OSHA 300A Summary Posting Feb 1 Process

Why this matters

Every covered employer with 11 or more employees at any point in the prior calendar year must post the OSHA Form 300A annual summary of work-related injuries and illnesses in a conspicuous workplace location from February 1 through April 30 of the following year. The posting requirement sits at 29 CFR 1904.32. Compliance officers entering for any reason can verify the posting in seconds; missing or incomplete 300A is a common citation that does not require a recordable injury to trigger. Trade businesses also have an electronic submission obligation under 29 CFR 1904.41 if they have 20 or more employees and operate in designated high-hazard industries (construction NAICS 23 is on the list). Get the workflow right and this is 30 minutes of work each January.

Determine if you are covered

Coverage is based on peak employee count during the prior calendar year, not current headcount. Count every W-2 employee on payroll on any day, including part-time, seasonal, and temporary direct hires. If you ever crossed 11 employees, you are covered. Independent contractors paid on 1099 do not count toward your number for 1904 purposes, but if you exercise day-to-day supervision the OSHA multi-employer doctrine may pull them in for citation purposes separately.

Partial-year exemption check at 29 CFR 1904.1: certain low-hazard SIC/NAICS codes are exempt from routine recordkeeping. Construction NAICS 23, HVAC service 238220, plumbing 238220, electrical 238210, landscaping 561730, pest control 561710, and most other field trades are NOT on the exempt list. Assume you must keep records.

Calendar the workflow

Treat this as a recurring January task with a hard deadline of January 31 for completion and February 1 for posting. Block time on the owner or office-manager calendar.

• Mid-December: pull the 300 Log year-to-date for a sanity check.
• Early January: finalize the 300 Log for the prior year, including any late-reported cases.
• Mid-January: complete the 300A summary form.
• January 25 or earlier: have a company executive certify (sign) the 300A.
• February 1: post the certified 300A in a conspicuous location.
• March 2: electronic submission deadline via OSHA ITA (if 20+ employees and in a covered NAICS).
• April 30: posting period ends; remove and archive.
• Retain the 300 Log, 300A, and any 301 incident reports for five years per 29 CFR 1904.33.

Complete the 300A correctly

The 300A pulls totals from the 300 Log. Each box must be filled even if the answer is zero.

• Total number of deaths
• Total number of cases with days away from work
• Total number of cases with job transfer or restriction
• Total number of other recordable cases
• Total number of days away from work
• Total number of days of job transfer or restriction
• Injury totals broken down by type (injury, skin disorder, respiratory condition, poisoning, hearing loss, all other illnesses)
• Annual average number of employees
• Total hours worked by all employees during the year

The hours-worked figure is your incidence-rate denominator. Pull it from payroll; if you use 1099 subcontractors heavily, do NOT include their hours. The average-employees figure is summed-pay-period-headcount divided by number of pay periods.

A company executive must certify the 300A. OSHA defines executive at 29 CFR 1904.32(b)(4) as owner, officer, highest-ranking company official at the worksite, or that official's immediate supervisor. Office managers and HR coordinators do not satisfy the certification requirement on their own.

Post in the right place

Conspicuous location means employees see it without having to ask. Acceptable: break room, time-clock area, main entrance employee bulletin board. Not acceptable: locked manager office, intranet-only posting (you may post electronically IN ADDITION to physical posting, but not instead of).

Multi-location businesses post a separate 300A at each establishment where employees report to work. One central posting at headquarters does not cover branch shops. For an establishment that has no fixed location (mobile field crews who report directly to job sites), 29 CFR 1904.30(b)(1) lets you keep records at a central location and post the 300A there, provided employees can access it.

Posting must remain from February 1 through April 30. Removing early is a citation; many inspectors check posting date by photograph.

Electronic submission via OSHA ITA

If your establishment had 20 or more employees at peak and operates in a NAICS code on the 1904.41 designated industries list, you must submit the 300A electronically through the Injury Tracking Application at osha.gov/injuryreporting/ita by March 2.

A 2024 rule expanded electronic submission for establishments with 100+ employees in high-hazard NAICS codes (construction is included) - those must submit the full 300 Log and the 301 incident reports, not just the 300A summary. The 100+ rule applies to NAICS codes listed in Appendix B of the 2024 final rule; construction NAICS 23 subcodes are included.

Create the ITA account well before March 2 - account approval can take days. Submission requires establishment-level EIN, NAICS code, and the 300A data fields.

After April 30 archive workflow

• Remove the posting on May 1.
• File the certified 300A, the 300 Log, and all 301 incident reports for the year in a five-year retention file.
• Keep both paper and a scanned PDF; OSHA accepts either format during inspection under 29 CFR 1904.35.
• If you sell the business or close an establishment, the buyer or final owner must retain records for the remainder of the five-year window per 29 CFR 1904.34.

References

• 29 CFR 1904.32 - Annual summary, posting and certification requirements
• 29 CFR 1904.41 - Electronic submission of injury and illness records
• 29 CFR 1904.33 - Retention and updating of records
• 29 CFR 1904.36 - Prohibition against discrimination and falsification
• OSHA Injury Tracking Application at osha.gov/injuryreporting/ita
• 29 CFR 1903.15 - Proposed penalties (inflation-adjusted annually)