If you're reading this in August, the 2 March OSHA ITA submission deadline feels a long way off. It isn't. Every year, the same pattern plays out: teams treat the recordkeeping calendar as a January problem, discover in late February that "the log is done" and "the log is ready to submit" are two different claims, and spend the first week of March fixing things that should have been caught in November. OSHA ITA submission — filing your Form 300A data, and for some establishments 300 and 301 data, through the Injury Tracking Application — isn't hard. It's just unforgiving of last-minute surprises. This post walks through the annual calendar, where teams actually get caught out, and what changes when a company decides the scramble isn't happening again.
Why does the same deadline catch teams out every year?
The recordkeeping calendar doesn't move. The OSHA 300 Log runs all year. It closes at year end. The OSHA 300A annual summary gets built from the log's totals and certified by a company executive. It's posted from 1 February through 30 April. And the electronic data — the 300A, plus 300 and 301 detail for larger or higher-hazard establishments under current thresholds — is generally due into OSHA's Injury Tracking Application by 2 March. None of that is new information. So why does it still catch people out?
Because the deadline that trips teams up isn't really the ITA submission date. It's the gap between "the log looks finished" and "the log is actually correct." A log can have every row filled in and still be wrong — a case classified as other-recordable that should have been days-away, a hearing loss case missing its standard threshold shift check, a contractor injury nobody resolved for work-relatedness. Those errors sit quietly until someone tries to certify the 300A and finds the totals don't add up, or until the file gets rejected on upload because a field doesn't match what the ITA expects. Three weeks feels like plenty of runway in January. It evaporates once you're validating case by case.
What actually happens between "log closed" and "ITA submitted"?
Closing the log is an internal decision — you've entered everything you know about for the year. Getting to a submittable 300A means several more steps, each with its own way to go wrong:
- Final review of every case. Anything logged provisionally — a "needs review" flag, a pending medical determination, an open restricted-duty case — has to be resolved one way or the other before the totals are final.
- Building the 300A totals. Deaths, days-away cases, restricted/transfer cases, other recordable cases, days counts, and — critically — total hours worked and average employment for the year. Get hours worked wrong and both your TRIR and DART rates are wrong on a certified federal filing. Our TRIR calculation guide and DART rate explainer cover exactly how those figures are built.
- Executive certification. A company executive has to review and sign the 300A — not just initial it. That person needs the finished numbers in front of them with enough lead time to actually read them, not a rushed signature on 1 March.
- Posting 1 February–30 April. The signed 300A goes up somewhere employees normally see workplace notices, for the full window, not just a few days of it. See our guide to 300A posting requirements for what "posted" actually means in practice.
- ITA submission by 2 March. The data — not a scanned copy of the poster — goes into OSHA's Injury Tracking Application in the format it expects. That's a separate technical step from posting, and it's the one most likely to surface a problem you didn't know you had.
The annual recordkeeping compliance calendar
| Milestone | Timing |
|---|---|
| OSHA 300 Log finalised | By year end (31 December), reviewed and closed before totals are pulled |
| OSHA 300A completed and certified | Early in the new year, from the log's finalised totals, signed by a company executive |
| OSHA 300A posted | 1 February – 30 April |
| OSHA ITA electronic submission | Generally by 2 March |
| Posting removed | After 30 April |
The recordkeeping calendar repeats every year under 29 CFR Part 1904 — the dates don't shift, but the amount of runway a team actually has does, depending on how early the log is genuinely finished.
If you haven't worked through how the 300A itself gets built, our 300A summary guide walks the whole process from log totals to certified form. And for the mechanics of the ITA upload specifically — file formats, thresholds for who has to submit what — our ITA electronic submission guide is the deeper reference.
A near-miss: how one mid-size employer almost missed the deadline
The following is an illustrative scenario built from patterns we see repeatedly across mid-size employers — not a real company, but a composite of the mistakes that show up every recordkeeping season.
Picture a manufacturing site with around 180 employees and one EHS coordinator responsible for recordkeeping alongside a dozen other duties. The 300 Log looked complete by mid-January — every incident from the year had a row. The coordinator treated that as the finish line and moved on to other priorities.
In the last week of February, pulling the 300A totals together, she found three problems at once. Two cases logged as "other recordable" back in June should have been days-away cases — the employees had taken time off that never got reflected in the log because the update happened over email, not in the record. A third case, a repetitive-strain injury reported by a contractor, had never been resolved for work-relatedness at all; it had just sat there unflagged since September. Fixing the totals meant re-checking hours worked too, since the days-away correction changed which pay period counted. The executive due to certify the form was travelling and available for exactly one 20-minute window before 2 March. The filing went in with hours to spare, but only because everyone dropped what they were doing that week.
Afterwards, the team changed two things. First, incident updates stopped happening over email — every change went straight into the log record so nothing depended on someone remembering to transcribe it later. Second, they moved the "final review" step from late February to early January, giving themselves six weeks of slack instead of six days. As one EHS manager we spoke with put it: "The deadline was never actually the problem. The problem was finding out in the last week that the log wasn't what we thought it was."
Where teams get this wrong
A few mistakes show up again and again, across companies of very different sizes:
- Treating "log finalised" and "ITA submitted" as the same task. They're not. Finalising the log is an internal judgement call. Submission means the data has to be correct, complete, and formatted the way OSHA's system expects — and that last part only gets tested when you actually try it.
- Never test-driving the export format ahead of time. Waiting until the last week of February to open the ITA upload tool for the first time is how minor formatting issues turn into a fire drill. Try the file well before the deadline, when there's still time to fix it calmly.
- One person as the single point of failure. If the coordinator who knows the log inside out is on leave, travelling, or leaves the company in February, and nobody else understands the record, the deadline becomes a scramble by default.
- Leaving borderline cases unresolved until the last minute. A case flagged "needs review" in July shouldn't still be unresolved in February. Every open question on the log is a number that can still change your totals.
- Certifying without giving the executive real time to look. A rushed signature the day before the deadline isn't meaningful review — and if the numbers are wrong, that signature is now attached to a federal filing.
OSHA's recordkeeping and posting requirements have stayed among its more frequently cited standards in recent years — not because the rules are obscure, but because paperwork discipline slips under deadline pressure in a way that's entirely avoidable with earlier prep.
What does "needs review" mean on a recordability call?
Some cases genuinely aren't obvious. Was an injury work-related if it happened in a break room? Does a case belong on the log if the employee was already scheduled for time off? The rule leaves room for judgement in places — work-relatedness under 1904.5 has real exceptions, and privacy-concern cases have their own handling under 1904.29. A tool — or a person — that forces a yes/no answer on every case regardless of the facts isn't being helpful, it's guessing. The better approach flags genuinely ambiguous cases as "needs review" so a human makes the final call, rather than quietly picking an answer that might not hold up. That's the standard we hold Job13's free recordability check to: it applies the three-part test in 29 CFR Part 1904 — work-relatedness, new case, recording criteria — and tells you plainly when a case needs a person to decide.
How far in advance should you start preparing for the ITA deadline?
Six to eight weeks before 2 March is realistic for most mid-size employers — enough time to close out lingering cases, pull and sanity-check hours worked, get the export tested, and give an executive real time to review before signing. Waiting until February compresses all of that into a few weeks alongside everything else on an EHS team's plate.
This is the exact gap Job13 is built to close. Every determination you run through the year lands in a saved OSHA 300 Log, so there's no separate reconstruction step in January. When year end comes, the 300A summary builds from that log automatically, and the export is formatted for OSHA's Injury Tracking Application from the start — not adapted to it under deadline pressure. See how it fits your team on our pricing page.
Frequently asked questions
What is the OSHA ITA submission deadline?
Electronic submission of Form 300A data — and 300 and 301 detail for establishments that meet current size or industry thresholds — is generally due into OSHA's Injury Tracking Application by 2 March each year, covering the prior calendar year's recordkeeping data.
Is the OSHA ITA deadline the same as the 300A posting deadline?
No. The 300A must be posted from 1 February through 30 April, a much longer window than the ITA submission deadline. Electronic submission through the Injury Tracking Application is a separate step with its own 2 March target, and it can be completed before, during, or shortly after the posting period begins — it just can't slip past 2 March.
What happens if a company misses the OSHA recordkeeping deadline?
Missing the electronic submission deadline or the posting window can expose an employer to citations under 29 CFR Part 1904's recordkeeping and reporting provisions. This article is general information, not legal advice — if you've missed a deadline or are unsure of your obligations, consult a qualified professional.
Do all employers have to submit electronically through the ITA?
No. Submission requirements depend on establishment size and industry classification under current OSHA thresholds. Check OSHA's official injury reporting guidance or osha.gov/recordkeeping to confirm which forms your establishment needs to submit.
Where can I read the actual regulation behind these deadlines?
The requirements sit in 29 CFR Part 1904, also available in full at eCFR. Job13 mirrors the regulation verbatim, section by section, at /rule/1904 if you want to check a specific requirement directly against the source text.
