March 14, 2024

OSHA electronic reporting requirements for employers

The Occupational Safety and Health Administration OSHA passed regulations in 2019 and 2023 requiring submission of certain injury reports through the Injury Tracking Application (ITA) .

You may have questions about whether your business is required to submit information electronically, and what information you will need to submit. Below, you will find a broad overview of OSHA’s electronic reporting requirements, and where you can find more information directly from OSHA and relevant state agencies.

Electronic submission requirements

Only employers with establishments that employ a certain number of workers need to electronically report. For those states covered by federal OSHA, the reporting requirements depend on the number of employees in each establishment, and whether the employer falls into certain categories of high-hazard industries. Different sizes of establishments and categories of employers must report different information.

As of the most recent OSHA rulemaking issued in July 2023, the federal reporting requirements are:

Establishments with 100-plus employees in the highest hazard industries must submit Form 300 Logs, 300A Summaries, and 301 Incident Reports
Workplaces with 20-249 employees in high hazard industries have to submit their 300A Annual Summary data
Workplaces with 250-plus employees in any industry must submit their 300A Annual Summary data

OSHA defines an establishment as “a single physical location where business is conducted or where services or industrial operations are performed. A firm may be comprised of one or more establishments.” This corresponds with your OSHA Form 300A, which is tracked at an establishment level.

Minnesota adopted OSHA’s rulemaking guidelines but does not limit the reporting requirements by industry. Minnesota establishments with 20 or more employees are required to submit 300A data and employers that have establishments with 100 or more employees are required to submit OSHA 300 log, OSHA 300A and OSHA 301 data.

Reporting requirements: federal and state

At a high level, OSHA’s reporting requirements are as follows.

Employers must submit 300A data if their establishment meets one of the following criteria:

250 or more employees and is not in an industry listed in the Exempt Industries list in Appendix A to Subpart B of OSHA’s recordkeeping regulation of 29 CFR Part 1904
20-249 employees and is in an industry listed in Appendix A to Subpart E of 29 CFR Part 1904

Employers must also submit 300/301 data if their establishments have 100 or more employees and is in an industry listed in Appendix B to Subpart E of 29 CFR Part 1904 .

Company officials can also use the ITA Coverage Application to help determine if their establishment is required to submit this data.

Minnesota

Minnesota does have its own reporting requirements.

Establishments with 20 or more employees are required to submit 300A data and employers that have establishments with 100 or more employees are required to submit OSHA 300 log, OSHA 300A and OSHA 301 data.”

There is no reporting requirement for employers with 19 or fewer workers in Minnesota.