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

  1. Identify whether your state is federal, full State Plan, or public-sector-only.
  2. Apply the size + industry test (250+, or 20–249 in a high-hazard industry).
  3. 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.

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This is informational, not legal advice — verify against your adopted rule and your state plan.

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One dated result card from the filing checker.

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