“The Company Is Over 300” Does Not Answer the OSHA ITA Question
Check an OSHA Injury Tracking Application claim using the establishment, 2017 NAICS, prior-year peak employment, required form set and reporting year.
Signals to watch
- A multi-site employer says the company headcount proves the OSHA ITA filing requirement
- A plant has a 300A receipt but a reviewer asks whether Forms 300 and 301 were also required
- The reporting year, establishment NAICS or prior-year peak employment is missing from the request
Company headcount does not answer an OSHA Injury Tracking Application question. The routine electronic-submission tests in 29 CFR 1904.41 apply to an establishment. To check a claim, recover five things: the establishment, its 2017 NAICS code, its highest employment during the covered year, the form set, and the calendar year plus ITA status or receipt.
That is the useful distinction for an occupational-safety software or compliance-service business-development lead reading authorised EHS operations, manufacturing-safety, warehouse-safety and multi-site compliance Telegram groups. A message that says “we filed OSHA” can point to a source-recovery or correction project, but only after the establishment-level facts are known. A day of delay can consume the buyer’s correction or audit-preparation window while another provider defines the scope.
Take this composite fragment, not a real company or submission:
“Company is over 300 now. ITA says submitted for the plant, but someone says 300/301 were required too. Need last year checked.”
It leaves out the plant location, 2017 NAICS, prior-year peak employment, reporting year, recordkeeping status and ITA result. “Over 300 now” answers none of those questions.
Put the establishment on the receipt first
An establishment is the physical location where business is conducted or services are performed. A company can have a headquarters, plants and warehouses with different employment peaks and NAICS classifications. A headquarters may submit for establishments it controls, but that does not merge them into one threshold calculation.
Record the legal company name, EIN, establishment name and address exactly as used in ITA. Then map the establishment to its 2017 NAICS code. Do not substitute a current corporate marketing description or the parent company’s primary industry. The rule’s Appendix A and Appendix B lists use 2017 NAICS codes.
The employment count is also establishment-specific. Section 1904.41 asks how many individuals the establishment employed at any time during the calendar year. The peak includes full-time, part-time, seasonal and temporary workers. An average, year-end figure or company-wide payroll total is not the same measure.
Three routine paths, not one “large employer” rule
The current rule creates three common annual electronic-submission paths:
- An establishment with 20–249 employees at any time in the prior year and a 2017 NAICS code listed in Appendix A submits Form 300A information.
- An establishment with 250 or more employees at any time in the prior year, when Part 1904 requires it to keep records, submits Form 300A information.
- An establishment with 100 or more employees at any time in the prior year and a 2017 NAICS code listed in Appendix B submits required information from Forms 300 and 301 in addition to Form 300A. Appendix B industries are a subset of Appendix A industries.
The deadline is March 2 of the year after the calendar year covered by the forms. Calendar-year 2025 forms were therefore due March 2, 2026; calendar-year 2026 forms are due March 2, 2027. A screenshot dated 2026 does not reveal which reporting year it represents.
Partially exempt establishments under 29 CFR 1904.1 or 1904.2 generally do not make the routine submissions unless OSHA or another authorised government representative specifically requests records. Employers in State Plan States remain subject to the electronic-submission requirements. Both points need an explicit check; neither should be inferred from a group name.
Read the form set as a separate fact
Form 300 is the log of work-related injuries and illnesses. Form 301 is an incident report. Form 300A is the annual summary. A 300A submission receipt therefore cannot establish that an Appendix B establishment also supplied the required 300 and 301 information.
Conversely, the phrase “send the OSHA logs” does not prove that every form belongs in the electronic submission. Establish the rule path first. When 300 and 301 data are submitted electronically, the rule excludes employee names and addresses, health-care professional names, and the names and addresses of off-site treatment facilities. A service proposal should not ask a buyer to post those fields into a Telegram thread.
For each covered establishment, preserve this compact source record:
- establishment identity, address, EIN and legal company name;
- 2017 NAICS code and the relevant appendix;
- prior-year peak employment and how temporary workers were counted;
- Part 1904 recordkeeping or exemption basis;
- required form set, calendar year and March 2 deadline; and
- actual ITA status, receipt, rejection or correction history.
This record can show that the available receipt corresponds to the expected filing. It cannot prove that every underlying record is accurate or that OSHA will accept a late or corrected submission.
The commercial request begins where the receipt stops
A source check is ready to scope when the buyer can identify the establishment and reporting year and can grant authorised access to the relevant forms and ITA status. The first job might be threshold analysis, account and EIN reconciliation, missing-form recovery, rejection diagnosis or controlled resubmission support. Those are different deliverables.
If the message only contains company headcount and a cropped screenshot, keep the form requirement and submission result unknown. Use the official-source ladder to restore the rule and primary record before relying on commentary. For another example of separating a filing claim from its source record, see SEC cyber-incident disclosure source recovery.
TOP Prospect can retain and prioritise relevant fragments from Telegram groups the user connected and was authorised to access, with source, time and review context. A newly saved matching target in the current product does not automatically run or create candidates. It cannot access an employer’s ITA account, determine recordability, file forms, correct OSHA records or contact the author. The Signal workflow explains the human review handoff.
Key facts
- OSHA ITA routine thresholds apply by establishment, not by total company headcount.
- The rule uses 2017 NAICS codes and the establishment’s highest employment at any time during the covered year.
- Temporary, seasonal, part-time and full-time workers are included in that employment count.
- Appendix B establishments with at least 100 employees submit required 300 and 301 data as well as 300A data.
- Routine annual submissions are due March 2 of the following year.
- A receipt must be matched to the establishment, year, form set and actual ITA status.
FAQ
Does a company with more than 300 employees always submit Forms 300, 301 and 300A electronically?
No. Apply the establishment’s prior-year peak employment, 2017 NAICS and Part 1904 status. The company-wide number alone cannot select the form set.
When are routine annual OSHA ITA submissions due?
March 2 of the year after the calendar year covered. Calendar-year 2025 data was due March 2, 2026.
Do temporary and seasonal workers count?
Yes. The peak employment measure includes every individual employed at the establishment at any time during the year, including temporary and seasonal workers.
Does an ITA receipt prove full compliance?
No. Verify which establishment, year and forms the receipt covers and whether the ITA status is accepted, rejected or corrected. The receipt does not validate every underlying injury and illness record.
Reviewed by TOP Prospect Editorial Team on 20 August 2026 against 29 CFR Part 1904, OSHA ITA materials and the 2023 final rule. Establishment coverage and filing decisions require the current rule, authorised records and qualified review.
Frequently asked questions
Does a company with more than 300 employees always submit Forms 300, 301 and 300A electronically?
No. The routine electronic-submission tests apply to each establishment and use its prior-year peak employment, 2017 NAICS and Part 1904 status. Company-wide headcount alone does not decide the form set.
When are routine annual OSHA ITA submissions due?
Section 1904.41 sets March 2 of the year after the calendar year covered by the forms. For example, calendar-year 2025 data was due March 2, 2026.
Do temporary and seasonal workers count toward the establishment threshold?
The rule counts every individual employed at the establishment at any time during the calendar year, including full-time, part-time, seasonal and temporary workers.
Does an ITA receipt prove the establishment fully complied?
Not by itself. Match the receipt and ITA status to the correct establishment, reporting year and required forms, and check whether the submission was accepted, rejected or later corrected.
Sources and further reading
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