June 17, 2026 · 2 min read · The RegFile team
State Plan vs. federal OSHA: how 300A filing differs by state
OSHA isn't one uniform rulebook everywhere. About half the states run their own OSHA-approved program, and those can differ from the federal rules in ways that matter for your 300A. Here's the plain version.
Three kinds of jurisdiction
- Federal OSHA states. Private employers follow the federal 29 CFR 1904 rules directly.
- Full State Plan states. The state runs an OSHA-approved program covering private employers. It must be at least as effective as federal OSHA — and sometimes goes further (different thresholds, deadlines, or extra reporting).
- Public-sector-only State Plan states. The state plan covers state and local government workers; private employers stay under federal OSHA.
Why it matters for the 300A
Most State Plans mirror the federal electronic-submission rule closely, but not always:
- A few states adopt the federal rule on a different timeline or with state-specific tweaks.
- Some states have their own reporting portal or additional requirements layered on top.
- California (Cal/OSHA), for example, has historically diverged on parts of the electronic-submission rule.
So "the federal deadline is March 2" is the right starting point everywhere — but in a State Plan state, it's worth confirming your state hasn't adjusted the threshold or the date.
How to figure out your situation
- Identify whether your state is federal, full State Plan, or public-sector-only.
- Apply the size + industry test (250+, or 20–249 in a high-hazard industry).
- Confirm your state hasn't changed the deadline or threshold.
The filing checker starts you down this path by state and summarizes the jurisdiction before you prepare a filing. When a state-specific detail is uncertain, confirm it against your state plan's own guidance.
The shortcut
Tracking per-state nuances is exactly the kind of thing that's easy to get wrong once a year. The filing checker resolves the jurisdiction for your establishment first, then starts covered sites in the 300A draft, review, authorization, and filing workflow.
This is informational, not legal advice — verify against your adopted rule and your state plan.