Federal Law Alert – Form 300 A – Do You Need To Comply?

Employers with 11 or more employees at any time in 2024 must post OSHA Form 300A, the Summary of Work-Related Injuries and Illnesses, by February 1 2025. Here’s all you need to know.

Form 300A Workplace Posting Begins February 1
Covered employers that had 11 or more employees in the entire company at any point in 2024 are required to post the Occupational Safety and Health Administration (OSHA) Form 300A, Summary of Work-Related Injury and Illnesses, from February 1 through April 30. This requirement applies even if the company didn’t have any recordable incidents in 2024. OSHA Form 300A must be certified by a company executive and posted in each establishment in a conspicuous location where notices to employees are customarily posted.

Certain establishments are partially exempt from OSHA’s routine record keeping requirements, including this one, if they have 10 or fewer employees or if their primary business activity is classified as low hazard according to OSHA’s guidelines. A full list of exempt low-hazard industries, ordered by North American Industry Classification System (NAICS) codes, can be found here. (The exemption is “partial” because all employers must notify OSHA when an employee is killed on the job or suffers a work-related hospitalization, amputation, or loss of an eye.)  

Form 300A Electronic Submission Due by March 2
Covered establishments that had 250 or more employees in the prior calendar year, or 20–249 employees if they’re in certain high-risk industries, must submit their 2024 Form 300A data electronically using OSHA’s online Injury Tracking Application (ITA). The deadline to submit the report is March 2, 2025. These requirements are based on the size of each establishment (how many employees there are at the physical location), not how many employees are in the entire company. Most employers that are covered by a State Plan must also use the ITA to send data electronically.

Employers that meet any of the following criteria DO NOT have to send Form 300A information to OSHA:

• They are partially exempt from OSHA’s routine record keeping requirements, as mentioned above.
• They never had 20 or more employees during the previous calendar year, regardless of industry.
• They had between 20 and 249 employees at some point during the previous calendar year but are NOT on this list of high-risk industries.

Additional information, FAQs, and the ITA can be found on OSHA’s ITA page.

Form 300 and Form 301 Electronic Submission Required by March 2
Covered establishments in designated high-hazard industries that had 100 or more employees in the prior calendar year will need to electronically submit information from their Form 300, Log of Work-Related Injuries and Illnesses, and Form 301, Injury and Illness Incident Report, through OSHA’s ITA. This is in addition to submitting information from their Form 300A.

Help Determining Coverage
Employers can use the ITA Coverage Application to determine if they’re required to electronically submit their injury and illness information or should review the applicable State Plan to determine reporting requirements.

This blog does not constitute formal HR or legal advice and does not address state or local law. This information came directly from our HR Resource Center by Mineral, which offers further advice on this and many other topics. For a small additional fee you can also speak to a live HR Specialist. Contact your friendly APlus Payroll CSS for further information (including login details) or login here. Wanting to know how we can help your Payroll process? Please contact us here. A friendly chat is always free!