For most of its life, the OSHA injury log was a folder. You kept it, you posted the summary on the wall each February, and unless someone came asking, that was the end of it. It described your year to you.
That changed quietly. For larger employers in designated high-hazard industries, the log does not stay in the folder any more — it is transmitted. And since 2024 it is not just the summary that leaves the building.
What actually gets submitted
Establishments covered by the electronic reporting rule submit information from their Form 300A— the annual summary. That part has been running for years, and it is a set of counts: how many recordable cases, how many days away, how many restricted.
The change is that some establishments must also submit information from their Form 300 and Form 301— beginning in 2024. Those are a different animal. The 300 is the log itself, case by case. The 301 is the incident report behind each one.
The distinction matters more than it sounds. A summary says eleven recordable injuries. Case-level detail says what happened, to whom, in what job, on what date, and what the outcome was. It is the difference between a number and a narrative.
Whether it applies to you
The thresholds are a combination of size and industry, not size alone. An establishment is outside the electronic reporting requirement if it meets any of these:
- peak employment of 19 or fewer in the previous calendar year;
- its industry is listed in Appendix A to Subpart B of the recordkeeping regulation; or
- peak employment between 20 and 249 and its industry is not listed in Appendix A to Subpart E.
The case-level obligation — the 300 and 301 — attaches to establishments with 100 or more employees in the industries designated under Appendix B to Subpart E.
Two things trip people here. The first is that the test is per establishment, not per company — a business under the threshold overall can have a location over it. The second is that the industry lists do the real work: two firms of identical size can land on opposite sides depending on their classification.
The deadline, and the thing about missing it
Submission is due by 2 March for the preceding calendar year.
What is worth knowing is what happens if that date goes past. It does not close the matter. In OSHA’s own words, establishments that meet the reporting requirements and failed to submit “must still submit the required recordkeeping data through the ITA and can do so until December 31.”
A missed deadline is not a lapsed obligation. It is an outstanding one, with your name against it, for the rest of the year.
Why a filing is different from a folder
Here is the part that is easy to miss while ticking off a compliance task.
A folder is only ever examined in context — someone visits, asks, and you walk them through it. A filing is a dataset. It can be compared: against your own prior years, against your industry, and against what you are able to produce when someone follows up on a specific line in it.
Which relocates the risk. The exposure is no longer really the form — the form is a few hours of work and a portal upload. The exposure is the source record sitting behind each submitted case. When a case from eighteen months ago is queried, the question is whether the day it describes can be reconstructed: what the crew was doing, what controls were in place, what was checked before work started, who was on site.
For a lot of field businesses, honestly answered, that reconstruction looks like:
- a supervisor’s recollection, eighteen months later;
- photos on a phone belonging to someone who has since left;
- a toolbox talk that definitely happened, with an attendance sheet nobody can find;
- a pre-start check that was done properly and recorded nowhere.
None of that is negligence. It is the ordinary result of capturing safety on paper in a moving environment. But it is a poor answer to a question about a case you yourself filed.
What we do about it
FieldTaskora is aimed squarely at that gap — not the submission, but the record underneath it.
- Pre-starts and safety checks are captured as work happens, on the phone the crew already carries, rather than on a sheet that has to survive a ute and a week.
- Who, when and where attach themselves. No one types the metadata, which is exactly the detail memory gets wrong at eighteen months.
- Incidents and near misses are raised in the field, against the job they happened on, so the context is captured while it is still fresh rather than reassembled for a report.
- Original media is hash-verified, so the evidence is defensible rather than merely available.
- Any job comes back out as a documentcarrying your branding — for an insurer, a client, or a follow-up question about a case you submitted.
The uncomfortable bit
Filing accurately is not the hard part, and most businesses do it. The hard part is that accurate filing makes you legible. Once your case detail is a row in a federal dataset, the follow-up question is no longer “do you keep records?”— it is about a specific case, on a specific date, that you reported yourself.
That question is answered by what the crew captured on the day. Not by the form.
Source: OSHA on injury and illness recordkeeping and electronic submission. Thresholds turn on the industry appendices to the recordkeeping regulation, so check your own classification. This is general information about record-keeping practice, not legal or safety advice.