The Occupational Safety and Health Administration (OSHA) has initiated a new enforcement program to identify employers who failed to submit Form 300A data through the agency’s Injury Tracking Application (ITA). OSHA created the injury and illness reporting program in 2016 and it publishes the reported data on its webpage at

A Government Accountability Office (GAO) report released last year found thatmore than halfof covered employers fail to report injury and illness data as required by the regulation. OSHA’s enforcement program seeks to find companies that have not reported and cite them. In addition, the enforcement initiative is also designed to incentive companies that have not reported to submit their reports.

Under current OSHA regulations in 29 CFR 1904.41, the following establishments must submit an annual summary of workplace injuries and illnesses (OSHA Form 300A):

  • Establishments with 250 or more employees that are required to keep OSHA injury and illness records (i.e., are not partially exempt per 29 CFR 1904.2); and
  • Establishments with 20—249 employees in certain high-risk industries. The current list of high-risk industries includes printing operations.

Each week, under the enforcement program OSHA matches newly opened inspections against a list of potential non-responders to OSHA’s collection of Calendar Year 2021 Form 300A data through the ITA and reports all matches to the appropriate OSHA area office. If the area office determines that the establishment on the list is the same establishment where the inspection was opened, OSHA will issue citations for failure to submit OSHA Form 300A Summary data.

This new approach takes the burden to identify allegedly non-compliant employers off OSHA inspectors, and arms them with information to issue citations for a failure to report. In addition to identifying non-responders at the establishment level, the agency is also reviewing the 2021 submitted data to identify non-responders at a corporate-wide level so companies with more than one location may receive a larger penalty.

The reporting deadline for calendar year 2021 was March 2, 2022, so the six-month date to issue a citation for non-compliance with the requirements ends on September 2, 2022.