Reminder: Annual OSHA Form 300A Posting Begins February 1

Employers that had 11 or more employees at any point in 2022 are required to post Occupational Safety and Health Administration (OSHA) Form 300A from February 1 through April 30 unless they qualify as an exempt low-risk industry. The employee count is based on the number of employees in the entire company, not per establishment. A full list of exempt low-risk industries, ordered by North American Industry Classification System (NAICS) codes, can be found here.

All covered employers are required to post Form 300A even if they didn’t have any recordable incidents in 2022. (Recordable incidents are required to be maintained on the OSHA Form 300 Log of Work-Related Injuries and Illnesses.) OSHA Form 300A must be certified by a company executive and posted in a conspicuous location where notices to employees are customarily posted.

Form 300A Electronic Submission Required for Certain Employers by March 2

Employers must submit their 2022 Form 300A data to OSHA if they have 250 or more employees or have 20–249 employees and are in certain high-risk industries. Employers must send this data electronically, using OSHA’s online Injury Tracking Application (ITA). The deadline to submit the report is March 2, 2023.

The electronic reporting requirements are based on the size of the establishment (how many employees are at the physical location), not how many employees are in the entire company.

Employers that are covered by a State Plan that has not yet adopted its own state rule must also use the ITA to send their data electronically.

Employers that meet any of the following criteria DO NOT have to send their Form 300A information to OSHA:
•    Employers that are exempt from OSHA’s routine recordkeeping requirements, as mentioned above.
•    Employers that never had 20 or more employees during the previous calendar year, regardless of industry.
•    Employers that 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 Injury Tracking Application can be found on OSHA’s ITA page.