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While most employers understand that OSHA requires them to record and report workplace injuries annually, many businesses are still cited for technical violations of these requirements, such as failing to electronically submit injury and illness records or not timely posting a proper OSHA Form 300A.
Two years ago, federal OSHA established its Injury Tracking Application (ITA) online portal, enabling covered employers to electronically submit their OSHA injury and illness records (Forms 300, 300A, and 301) each year. ITA submissions are required by March 2 following the reporting year. Michigan OSHA (MIOSHA) adopted and expanded upon the federal requirement through its Part 11, Recording and Reporting of Occupational Injuries and Illnesses. States are required to follow federal OSHA's recordkeeping requirements as well.
Only certain establishments are required to submit electronic reports via the ITA each year. Reporting requirements differ depending on employer size and industry, as detailed below:
- Employers with 100 or more employees in high-hazard
industries
Must electronically submit OSHA Form 300 (Log of Work-Related Injuries and Illnesses) and OSHA Form 301 (Injury and Illness Incident Report) - Employers with 20 to 249 employees in high-hazard
industries
Must electronically submit OSHA Form 300A (Summary of Work-Related Injuries and Illnesses). - Employers with 250 or more employees
Must electronically submit OSHA Form 300A, provided they are routinely required to keep OSHA records.
Employers with 10 or fewer employees at all times during the previous calendar year are partially exempt from routinely keeping OSHA injury and illness records. Additionally, establishments classified in certain low-hazard industries are exempt unless specifically requested in writing by OSHA. Federal OSHA has a website which provides guidance to employers about whether they are required to file electronically or not. MIOSHA also has a chart summarizing the coverage for each filing requirement.
Neither OSHA nor MIOSHA notify employers whether they must electronically submit their injury and illness records using the ITA. Employers are responsible for independently determining whether they are subject to the electronic reporting requirements.
In addition to ITA submissions, employers are required to prominently display their Form 300A summary of work-related injury and illness data at the workplace from February 1 to April 30 each year. With the Form 300A, the employer certifies the information in their Log of Work-Related Injuries and Illnesses (Form 300) is complete and accurate.
A common misconception, which often leads to citations, is that any employee can complete the Form 300A. Pursuant to 29 C.F.R. § 1904.32(b)(3)-(4), the Form 300A can only be certified by a "company executive," defined as the owner of the company, an officer of the company, the highest ranking company official working at the establishment, or the immediate supervisor of the highest ranking company official working at the establishment.
Key Takeaway: Employers must ensure they are prepared to comply with both federal and state electronic reporting requirements by March 2, 2026, and posting requirements by Feb. 1, 2026. Staying informed about OSHA's evolving standards and mastering the ITA process will remain essential for compliance.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
