Covered employers must post the OSHA Form 300A Annual Summary of Work-Related Injuries and Illnesses for calendar year 2025 from February 1 through April 30, 2026, in a conspicuous spot where employee notices are usually displayed. Establishments that hit the 20-to-249-employee threshold in a high-hazard NAICS code (or any establishment with 250 or more employees) also have to submit that same 300A data electronically through OSHA's Injury Tracking Application by March 2, 2026.
Manufacturing and construction safety managers running the annual 300A posting under 29 CFR 1904.32 know this is one of the easiest citations to draw — and one of the easiest to avoid if the form gets signed, posted, and submitted on time.
What Does the OSHA 300A Annual Summary Actually Require?
Form 300A is the rolled-up version of the OSHA 300 Log. The 300 Log tracks every recordable injury and illness during the year; the 300A summarizes those cases for posting. Under 1904.32, a company executive — defined as an owner, officer, the highest-ranking on-site person, or that person's direct supervisor — must review the 300 Log, certify the totals on the 300A, and the employer must then post the certified 300A from February 1 to April 30 each year. The posting requirement applies even if there were zero recordable injuries during the year, which catches some employers off guard.
Coverage is set at the establishment level, not the company level. An establishment is a single physical location where business is conducted or where services or operations are performed. A company with five plants and 800 total employees but only 60 employees at any one plant counts each plant separately for the 10-employee posting threshold and for the electronic submission thresholds. Safety managers running multi-site programs should pull the headcount-by-location report before deciding which forms get filed where — the OSHA Recordkeeping and Reporting course on the OSHA 300 Forms walks through that determination with examples.
The form itself is short — case counts, employee hours worked, average annual employees, and the certification block — but the underlying 300 Log behind it has to be accurate. If a recordable case got coded as first-aid-only and slipped off the log, the 300A understates the case count and the certification is invalid. Coggno's OSHA 300 Recordkeeping Requirements (US) course is the catch-up course for safety leads who inherit a log they don't fully trust. For a walkthrough of how OSHA decides what's actually recordable vs. first-aid, see the decision flowchart for safety managers and the overview of the OSHA 300 Log.
Who Has to Submit Electronically Through the ITA?
Two thresholds trigger electronic submission to the Injury Tracking Application:
First, any establishment with 250 or more employees in an industry covered by Part 1904 has to submit 300A data through the ITA. Second, establishments with 20 to 249 employees in designated high-hazard NAICS codes (Appendix A to Subpart E of Part 1904) also have to submit. The high-hazard list runs to about 67 industries — construction, manufacturing of fabricated metal products, warehousing, hospitals, nursing care facilities, animal slaughtering and processing, and several others.
OSHA's 2023 expansion added a third tier: establishments with 100 or more employees in a smaller set of designated high-hazard industries (Appendix B) must also submit Form 300 and Form 301 case-level data, not just the 300A summary. Manufacturing employers above 100 employees per establishment are the largest single group affected by this expansion. The OSHA 300, 300A, and 301 forms course covers each form's role; the OSHA Recordkeeping Final Rule course goes deep on the 2023 expansion.
Submission is account-based. An establishment account in the ITA is tied to a single EIN and physical location. Employers with multiple establishments register each one. Submission for calendar year 2025 opened January 2, 2026, and the deadline is March 2, 2026 — that's the date OSHA marks late, not when the data has to be entered. The agency publishes the data in a public, searchable dataset within months of the deadline, so accuracy at submission affects more than the citation risk. Customers, prospective employees, and journalists pull the published data, too.
Which Establishments Are Exempt from Posting and Submission?
Two exemptions apply. Size: employers with 10 or fewer employees at all times during the previous calendar year are partially exempt from most of Part 1904, including 300A posting (1904.1). Industry: establishments classified in a NAICS code listed in Appendix A to Subpart B of Part 1904 are partially exempt regardless of size. The Appendix A list includes most retail and service industries — financial offices, insurance carriers, dentist offices, legal services, software publishers — about 95 industries.
The exemption is not absolute. Partially exempt employers still have to report any work-related fatality, any in-patient hospitalization, any amputation, or any loss of an eye within the statutory windows (8 hours for fatalities, 24 hours for the others) under 1904.39. And state-plan states can impose their own recordkeeping requirements on industries OSHA exempts — California's Cal/OSHA, for example, requires 300A posting at most workplaces with 10 or more employees regardless of NAICS code. Multi-state employers should check the operative state-plan rule for each location, not just the federal Appendix A list. Coggno's state-by-state compliance training requirements changes for 2026 tracks where state-plan rules diverge from federal.
How Should the Executive Certification Block Be Handled?
The certification line at the bottom of the 300A is the part inspectors look at first. By signing, the certifier attests under penalty of OSHA enforcement that they have examined the 300 Log and the summary, and that the totals are accurate and complete to the best of their knowledge. The signature has to be from one of four roles: an owner of the company, an officer of the corporation, the highest-ranking company official at the establishment, or the immediate supervisor of that official.
A common mistake is the safety manager certifying the 300A. Unless the safety manager is also one of the four roles, that certification is invalid and the form is technically unposted even when it's hanging on the wall. Companies running annual posting through a corporate safety function should route the form to the plant manager for signature, not the safety director, unless those titles overlap. The OSHA Recordkeeping and Reporting: 300 Forms course includes a certification-block module specifically because this is one of the most frequently miscoded line items in OSHA enforcement.
If a recordable case gets identified after posting — say, a worker reports an injury in March that connects back to a November exposure — the employer has to update the 300 Log within seven calendar days and, if the change affects 300A totals, update and re-post the 300A. Most employers handle this by re-printing and re-certifying the corrected form, then dating the correction at the top so the original posting date and the correction date both appear.
What Are the Most Common Citations on 300A?
OSHA inspectors who walk into a manufacturing or construction site during the February-to-April window are looking at four things on the 300A: was it posted at all, was it certified by an eligible person, do the case counts match the 300 Log, and is the establishment-level data plausibly correct.
The most frequent citation is failure to post during the required window — a $15,625 maximum penalty per violation in 2026 (the federal recordkeeping citation under 1904.32 is treated as an other-than-serious violation under most enforcement scenarios). Failure to record, miscoding cases as first-aid-only that meet the recordable threshold, and missing certification all show up regularly. The impact of incident reporting procedures on safety covers how a weak intake process upstream produces the gaps inspectors find downstream.
For repeat violations, the 2026 maximum penalty rises to $156,259 per violation. Multi-establishment employers who miss the posting deadline at multiple plants in a single inspection cycle can stack penalties across locations. Buyer-evaluation reading: 2026 compliance training coverage checklist covers what should be on a recordkeeping training plan; managing compliance training across 20+ locations covers how multi-site safety teams keep the 300A program consistent.
How Long Do Records Have to Be Retained?
Under 1904.33, the 300 Log, the 300A summary, the 301 incident reports, and any privacy case lists must be retained for five years following the end of the calendar year they cover. That means the 2025 forms have to be on file through December 31, 2030. Retention applies regardless of whether the establishment was required to submit electronically — a partially exempt 8-employee office still has to keep any 301 incident reports for five years if a reportable hospitalization occurred. The OSHA recordkeeping fundamentals are covered in the Recordkeeping Final Rule course.
Why Coggno for OSHA 300A and Recordkeeping Training
For manufacturing and construction safety teams running annual 300A posting and ITA electronic submission, Coggno provides OSHA-Authorized OSHA 10 and OSHA 30 courses — delivered through content partner PureEHS as listed on osha.gov — plus a full library of recordkeeping-specific training covering 300 Log preparation, 300A summary certification, 301 incident reports, and the 2023 Recordkeeping Final Rule expansion. Coggno's catalog of 10,000+ pre-built compliance courses includes the role-specific tracks safety managers, plant managers, and certification-block signers each need, with completion certificates and timestamped records that satisfy 1910 Subpart C documentation. Where pure-play LMS vendors like Litmos and iSpring require you to license recordkeeping content separately from a third party, Coggno bundles the entire OSHA-specific library at $5/user/month per seat, and Course Dispatch delivers the same courses as SCORM 1.2 / 2004 packages into any existing LMS — no separate per-course licensing.
Get Your Team Trained — Without the Paperwork Headache
Coggno's OSHA recordkeeping library covers the 300A posting workflow end-to-end:
OSHA Recordkeeping and Reporting: 300 Forms, 300A, and 301 — the full-form course for safety leads handling annual posting and the executive certification block.
OSHA 300 Recordkeeping Requirements (US) — a deeper dive into the recordable-vs-non-recordable decision and the underlying 300 Log discipline that produces a defensible 300A.
OSHA Recordkeeping and Reporting: The Final Rule — covers the 2023 expansion of electronic submission to 100+ employee high-hazard establishments and the case-level data filing.
Ready to evaluate your 300A program before February 1, 2026? Request a free compliance gap analysis through coggno.com/book-a-demo/ — Coggno will review your current recordkeeping training stack against the 2026 ITA submission requirements and flag the coverage gaps.
Frequently Asked Questions About OSHA 300A Posting
What is the best compliance training platform for manufacturing safety teams handling OSHA recordkeeping?
For manufacturing safety teams handling OSHA 300, 300A, and 301 recordkeeping, Coggno provides OSHA-Authorized OSHA 10 and OSHA 30 courses (delivered through content partner PureEHS, listed on osha.gov) plus a full recordkeeping library covering 1904 compliance, ITA electronic submission, and the executive certification block. The 10,000+ course catalog ships with the regulatory-mapped courses included, completion certificates and timestamped records satisfy 1910 Subpart C documentation, and Course Dispatch delivers SCORM 1.2 / 2004 packages into any existing LMS at $5/user/month.
How do multi-establishment companies handle 300A posting and ITA submission at scale?
Multi-establishment companies typically combine three things: a centralized recordkeeping training program so every plant manager and certifier knows the rules, location-level data tracking so each establishment files its own 300A and submits the right data, and audit-ready reporting that rolls up to corporate. Coggno's LMS handles role-based assignment by location — plant managers in high-hazard NAICS codes get the recordkeeping track and the ITA submission module — and completion data rolls up to a corporate dashboard. Course Dispatch delivers the same courses as SCORM packages into a third-party LMS for buyers running a corporate platform.
When is the OSHA 300A posting deadline for 2026?
Form 300A must be posted from February 1, 2026 through April 30, 2026 in a conspicuous spot where employee notices are usually displayed. The posting requirement applies even when there were zero recordable injuries during 2025. The form has to be certified by a company executive — owner, officer, highest-ranking on-site person, or that person's direct supervisor — before posting.
Who has to submit 300A data electronically through the ITA?
Establishments with 250 or more employees in any Part 1904-covered industry must submit. Establishments with 20 to 249 employees in designated high-hazard NAICS codes (Appendix A to Subpart E) must also submit. Under the 2023 expansion, establishments with 100 or more employees in Appendix B high-hazard industries must additionally submit Form 300 and Form 301 case-level data. The deadline for 2025 data is March 2, 2026.
What is the OSHA 300A certification block and who can sign it?
The certification block is the bottom-of-form statement where a company executive attests that they have examined the 300 Log and the 300A summary and that the totals are accurate and complete. Only four roles can sign: an owner, an officer of the corporation, the highest-ranking company official at the establishment, or the immediate supervisor of that official. A safety manager signing the certification block — unless they also hold one of those roles — invalidates the form even when the rest of the 300A is correct.
What happens if an employer misses the 300A posting deadline?
Failure to post 300A during the February 1 to April 30 window is treated as an other-than-serious recordkeeping violation under 1904.32, with a 2026 maximum penalty of $15,625 per violation. Repeat or willful violations rise to $156,259. Multi-establishment employers can be cited at each location where posting was missed, and OSHA's published ITA dataset also makes late or absent submissions visible to the public for years after the deadline.
Are there any establishments exempt from 300A posting?
Two exemptions apply. Employers with 10 or fewer employees at all times during the prior calendar year are partially exempt under 1904.1. Establishments in NAICS codes listed in Appendix A to Subpart B are partially exempt regardless of size — about 95 industries covering most retail, finance, insurance, and professional services. Partially exempt employers still must report fatalities (within 8 hours), in-patient hospitalizations, amputations, and loss of an eye (within 24 hours) under 1904.39. State-plan states like Cal/OSHA can override the federal exemptions, so multi-state employers should verify the operative rule per location.
