the decisions and you file.
