OSHA ITA: How to comply as a construction employer

In addition to following OSHA’s safety regulations, contractors must maintain compliance with workplace incident reporting and recordkeeping. This includes completing Forms 300, 300A, and 301 and retaining them for five years. On top of standard paper or digital logging, many construction employers must also electronically submit these records through OSHA’s Injury Tracking Application (ITA). 

However, understanding electronic filing requirements isn’t always straightforward. OSHA enforces ITA reporting at the establishment level rather than company-wide. As such, contractors managing multiple jobsites or regional offices must evaluate each workplace independently. Key factors like workforce size, North American Industry Classification System (NAICS) codes, and subsector hazard levels dictate which logs each jobsite must submit through OSHA ITA.

This guide breaks down OSHA ITA reporting requirements, key reporting thresholds, and step-by-step instructions for meeting annual deadlines.

What is the OSHA Injury Tracking Application?

The OSHA ITA is an electronic reporting portal covered companies use to submit injury and illness reports. It simplifies collection of annual work-related injury and illness records to evaluate workplace safety. Employers can submit data through manual form entry, CSV upload, or automated data transfer via a connected application.

Which construction establishments must submit OSHA ITA data?

Construction employers don’t submit company-wide logs. OSHA ITA applies at the establishment level based on peak employee head count, NAICS code, and industry risk tier. Contractors overseeing multiple jobsites or offices may face different reporting requirements across workplaces:

• Establishments with 20 or more employees: Appendix A to Subpart E covers establishments with 20 to 249 employees, and it lists the entire construction sector (NAICS 23). Establishments with 250 or more employees are covered separately under 1904.41(a)(1)(ii), which applies to any establishment required to keep Part 1904 records. Either way, a construction establishment with 20 or more peak employees submits Form 300A electronically.
• Establishments with 100 or more employees in designated industries: Appendix B lists high-hazard subsectors. This includes Foundation, Structure, and Building Exterior contractors (NAICS 2381). Construction establishments operating in this sector with 100 or more peak employees must submit detailed incident data from Forms 300 and 301 in addition to their Form 300A summary.

Because electronic submission rules depend on exact subsector codes, contractors must assign each establishment to the correct six-digit NAICS code.

Establishments exempt from electronic submission

Construction establishments with fewer than 20 peak employees during the previous year are generally exempt from electronic ITA reporting. However, if the company has more than 10 employees, they must still maintain paper or digital recordkeeping logs, post Form 300A annually, and report severe injuries directly to OSHA.

Which OSHA forms must covered establishments submit?

ITA reporting involves the following official forms:

• Form 300 tracks specific details of every recordable work-related injury and illness throughout a calendar year. Only construction establishments with 100 or more employees in Appendix B (NAICS 2381) must submit this.
• Form 301 outlines specific information about each recordable injury or illness, including employee information and the incident timeline. Construction establishments with 100 or more employees in Appendix B (NAICS 2381) must submit this; however, five pieces of personally identifiable information (PII) must be left out: the employee name on Form 300, and the employee name, employee address, name of the physician or other health care professional, and the name and address of any off-site treatment facility on Form 301.
• Form 300A displays year-end totals for injuries, illnesses, missed days, and hours worked. All construction establishments with 20 or more employees must submit this, even if zero injuries occurred.

Broader OSHA requirements

ITA OSHA reporting is just one responsibility within OSHA’s broader recordkeeping framework. Contractors are also required to:

• Maintain OSHA Forms 300, 300A, and 301 for at least five years
• Post Form 300A physically on each jobsite yearly from February 1 to April 30
• Report workplace deaths directly to OSHA within eight hours
• Report severe injuries like an in-patient hospitalization (formal admission for care or treatment, not an ER visit or an admission for observation or testing only), amputations, or loss of an eye directly to OSHA within 24 hours

How to comply with OSHA ITA requirements in 6 steps

There are strict penalties for OSHA violations, so contractors must comply with both jobsite safety and recordkeeping regulations to avoid costly fines. Below is a six-step guide to maintaining ITA compliance.

1. Identify each establishment

OSHA rule 1904.30 requires a separate 300 log for each jobsite expected to be in operation for one year or longer. Only jobsites that will exist for less than a year can go on one combined log, grouped by company, division, or geographic region.

2. Confirm the applicable NAICS code

Verify the exact six-digit NAICS code for each establishment against OSHA’s Appendix A and Appendix B industry lists. If the establishment falls under NAICS 2381, contractors must expand reporting on sites with 100 or more workers to include Forms 300 and 301.

3. Calculate peak employment head count

Count all workers employed at the establishment at any point during the calendar year, per OSHA regulation 1904.41(b)(2). Include full-time, part-time, seasonal, temporary, and directly supervised staffing-agency workers. Use peak employee count to determine filing tier.

4. Review the records for accuracy and privacy

Scrub all PII before submitting Form 300 or 301 data. Omit employee names, addresses, and healthcare provider details, as required by 1904.41(b)(9).

5. Access the ITA portal and submit the data

Log into the online ITA portal using secure Login.gov credentials. Upload records via direct web entry, CSV batch upload, or API integration.

6. Retain the records

Retain physical or digital copies of Forms 300, 300A, and 301 for at least five years, as required under 1904.33(a).

When is OSHA ITA due?

Covered establishments must electronically submit required forms annually by March 2 for the prior calendar year.

Common OSHA ITA compliance mistakes

OSHA recordkeeping is a notoriously complex compliance system, so even highly experienced contractors can make mistakes. Common ITA errors include:

• Treating the entire company as one establishment: Combining jobsites into a single entity without evaluating OSHA’s establishment criteria can lead to incorrect reporting processes.
• Misclassifying NAICS codes: Using generic classification codes instead of specific subsector codes can lead to submitting incomplete or incorrect forms.
• Failing to file when there aren’t injuries: Neglecting to follow zero-injury filing instructions for Form 300A is noncompliant.
• Including PII: Submitting worker names, addresses, or medical facility details on Forms 300 and 301 violates OSHA data privacy standards.
• Losing access to the establishment’s ITA account: Misplacing login credentials can lead to missed deadlines and poor handoff procedures during transitions.

Maintain accurate safety records with Miter

While the electronic submission deadline occurs once a year on March 2, ITA compliance requires year-round incident tracking at the establishment level. Gathering jobsite data at the last minute can lead to missing records, inaccurate head counts, or privacy violations.

Miter Safety simplifies this year-long process. Field crews can log incidents, near misses, and jobsite observations directly through the Miter mobile app. Miter connects safety report data directly with workforce data to support annual recordkeeping processes:

• Automated OSHA logging: Miter compiles field entries to generate compliant OSHA Forms 300, 300A, and 301 organized by establishment. 
• Audit-ready data: Total hours worked and peak employee counts connect to time card data, ensuring accurate Form 300A calculations. 
• Simplified ITA submissions: Miter formats annual metrics as clean, compliant CSVs or summary files ready for the ITA portal.

Frequently asked questions

Is OSHA ITA reporting the same as posting Form 300A?

No. Posting Form 300A requires physically displaying the summary in a visible location on the jobsite from February 1 to April 30. ITA reporting requires electronic record submission through OSHA’s online web portal by March 2. 

Does a construction company submit one ITA report for the entire business?

No. Construction companies must submit an ITA report for each qualifying establishment. Employers with multiple long-term jobsites or regional offices must evaluate and report for each location individually.

Is OSHA ITA data available to the public?

Yes. OSHA publishes compiled establishment injury data online. However, they withhold identifying or sensitive information like worker names and addresses to protect privacy.

Does submitting data through the ITA replace OSHA severe-incident reporting?

No. Contractors must report severe incidents directly to OSHA within eight hours for fatalities and within 24 hours for in-patient hospitalizations, amputations, or loss of an eye.

Do states with State Plans use the federal ITA? 

Yes. Employers in OSHA-approved State Plan states must use the federal ITA web portal to submit their electronic recordkeeping data under 1904.41(b)(7).