What you need to know
Companies with more than 10 employees at any time last year must keep OSHA injury and illness records unless partially exempt by industry, and must certify and post the 300A summary from February 1 to April 30. Covered establishments also file 300A data electronically by March 2, and all employers must report fatalities and severe injuries.
Potentially affected
Employers with field technicians and other staff, and the office, HR and safety staff who keep injury records and handle OSHA reporting.
DSE recommendation
DSE recommends assigning one owner for the OSHA 300 log and putting the February 1 posting and March 2 submission on the compliance calendar.
Companies with more than 10 employees at any time last year must keep OSHA injury and illness records unless partially exempt by industry, and must certify and post the 300A summary from February 1 to April 30. Covered establishments also file 300A data electronically by March 2, and all employers must report fatalities and severe injuries.
Source facts
Under 29 CFR 1904.1, a company that had more than 10 employees at any time during the last calendar year must keep OSHA injury and illness records unless its establishment is in a partially exempt industry, and the size test uses peak employment across the entire company. Even exempt employers must report any work-related fatality, in-patient hospitalization, amputation or loss of an eye.
29 CFR 1904.32 requires employers at year end to review the OSHA 300 log, create an annual summary, have a company executive certify it, and post it in each establishment no later than February 1 and keep it posted until April 30. If there were no recordable cases, the summary still needs zeros in each column total.
OSHA’s Injury Tracking Application page says covered establishments must submit 300A data electronically by March 2 of the following year, that establishments with 100 or more employees in listed industries must also submit 300 and 301 data, and that establishments with peak employment of 19 or fewer do not have to report electronically. It says the deadline this year was March 2, 2026, that late filers must still submit, and that establishments under State Plan jurisdiction should contact their State Plan.
Applicability
Use this for employers under federal OSHA. Michigan establishments fall under MIOSHA’s State Plan, so confirm recordkeeping and electronic reporting rules with MIOSHA.
DSE recommendation
DSE recommends assigning one owner for the OSHA 300 log and putting the February 1 posting and March 2 submission on the compliance calendar. Record cases as they happen, keep the log and incident reports with restricted access because they contain injury details, have an executive certify the summary in January, and check each year whether your establishments must submit electronically.
Verification
Each February, photograph the posted summary at every establishment, keep any electronic submission confirmation, and reconcile the log against workers’ compensation claims.
Official references
OSHA — 29 CFR 1904.1, Partial exemption for employers with 10 or fewer employees. OSHA — 29 CFR 1904.32, Annual summary. OSHA — Injury Tracking Application (ITA) Information. Reviewed October 19, 2026.
Review the official source
OSHA — 29 CFR 1904.1, Partial exemption for employers with 10 or fewer employees · Verified October 19, 2026
Need help applying this guidance safely?
DSE can help confirm applicability, protect service continuity, and validate the result across physical security and IT systems.
Talk with DSE