Which businesses must file OSHA 300A? High-hazard work, in plain English

For OSHA 300A electronic filing, "high-hazard industry" usually means an establishment with 20-249 employees in one of OSHA's listed industry classifications for annual Form 300A submission. Establishments with 250 or more employees generally file Form 300A if they are required to keep OSHA records and are not in a partially exempt industry.

The practical test is establishment-by-establishment:

1. Count peak employment at that establishment during the covered year.
2. Identify what that establishment actually does, not just the parent company's broad business.
3. Check whether that industry classification is on OSHA's electronic-submission list.
4. Check whether the establishment has a separate 100-employee case-detail obligation for Forms 300 and 301.

OSHA's ITA Coverage Application is the best official final check because it combines state, size, government-employer status, and industry classification.

The 20-249 employee high-hazard rule

OSHA lists the industry classifications whose 20-249 employee establishments must submit Form 300A electronically. The list includes several broad sectors and many specific industry groups.

Large broad sectors on the list include:

• 11 Agriculture, forestry, fishing, and hunting
• 22 Utilities
• 23 Construction
• 31-33 Manufacturing
• 42 Wholesale trade

That means many mid-size farms, contractors, manufacturers, utilities, and wholesalers should not assume they are exempt just because they are below 250 employees. If the establishment had 20-249 employees and sits in one of those covered sectors, run the 300A ITA filing check before closing the file.

Retail and local-service industries that surprise people

Some covered industries are not what many owners think of as "industrial." OSHA's 20-249 list includes several retail and local-service business types, including:

• Automotive parts, accessories, and tire stores
• Furniture and home furnishings stores
• Building material and garden supply dealers
• Grocery and specialty food stores
• Department and other general merchandise stores
• Used merchandise stores
• Vending machine operators and direct selling establishments
• Services to buildings and dwellings
• Dry-cleaning and laundry services

The lesson: do not rely on a broad label like "retail" or "service business." Use the establishment's actual business activity and match it to OSHA's official list.

Transportation, logistics, and warehousing

Transportation and logistics are heavily represented on OSHA's list. Covered codes include general freight trucking, specialized freight trucking, multiple passenger transportation categories, support activities for air, rail, water, and road transportation, couriers, local delivery, postal service, and warehousing and storage.

For multi-site logistics companies, the establishment boundary matters. A warehouse, terminal, maintenance shop, or regional office may have a different industry classification and different peak employment than the corporate entity. Treat each site as its own filing question.

Healthcare, residential care, and social assistance

Healthcare is another common source of confusion. OSHA's list includes general medical and surgical hospitals, psychiatric and substance abuse hospitals, specialty hospitals, nursing care facilities, residential mental health and substance abuse facilities, community care facilities for the elderly, other residential care facilities, community food and housing services, and vocational rehabilitation services.

Healthcare employers should also separate the ITA filing question from general recordkeeping and state-plan questions. A facility should check recordkeeping, 300A posting, ITA filing, and case-detail Forms 300/301 separately because size, business activity, and jurisdiction can point to different duties.

Hospitality, entertainment, and repair

OSHA's 20-249 list also reaches industries such as performing arts companies, spectator sports, museums and historical sites, amusement parks and arcades, gambling industries, traveler accommodation, RV parks and recreational camps, rooming and boarding houses, special food services, and commercial and industrial machinery repair.

These are easy to miss because they do not always feel like "high-hazard" work from a compliance-office view. OSHA's list is code-based, so the code controls.

What changes at 100 and 250 employees

There are two important size thresholds:

• 20-249 employees: file Form 300A if the establishment is in OSHA's Appendix A electronic-submission industry list.
• 250 or more employees: file Form 300A if the establishment is required to keep OSHA injury and illness records and is not in a partially exempt industry.

There is also a separate 100-employee rule for certain designated industries. Those establishments submit Form 300A plus case-detail information from Forms 300 and 301. That is a different list, so do not assume the 20-249 high-hazard list answers the 100-employee case-detail question.

Common mistakes

• Using company-wide headcount. The electronic filing rule is applied to the establishment, not automatically to the whole company.
• Using the wrong industry classification level. Some rules use broad sectors; others use specific industry groups. Match the level OSHA lists.
• Assuming State Plan rules are identical. Most private-sector State Plan requirements align with federal OSHA for ITA, but OSHA notes that some State Plans add their own requirements.
• Confusing posting with electronic filing. The 300A posting requirement is separate from ITA submission.
• Skipping the filing because there were zero cases. If the establishment is covered, submit the zero-case 300A.

How to check your establishment

Start with the official OSHA coverage tool, then keep a copy of the inputs you used: state, government status, peak employment, business activity, and filing year. That record is useful if a manager, customer, or auditor later asks why the establishment did or did not file.

The filing checker walks through the same kind of size, business activity, and state-plan questions in plain language. If the result shows a filing path, you can continue with RegFile instead of rebuilding the ITA submission by hand.

Start the filing checker ->

This is informational, not legal advice - verify against your adopted rule.