How to Hit Every OSHA 300 Log Recordkeeping Deadline

It's January, and the EHS reporting season is in full swing. If you're responsible for injury and illness records, you already know the OSHA 300 log deadlines cluster in the first three months of the year. Missing even one can trigger a citation under 29 CFR 1904.32 or 1904.33. Here's how to work through each deadline in order, with the exact dates and documents you need.

Know What You're Filing and When

The OSHA 300 log is your annual record of work-related injuries and illnesses. But it's not the only document on the calendar. You also need the OSHA 301 Incident Report (or an equivalent) for each logged case, and the OSHA 300A Summary, which is the annual tally.

The deadlines that matter:

1. February 1 – Post the OSHA 300A Summary in a visible location where employees normally check notices.
2. February 1 – Electronically submit the 300A Summary to OSHA through the Injury Tracking Application (ITA), if you're in a state that uses federal OSHA's reporting system.
3. April 30 – Keep the 300A posted until this date.
4. March 2 – Submit the 300A electronically if your establishment meets the size/industry criteria (see below).
5. Within 7 calendar days – Record any new work-related injury or death that meets the recording criteria (29 CFR 1904.29(b)(3)).

That last one is a rolling deadline—every new case has its own 7-day window. Don't let it slip while you're focused on the annual summary.

Step 1: Verify Your Establishment's Exemption Status

Before you do anything, confirm whether you're required to keep a log at all. Under 29 CFR 1904.1, establishments with 10 or fewer employees at all times during the previous calendar year are partially exempt. So are establishments in specific low-hazard industries, as listed in 29 CFR 1904.2.

If you're exempt, you don't need to post or submit the 300A. But check your state plan—some states (like California and Washington) have stricter requirements. Don't assume federal rules apply everywhere.

Step 2: Review and Correct the OSHA 300 Log

Before you can certify the 300A, you need to make sure the 300 log is complete and accurate. Go through each entry and verify:

• The case was correctly classified (injury, skin disorder, respiratory condition, poisoning, or other illness).
• The days away from work or restricted duty are counted correctly, including the cap at 180 days (29 CFR 1904.7(b)(3)(v)).
• The privacy concern cases (29 CFR 1904.29(b)(7)) are redacted correctly—names removed, but the log still shows the case.

Common mistake: people forget to count the day of the injury as a lost workday. It's not counted—the first full day away is day one. Fix that before you post.

Step 3: Prepare and Certify the OSHA 300A Summary

The 300A is a separate form that totals the year's columns from the 300 log. You must complete it even if you had zero recordable cases. The form asks for the annual average number of employees and total hours worked—use the same payroll figures you'd use for workers' comp.

After filling it in, a company executive must certify it. Under 29 CFR 1904.32(b)(3), that's a company executive—not the safety manager—who certifies the summary is true and accurate. The certification is your signature line on the 300A. If the executive is away, get a deputy or someone with authority to sign. Don't leave it blank.

Step 4: Post the 300A by February 1

This is the hard deadline that catches most people. The 300A must be posted by February 1 and stay up until April 30. The posting location must be where employees typically see notices—the breakroom, the main entrance, or the HR board. If you have workers who don't report to a fixed site, post a copy at each location or send it electronically to all affected employees.

If you're in a state with its own OSHA plan, check whether the posting window is the same. Most follow the federal dates, but a few (like Oregon) have slightly different rules.

Step 5: Submit Electronically by March 2 (If Required)

Electronic submission is a separate step from posting. Under 29 CFR 1904.41, establishments with 20 or more employees in designated high-hazard industries (as listed in Appendix A to Subpart E) must submit their 300A to OSHA's ITA by March 2. The ITA is at osha.gov/ita.

If you're not in a high-hazard industry, you may still need to submit if your state has its own electronic reporting mandate. For example, California requires electronic submission for more industries than federal OSHA. Check your state plan's website before you assume you're exempt.

Step 6: Keep the 300 Log and 301 Forms for Five Years

Once you've posted and submitted, you're not done. The 300 log and 301 forms must be retained for five years following the end of the calendar year (29 CFR 1904.33(a)). So the 2024 log stays on file through 2029. Keep them in a place that's accessible to OSHA inspectors—they can ask for them at any time during an inspection.

A common mistake is to discard the 300 log after posting the 300A. The 300A is just a summary; the detailed log is what OSHA reviews when they audit your recordkeeping.

What to Do If You Miss a Deadline

If you realize you missed the February 1 posting or the March 2 submission, don't panic. Correct the omission immediately. OSHA typically treats a late posting as a minor violation if you can show good faith and fix it quickly. But a repeated pattern of late submissions can escalate to a willful violation.

For electronic submission, the ITA system has a late-submission window, but it's better to file on time. If you're unsure whether your establishment is required, check the OSHA 300A instructions or use the ITA's industry lookup tool.

Takeaway: Build a Year-Round Calendar

The deadlines cluster, but they're not the only dates that matter. Every recordable injury has a 7-day recording window. Every year, you need to review, certify, post, and submit. The easiest way to avoid missing a deadline is to put the dates on your EHS calendar in December—before the year ends—and assign an owner to each step.

If you're new to this, start by confirming your exemption statushare, then work backward from March 2. That way, you'll never be the one explaining to OSHA why your 300A wasn't posted.

FAQ

Q: What is the deadline to post the OSHA 300A Summary? A: The 300A must be posted by February 1 and remain posted until April 30. This applies to all establishments required to keep a log, even if you had zero recordable cases.

Q: Who can certify the OSHA 300A Summary? A: A company executive—such as the owner, partner, or highest-ranking officer—must certify the 300A. The safety manager cannot sign it unless they hold an executive position.

Q: Do I need to submit the 300A electronically if I have fewer than 20 employees? A: Not under federal OSHA unless you're in a state with stricter rules. Federal electronic submission applies only to establishments with 20 or more employees in designated high-hazard industries. Check your state plan.

Q: How long must I keep the OSHA 300 log and 301 forms? A: You must retain the 300 log and 301 incident reports for five years following the end of the calendar year they cover. For example, the 2024 log must be kept until 2029.

Q: What happens if I miss the March 2 electronic submission deadline? A: Submit as soon as you realize the omission. OSHA may accept a late filing, but repeated lateness can lead to citations. Correcting it quickly shows good faith.

Q: Are the deadlines the same in all states? A: Not always. State plans can have different posting windows, electronic submission requirements, or industry lists. Always check your state's OSHA website for local rules.