OSHA Form 300A, the Annual Summary of Work-Related Injuries and Illnesses, must be posted in a visible spot in your workplace from February 1 through April 30 each year, covering the prior calendar year’s recordable cases. Most employers with more than ten employees are covered, and the summary must go up even if nothing recordable happened all year. A company executive has to sign it first. Skip the posting or get the numbers wrong and OSHA can assess penalties of $16,550 or more per violation.1Occupational Safety and Health Administration. OSHA Penalties
Which Employers Have to Post
If your company had more than ten employees at any point during the previous calendar year, you are covered by OSHA’s recordkeeping rules under 29 CFR Part 1904. The count looks at your entire company, not each location, so a business with twelve employees spread across three small offices still has to keep records at each establishment.2Occupational Safety and Health Administration. 1904.1 – Partial Exemption for Employers With 10 or Fewer Employees
Some low-hazard industries get a partial exemption from routine recordkeeping, based on the establishment’s NAICS code. The full list sits in Appendix A to Subpart B of Part 1904 and includes legal services, accounting firms, full-service restaurants, physician offices, religious organizations, and electronics retailers.3eCFR. 29 CFR Part 1904 Subpart B – Scope The exemption applies at the establishment level, so a company with sites in different industries might be exempt at one and covered at another.
If you operate in a state that runs its own OSHA-approved plan, the rules can be stricter. A state plan may require recordkeeping from employers with ten or fewer workers or add data requirements beyond the federal ones, so check your state’s version before assuming the federal exemption applies to you.4Occupational Safety and Health Administration. How May State Regulations Differ From the Federal Requirements
Where and When to Post the Summary
The certified Form 300A goes up no later than February 1 and stays up through April 30. That is a full three-month window with no early takedown allowed. Post it where you normally hang employee notices so workers actually see it, and keep it visible and unobstructed the entire time. Covering it with another posting or moving it out of sight counts as a posting failure.5eCFR. 29 CFR Part 1904 – Recording and Reporting Occupational Injuries and Illnesses
Zero recordable cases does not get you out of posting. If your Form 300 Log is empty, you still complete Form 300A with zeros in each field and post it during the three-month window. A blank summary still tells employees something meaningful about the workplace, which is why OSHA requires it either way.6Occupational Safety and Health Administration. Injury Tracking Application Frequently Asked Questions
Form 300A is also the only one of OSHA’s three recordkeeping forms that gets posted publicly. The detailed Form 300 Log and the individual Form 301 incident reports stay in your files. The summary exists so workers can see the establishment’s overall safety record without exposing details about specific incidents or individuals.7Occupational Safety and Health Administration. Posting Requirements for the OSHA 300 Log and OSHA 300-A Summary Form
What Goes on Form 300A
You fill out Form 300A after the calendar year ends, using totals pulled directly from your Form 300 Log. The form asks for case counts in four categories: total deaths, total cases with days away from work, total cases involving job transfer or restriction, and total other recordable cases. Enter zeros rather than leaving fields blank.8Occupational Safety and Health Administration. OSHA Recordkeeping Forms Package
Annual Average Number of Employees
Add up the number of employees on the payroll during each pay period, then divide by the number of pay periods in the year. Round up to the next whole number. Include full-time, part-time, temporary, and seasonal workers. A common mistake is dividing the number of W-2s issued by pay periods; OSHA specifically calls that approach wrong because it overcounts anyone who was only on the payroll for part of the year.9Occupational Safety and Health Administration. OSHA Recordkeeping Forms Package – Optional Worksheet to Help You Fill Out the Summary
Total Hours Worked
Count only actual working hours. Vacation, sick leave, holidays, and other paid non-work time are excluded even though employees were paid for them. If your payroll system tracks hours paid rather than hours worked, or if you have salaried staff, you have to estimate actual hours worked.10Occupational Safety and Health Administration. How Do I Calculate the Total Hours Worked on My Annual Summary
Executive Certification
Before the summary goes on the wall, a company executive has to review the Form 300 Log, verify the summary is accurate, and sign it. The certifying person is typically the owner, a corporate officer, or the highest-ranking official at the establishment. The signature confirms that, to the executive’s knowledge, the entries are true and complete.11Occupational Safety and Health Administration. 1904.32 – Annual Summary An unsigned Form 300A is treated as incomplete, so the certification is not optional.
Electronic Submission Is a Separate Obligation
Posting the summary in the workplace does not satisfy OSHA’s electronic reporting rule, and submitting electronically does not replace the posting. Both apply on their own. Electronic submissions go through OSHA’s Injury Tracking Application (ITA), and the deadline is March 2 each year for the prior calendar year’s records. Missing that date does not erase the obligation; late submissions are still required.12Occupational Safety and Health Administration. Injury Tracking Application (ITA)
Three categories of establishments have to submit electronically:
- Establishments with 250 or more employees that are not on OSHA’s exempt-industry list must submit Form 300A data.
- Establishments with 20 to 249 employees in industries listed in Appendix A to Subpart E of Part 1904 must submit Form 300A data.
- Establishments with 100 or more employees in industries listed in Appendix B to Subpart E must submit detailed data from Forms 300 and 301 in addition to the 300A summary.
The 100-employee threshold for submitting detailed Form 300 and 301 data took effect beginning with calendar year 2023 data. These submissions include specifics about each recorded injury: the date, location, severity, worker details, and how the incident happened.13Occupational Safety and Health Administration. Final Rule Issued to Improve Tracking of Workplace Injuries and Illnesses All electronic submissions share the same March 2 deadline.6Occupational Safety and Health Administration. Injury Tracking Application Frequently Asked Questions
What It Costs to Get This Wrong
OSHA’s civil penalties for recordkeeping and posting failures are not symbolic. As of January 15, 2025, the maximum penalty for a serious, other-than-serious, or posting-requirement violation is $16,550 per violation. Willful or repeated violations carry a maximum of $165,514 per violation.1Occupational Safety and Health Administration. OSHA Penalties These figures adjust upward for inflation every year, so the numbers in effect when OSHA arrives at your door may be higher.14Occupational Safety and Health Administration. US Department of Labor Announces Adjusted OSHA Civil Penalty Amounts for 2025
A willful violation means the employer intentionally ignored the requirement or showed plain indifference to it. A repeated violation means OSHA cited the same employer for the same type of violation within the past five years. Both carry dramatically higher exposure than a first-time, good-faith mistake. Because each missing or inaccurate log entry can count as a separate violation, an employer who systematically fails to record injuries can accumulate penalties across dozens of individual cases in a single inspection.
Keep the Records for Five Years
Take the summary down on May 1, but do not throw it away. You must keep your Form 300 Log, Form 300A summary, and Form 301 reports for five years after the end of the calendar year they cover. During that retention period, the Form 300 Log obligation continues. If you learn that an injury was more or less serious than originally classified, or a new recordable case from the prior year surfaces, you have to correct the log by lining out the original entry and adding the updated information. You are not required to update the Form 300A summary for previous years.15eCFR. 29 CFR Part 1904 Subpart D – Other OSHA Injury and Illness Recordkeeping Requirements
OSHA can ask to see any of these records during an inspection. If you discarded them early, the exposure is the same as never having kept them at all.