OSHA 300A Posting: The February 1 Deadline and Why It Matters for Contractors
Every year, most construction employers have to post OSHA Form 300A — the Summary of Work-Related Injuries and Illnesses — from February 1 through April 30. The form summarizes the previous calendar year's recordable injuries and illnesses for each workplace establishment, and it has to be posted where employees can see it.
For construction, the 300A posting is one of the few regulatory requirements that hits the calendar annually and has a specific, unavoidable deadline. Missed postings, inaccurate forms, or postings in non-visible locations all lead to OSHA citations. And because the 300A summary data also feeds industry safety benchmarks (TRIR, DART rates) that affect prequalification, bonding, and insurance, accuracy matters beyond the compliance filing itself.
The 300A is the annual summary of what's on the OSHA 300 log — the running log of work-related injuries and illnesses maintained throughout the year. Specifically, the 300A reports by establishment:
Fields on the OSHA 300A summary
- Total number of cases with days away from work
- Total number of cases with job transfer or restriction
- Total number of other recordable cases
- Total number of cases involving deaths
- Total days away from work (across all cases)
- Total days of job transfer or restriction
- Type of injury/illness counts — injuries, skin disorders, respiratory conditions, poisonings, hearing loss, all other illnesses
- Establishment information — name, address, industry, size (average employee count), total hours worked
- Company executive certification signature
The establishment-level reporting matters. A contractor with multiple offices or yards files a separate 300A for each establishment. For construction employers without a fixed establishment (where the work is at varying job sites), the home office usually serves as the establishment for recording purposes.
OSHA recordkeeping rules apply to most employers with 11 or more employees at any time during the previous calendar year. The 300A posting requirement follows the same threshold. Employers with fewer than 11 employees throughout the year are partially exempt from routine recordkeeping (though they still have to report severe injuries and fatalities).
Certain low-hazard industries are exempt regardless of size. Construction, however, is not a low-hazard industry — virtually all construction NAICS codes require recordkeeping. Contractors should assume they're required to maintain the 300 log and post the 300A unless they verify exemption under the specific NAICS rules.
An injury or illness is recordable on the OSHA 300 log (and therefore rolls up into the 300A) if it meets one of these criteria:
OSHA recordability criteria
- Death resulting from the event
- Days away from work beyond the day of injury
- Restricted work activity or job transfer
- Medical treatment beyond first aid
- Loss of consciousness
- Diagnosis of a significant injury or illness by a physician or licensed health care professional (e.g., fractures confirmed by X-ray, puncture wounds, cancer, etc.)
First aid — defined specifically by OSHA — is not recordable. Bandages, non-prescription medications, simple eye irrigations, and similar minor treatments fall under first aid. Splinting, stitching, prescription medications, physical therapy, and similar treatments beyond first aid make an injury recordable.
The distinction matters. Aggressive recording (treating first-aid-level incidents as recordables) inflates injury rates and hurts the company's safety metrics. Under-recording (missing actual recordables) creates OSHA citation exposure. Accurate recording per the specific OSHA criteria is the balanced practice.
When a case is on the boundary of recordable vs. first aid, consult the OSHA recordability letters of interpretation — OSHA has published decades of Q&A on specific scenarios. Trying to guess the right call creates risk both ways; looking up the precedent is usually quick.
The posting has specific requirements:
OSHA 300A posting requirements
- Post from February 1 through April 30 of each year (three full months)
- Post where employees can see it — typically a break room, office common area, or job site office
- Must be the actual 300A form, not a summary or alternate format
- Must be signed by a company executive (CEO, president, or equivalent senior corporate officer)
- Must reflect the previous calendar year's recordable cases
- For multiple establishments, each establishment's 300A must be posted at that establishment
- For construction without fixed establishments, the home office posting covers the company (with job site coverage through other safety postings)
The company executive signature line is sometimes skipped in practice — the safety director signs and the executive never actually reviews. The regulation is specific that a company executive must sign, certifying they've examined the document and that the contents are correct. Having someone else sign on the executive's behalf is technically non-compliant.
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Electronic Submission
Beyond the posting, larger employers also have to electronically submit their 300A data to OSHA through the Injury Tracking Application (ITA). The electronic submission requirements as of recent years apply to:
Electronic submission thresholds (as of recent years)
- Establishments with 250+ employees in any industry
- Establishments with 20-249 employees in specific high-hazard industries (construction is included)
- Establishments with 100+ employees in even more high-hazard industries must also submit 300 log data and 301 incident detail forms
The electronic submission deadline is March 2 each year. Contractors that meet the thresholds need to submit by this date in addition to posting the 300A. OSHA publishes the data from electronic submissions in a searchable database, so the data is public.
The 300A data drives several downstream metrics that affect the contractor's business:
Downstream uses of 300A data
- TRIR (Total Recordable Incident Rate) — calculated from 300A counts × 200,000 / hours worked
- DART rate — days away, restricted, or transferred, similarly calculated
- Prequalification submissions — owners and GCs ask for recent years' 300A and EMR as safety indicators
- Insurance rating — workers' comp premiums are partly based on injury experience, and general liability carriers may also consider safety performance
- Bonding capacity — sureties factor safety performance into underwriting decisions
- Bid evaluations — some public agencies factor safety performance into award decisions
Given these uses, the accuracy of the 300A matters beyond the compliance filing. Errors — either over-reporting first aid as recordable, or under-reporting actual recordables — affect business metrics in ways that persist for years.
The 300 log and 300A have a five-year retention requirement. The 300 log from 2026 must be retained through 2031; the 300A for 2026 activity (posted February-April 2027) must be retained through 2032. During the retention period, the records must be available to OSHA inspectors on request.
Contractors should maintain both the annual 300A summary and the underlying 300 logs that support it. OSHA compliance reviews sometimes dig into the log to verify that the summary numbers actually reflect the documented incidents.
OSHA 300A posting is an annual requirement for most construction employers — post from February 1 through April 30, at every establishment, signed by a company executive. Larger employers also submit electronically. The data flows into industry safety metrics that affect prequalification, insurance, and bonding for years after. Getting it right requires accurate day-to-day recording of incidents against OSHA's recordability criteria, careful annual summary preparation, and proper posting and submission compliance on the specific deadlines.
Written by
Jordan Patel
Compliance & Legal
Former corporate counsel specializing in construction contracts and tax compliance. Writes about the documentation layer — COIs, W-8/W-9, certified payroll, notice-to-owner deadlines — and the legal backbone behind audit-ready AP.
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