Submission of OSHA Form 300-A (Summary of Work-Related Injuries and Illnesses) OSHA Recordkeeping

The Calendar Year 2020 Announcements

The reference point to determine the need for compliance is based on the number of employees at an Establishment and the NAICS Code. Covered establishments must electronically submit information from their OSHA Form 300-A by March 2, 2021.

OSHA Website

Not all establishments are covered by this requirement.

Let’s start with defining the word establishment. An establishment is defined as a single physical location where the business is conducted or where services or industrial operations are performed.

A firm may be comprised of one or more establishments. The submitted data must be specific for each individual establishment. A firm with more than one establishment must submit establishment-specific 300A data for each establishment that meets the size and industry reporting criteria. The data may be submitted using one ITA account. It is important to note that the electronic reporting requirements are for data at the establishment level, not the firm level.

The reference point to determine the need for compliance is based on:

  1. Establishments with 250 or more full or part-time employees that are currently required to keep OSHA Injury and Illness records; or
  2. Establishments with 20-249 full or part-time employees that are classified in certain industries (NAICS Codes) with historically high rates of occupational injuries and illnesses.

The NAICS Code (North American Industry Classification System) code can be found on the Federal Tax Return and is listed as Activity Code.

Establishments that meet any of the following criteria DO NOT have to send their information to OSHA. Remember, these criteria apply at the establishment level, not to the firm as a whole.
  1. The establishment peak employment (full-time & part-time) during the previous calendar year was 19 or fewer, regardless of the establishment’s industry.
  2. The establishment industry is on the list of Non-Mandatory – Partially Exempt Industries, regardless of the size of the establishment.
  3. The establishment had peak employment (full-time & part-time) between 20 and 249 employees during the previous calendar year AND the establishment’s industry is not on the REQUIRED ESTABLISHMENT LIST defined as “certain high-risk industries”.

Tom Conigliaro, our Director of Risk Management Services here at Joyce, Jackman & Bell Insurors is available to discuss OSHA Form 300-A. Call the agency at 570-654-5223 or email Tom at