OSHA 300A and electronic ITA: the March 2 construction deadline

Three forms, one recordkeeping system

OSHA's injury and illness recordkeeping rule, 29 CFR Part 1904, runs on three forms that work together. The Form 300 log records each recordable work-related injury or illness as it happens through the year. The Form 301 incident report captures the detail on each one — what happened, what part of the body, what treatment. The Form 300A summary totals the year and gets posted and, for covered employers, submitted electronically. None of the three is paperwork filed away after the fact; the log is a running record required to be maintained contemporaneously, not reconstructed at year-end.

Who has to keep the logs

The baseline threshold is more than 10 employees at the establishment at any point during the current or prior calendar year — smaller employers are exempt from routine recordkeeping. Above that threshold, a defined list of low-hazard industries (retail, finance, most services) is partially exempt under 29 CFR §1904.2 and the associated industry list. Construction is not on that exempt list. A contractor classified under NAICS 236, 237, or 238 with more than ten employees keeps full logs, full stop.

Size doesn't excuse the separate severe-injury reporting duty under 29 CFR §1904.39: every employer, regardless of size or exemption status, must report a work-related fatality to OSHA within 8 hours, and a work-related in-patient hospitalization, amputation, or loss of an eye within 24 hours.

The electronic ITA submission

Under 29 CFR §1904.41, covered establishments submit their recordkeeping data electronically to OSHA's Injury Tracking Application (ITA) by March 2 each year, for the prior calendar year. The rule, revised effective 2024, splits the obligation by establishment size and industry:

• Establishments with 100 or more employees in the high-hazard industries designated for expanded reporting — which include construction, NAICS 236, 237, and 238 — submit data from Forms 300, 301, and 300A.
• Establishments with 20 to 249 employees in the industries designated as high-hazard submit Form 300A summary data only.
• Establishments below those thresholds, or outside the listed industries, generally have no ITA submission duty even if they keep logs for inspection purposes.

Posting the 300A

Regardless of the ITA submission requirement, every establishment that keeps OSHA records must post the Form 300A summary, signed by a company executive, in a conspicuous location where notices to employees are customarily posted, from February 1 through April 30 of the year following the one it summarizes — even when the total is zero recordable injuries. The posting duty and the electronic-submission duty are separate obligations; satisfying one doesn't satisfy the other.

Cal/OSHA's parallel recordkeeping layer

California employers work under Title 8 of the California Code of Regulations, §14300 et seq., which largely mirrors federal Part 1904 — the same 300/300A/301 forms, the same recordability standard, and its own posting and electronic-submission obligations administered by Cal/OSHA within the DIR. Because Cal/OSHA's rulemaking runs on its own timeline relative to federal changes, the safest practice for a California contractor is to confirm current DIR/Cal/OSHA guidance for the establishment's size and NAICS code each reporting cycle, rather than assume state and federal thresholds line up exactly in a given year.

The IIPP: a standing obligation, not an annual filing

Separate from the 300-series logs, Labor Code §6401.7 requires every California employer to maintain a written Injury and Illness Prevention Program (IIPP), detailed at Title 8 CCR §3203. The IIPP has to identify a responsible person, a system for identifying and correcting workplace hazards, a training program covering those hazards for every employee, and recordkeeping of both hazard-correction actions and the training itself. It is the document a Cal/OSHA inspector typically asks for first on a jobsite visit — the logs prove what happened; the IIPP is supposed to prove you were looking for what could happen.

The 300A tells an inspector what already went wrong. The IIPP is the only document that tells them whether you were looking for it beforehand.

Where contractors actually get cited

The findings that recur across construction jobsites:

• No 300A posted between February 1 and April 30, or posted unsigned.
• ITA submission missed, or filed against the wrong establishment size or industry code.
• An IIPP that exists on paper but has no evidence of hazard-correction follow-through or documented training.
• Recordability calls made incorrectly — treating a case as first-aid-only when it involved restricted duty, days away from work, or medical treatment beyond first aid, which makes it recordable.
• Logs updated in batches after the fact rather than maintained within the required time frame.

This article is educational and does not constitute legal or tax advice. Statutes and agency requirements change; confirm current rules with the California DIR, the U.S. Department of Labor, the IRS, or qualified counsel before relying on them. Aeternus Dynamics is a compliance and advisory firm, not a law or accounting firm.