OSHA’s high hazard industry list is the set of North American Industry Classification System (NAICS) codes that the agency has flagged, in Appendix A and Appendix B to Subpart E of 29 CFR Part 1904, as having the worst injury and illness track records. If your establishment’s NAICS code appears on either list, you must submit injury data electronically each year through OSHA’s Injury Tracking Application, and you carry a higher probability of being selected for a programmed inspection. The national benchmark regulators measure you against is the private industry DART rate of 1.4 cases per 100 full-time workers.1Bureau of Labor Statistics. Table 1 – Incidence Rates of Nonfatal Occupational Injuries and Illnesses
How Industries Get on the List
OSHA measures industry risk with two rates drawn from employer-submitted data. The DART rate counts recordable incidents per 100 full-time workers that led to days away, restricted duties, or a job transfer. The Total Recordable Case rate is broader, capturing every work-related injury or illness that required more than basic first aid, including fatalities, losses of consciousness, and diagnosed conditions like fractures or chronic disease. Both are calculated by multiplying the raw case count by 200,000 (one hundred employees working full-time for a year) and dividing by total hours worked.
Two appendices do the sorting. Appendix A to Subpart E of Part 1904 covers a broad group of industries whose mid-sized establishments, meaning those with 20 to 249 employees, must submit annual summary data.2eCFR. Appendix A to Subpart E of Part 1904, Title 29 Appendix B is narrower and applies to larger establishments, those with 100 or more employees, that must submit detailed case-level records.3Legal Information Institute. 29 CFR Appendix B to Subpart E of Part 1904
Neither appendix is permanent. OSHA revises them as industry injury trends move, so it is worth checking your NAICS code against the current version before every annual submission.
Which Industries Are on the List
Appendix A is wide. Entire two-digit NAICS sectors are covered, including agriculture, forestry, utilities, construction, manufacturing, and wholesale trade. Retail is included selectively: grocery stores, department stores, building material dealers, and warehouse clubs, among others. Transportation and warehousing appear heavily, from general freight trucking and couriers to urban transit and warehousing and storage operations.2eCFR. Appendix A to Subpart E of Part 1904, Title 29
Healthcare shows up repeatedly: general medical and surgical hospitals, psychiatric and substance abuse hospitals, nursing care facilities, and residential care facilities for people with intellectual disabilities or mental health conditions. Psychiatric and substance abuse hospitals carry some of the highest injury rates in the economy, reaching 146.5 per 10,000 full-time workers.4Occupational Safety and Health Administration. Prevention of Workplace Violence in Healthcare and Social Assistance – Issues Document Waste collection, waste treatment, and remediation services are on the list, along with less obvious entries like performing arts companies, spectator sports, and vocational rehabilitation services.
What You Have to File and When
Three groups of employers must submit injury and illness data electronically through OSHA’s Injury Tracking Application, and the scope of what each group files differs.5Occupational Safety and Health Administration. Electronic Submission of Employer Identification Number (EIN) and Injury and Illness Records to OSHA
- Establishments with 20 to 249 employees in an Appendix A industry submit Form 300A, the annual summary of total case counts, days away, and injury types.
- Establishments with 100 or more employees in an Appendix B industry submit Form 300A plus the detailed Form 300 injury log and a Form 301 incident report for every individual case.
- Establishments with 250 or more employees in any industry subject to OSHA recordkeeping submit Form 300A, whether or not the industry sits on either appendix.
The deadline for all three groups is March 2 of the year after the calendar year the data covers.5Occupational Safety and Health Administration. Electronic Submission of Employer Identification Number (EIN) and Injury and Illness Records to OSHA Every employee who worked at the establishment at any point during the year counts toward the threshold, including part-time, seasonal, and temporary workers.
What Each Form Contains
Form 300A is a one-page summary. It totals the recordable cases, days away from work, job transfers, and injury types for the entire year, and a company official (the owner, a corporate officer, or the highest-ranking person at the establishment) must certify it. You are also required to post Form 300A in a visible workplace location from February 1 through April 30.6Occupational Safety and Health Administration. Brief Tutorial on Completing the OSHA Recordkeeping Forms
Form 300 is the running log. Each line captures one work-related injury or illness: job title, date, location, a short description, and the body parts affected. Form 301 goes deeper into each incident, recording what the employee was doing, what object or substance was involved, and how the injury occurred.
Redact Personal Information Before Uploading
When you upload Form 300 and 301 data to the Injury Tracking Application, personally identifiable information has to come out. Names, Social Security numbers, addresses, phone numbers, email addresses, healthcare provider details, and family member information must be stripped from every text field before submission.7Occupational Safety and Health Administration. Injury Tracking Application (ITA) User Guide That includes job title fields, incident location descriptions, and the narrative columns describing what happened. Keep your internal records complete and prepare a separate redacted version for upload; the redaction step belongs in the submission workflow rather than at the end of it.
Who Is Exempt
Two partial exemptions exist. Any company that had ten or fewer employees at all times during the previous calendar year does not need to maintain OSHA injury and illness logs.8Occupational Safety and Health Administration. Partial Exemption for Employers With 10 or Fewer Employees The count is company-wide, not per location. If headcount peaks at 11 at any point in the year, the exemption is lost for that entire year.
Establishments classified under certain low-hazard NAICS codes listed in Appendix A to Subpart B of Part 1904 are also exempt from routine recordkeeping. These tend to be office-based or service industries with historically low injury rates.9Occupational Safety and Health Administration. Partially Exempt Industries
Neither exemption releases you from reporting a work-related fatality, hospitalization, amputation, or loss of an eye. Every employer covered by the OSH Act must report those incidents directly to OSHA regardless of company size or industry.8Occupational Safety and Health Administration. Partial Exemption for Employers With 10 or Fewer Employees OSHA or the Bureau of Labor Statistics can also notify an otherwise exempt employer in writing that recordkeeping is required for a specific period.
Why Being on the List Changes Your Inspection Odds
The Site-Specific Targeting program is OSHA’s primary tool for picking non-construction workplaces with 20 or more employees for programmed inspections, and it runs directly on the data you submit. The software flags establishments on several criteria:10Occupational Safety and Health Administration. US Department of Labor Updates Inspection Program Focusing on Workplaces With Highest Injury, Illness Rates
- DART rates above a threshold set separately for manufacturing and non-manufacturing.
- Rates at or above twice the private sector national average that have kept climbing over a three-year period.11Occupational Safety and Health Administration. CPL 02-01-067 – Site-Specific Targeting (SST-17)
- Rates far below industry averages, which may signal underreporting.
- Failure to submit Form 300A at all.
Flagged establishments go onto a randomized inspection list. Area offices generate inspection cycles, typically 5 to 50 establishments each depending on staffing and geography, and inspectors use the previously submitted Form 300 and 301 data as their starting point for walk-throughs and employee interviews.12Occupational Safety and Health Administration. CPL 02-01-064 – Site-Specific Targeting (SST-16)
Do not expect a warning before the inspector arrives. Federal law makes it a crime to give unauthorized advance notice of an OSHA inspection, punishable by a fine up to $1,000, up to six months in jail, or both.13eCFR. 29 CFR 1903.6 – Advance Notice of Inspections Narrow exceptions exist for imminent danger, after-hours access, and cases the area director specifically approves, but they are rare in practice.
Penalties for Skipping or Falsifying Reports
OSHA adjusts civil penalties every year for inflation. Under the adjustment effective January 15, 2025, the maximums are:14Occupational Safety and Health Administration. OSHA Penalties
- Serious violation: up to $16,550 per violation.
- Other-than-serious violation: up to $16,550 per violation.
- Failure to abate: up to $16,550 per day beyond the abatement deadline.
- Willful or repeated violation: up to $165,514 per violation, with a minimum of $11,823 for willful violations.15Occupational Safety and Health Administration. Federal Civil Penalties Inflation Adjustment Act Annual Adjustments
Recordkeeping problems (missed electronic submissions, incomplete logs, misclassified injuries) can be cited as other-than-serious or serious depending on the circumstances.16Office of the Law Revision Counsel. 29 USC 666 – Penalties In egregious cases, OSHA can issue per-instance citations, treating each missing or falsified Form 300 entry as a separate violation. The arithmetic gets ugly quickly. And skipping the ITA submission is doubly costly, because the non-filing itself puts your establishment on the SST inspection list.
State Plan States Handle This Differently
About half the states run their own OSHA-approved occupational safety programs. Federal law requires those state plans to be at least as effective as federal OSHA, but the targeted industries, inspection selection criteria, and penalty amounts can differ. If your business operates in a state plan state, confirm with your state occupational safety agency which reporting requirements and inspection programs apply to your establishments; the federal rules above may be implemented on a different schedule or with a different scope.