OSHA February 1 Deadline 2026: Complete Compliance Guide for Fleet Owners
If you run a delivery fleet, trucking company, or logistics operation with 10+ employees, you have less than three weeks to meet OSHA's February 1 annual reporting deadline.
Missing this deadline can result in penalties ranging from hundreds to thousands of dollars per violation, and it puts you at risk during OSHA inspections. This guide explains exactly what you need to submit, how to prepare it, and what to do if your records aren't ready.
What's Due on February 1?
The February 1 deadline requires employers in certain industries to:
1. Post Form 300A (Annual Summary) at your workplace from February 1 to April 30
2. Submit Form 300A electronically* to OSHA via the Injury Tracking Application (ITA) by *March 2 if you have 250+ employees OR are in a high-hazard industry with 20-249 employees
Important:* February 1 is the posting deadline. Electronic submission (if required) is due *March 2.
Who must comply:
- Establishments with 20-249 employees in designated high-hazard industries (including transportation and warehousing - NAICS codes 48-49)
- Establishments with 250+ employees in ALL industries
- Employers with 10 or fewer employees are generally exempt
Understanding Form 300A: The Annual Summary
Form 300A is a one-page summary of all work-related injuries and illnesses that occurred at your establishment during the previous calendar year (2025).
Key data required:
- Total number of OSHA recordable cases
- Number of cases involving days away from work
- Number of cases with job transfer or restriction
- Total days away from work
- Total days of job transfer or restriction
- Number of deaths
- Injury and illness types (injury, skin disorder, respiratory condition, poisoning, hearing loss, all other illnesses)
Calculation requirements:
- Total hours worked by all employees during 2025
- Annual average number of employees
- Total Case Incident Rate (TCIR) and Days Away, Restricted, or Transferred (DART) rate
Who Signs Form 300A?
Form 300A requires a signature from a company executive, which can be:
- Owner of the company
- Highest-ranking company official working at the establishment
- Immediate supervisor of the highest-ranking official
This signature certifies that you examined the OSHA 300 Log and believe the annual summary is correct and complete. Administrative staff cannot sign Form 300A.
Step-by-Step: Preparing Form 300A
Step 1: Gather Your 2025 Injury Records
You need documentation for every work-related injury or illness from January 1 - December 31, 2025. This includes:
- Workers compensation claims
- First report of injury forms
- Medical treatment records
- Supervisor incident reports
- Email reports from drivers or field employees
- Text messages reporting injuries
Realistic challenge for fleet owners: Your records are scattered across insurance claims, email threads, text messages from drivers, and handwritten notes. This is normal, but you need to consolidate them.
Step 2: Determine OSHA Recordability
Not every injury is OSHA recordable. An injury must meet ALL three criteria:
1. Work-related - Occurred in the work environment during work activities
2. New case - First time recording this injury (or significant re-injury)
3. Meets severity criteria - Results in death, days away from work, restricted work, medical treatment beyond first aid, loss of consciousness, or significant injury diagnosed by healthcare provider
Common recordable cases for fleet operations:
- Driver slips on ice in customer parking lot during delivery (fracture, sprain requiring medical treatment)
- Forklift operator injures back lifting package (requires physical therapy)
- Mechanic cuts hand on equipment (requires stitches)
- Warehouse worker struck by falling merchandise (concussion, days away from work)
Common NON-recordable cases:
- Minor cuts treated with bandages only
- Bruises treated with ice pack
- Soreness treated with over-the-counter pain relievers
- Pre-existing conditions that don't worsen at work
Step 3: Count Cases and Calculate Rates
Once you've identified all recordable cases, categorize them:
Count these separately:
- Total cases
- Cases with days away from work (employee couldn't work their normal job)
- Cases with job transfer or restriction (employee worked but couldn't perform normal duties)
- Total days away (sum of all calendar days employees were off work)
- Total days of restriction/transfer (sum of all calendar days employees worked restricted duty)
Calculate required rates:
Total Case Incident Rate (TCIR):
```
TCIR = (Total recordable cases × 200,000) / Total hours worked by all employees
```
Days Away, Restricted, or Transferred (DART) Rate:
```
DART = (Cases with days away/restricted/transferred × 200,000) / Total hours worked
```
The 200,000 represents 100 full-time employees working 40 hours per week for 50 weeks.
Example calculation for a small fleet:
- 120 employees
- 240,000 total hours worked (120 employees × 2,000 hours/year)
- 5 recordable cases (2 with days away, 3 with restriction)
```
TCIR = (5 × 200,000) / 240,000 = 4.17
DART = (5 × 200,000) / 240,000 = 4.17
```
Step 4: Fill Out Form 300A
Form 300A requires:
Establishment information:
- Legal company name
- Establishment name (if different from company name)
- Street address, city, state, ZIP
- Industry description
- Standard Industrial Classification (SIC) or North American Industry Classification System (NAICS) code
- Employment information (annual average number of employees, total hours worked)
Injury and illness data:
- Number of cases (various categories from Step 3)
- Number of days (away from work, job transfer/restriction)
- Injury and illness types
Signature section:
- Name and title of company executive
- Phone number
- Date signed
Step 5: Post Form 300A at Your Workplace
Posting requirements:
- Must be posted from February 1 through April 30
- Must be posted in a common area where notices to employees are typically placed
- Must be posted in each establishment (if you have multiple locations, each needs its own Form 300A)
Good posting locations:
- Break rooms
- Near time clocks
- Main office entrance
- Dispatch areas where drivers check in
Step 6: Submit Electronically (if required)
If you're required to submit electronically (250+ employees, OR 20-249 employees in a high-hazard industry), use OSHA's Injury Tracking Application (ITA):
Submission process:
1. Go to https://www.osha.gov/injuryreporting/ita/
2. Create an account or log in
3. Enter your establishment information
4. Upload Form 300A data (you can type it in or upload a CSV file)
5. Submit by March 2
Important: The ITA system can be slow in late January as employers rush to meet the deadline. Submit early if possible.
What If Your Records Aren't Ready?
If you're reading this in late January and your records are a mess, here's what to do:
Option 1: Prioritize and Estimate (Not Ideal, But Better Than Nothing)
If you're days away from the deadline:
1. Pull your workers compensation claims from your insurance provider
2. Review your incident log or emails for any reported injuries
3. Make your best estimate of recordable cases
4. Post Form 300A and submit to OSHA
5. Add a note that you'll review and amend if needed
Why this works: OSHA prefers timely submission over perfection. You can amend later if you discover errors.
Option 2: Use Automation to Process Scattered Records Quickly
If you have scattered records (emails, texts, comp claims, spreadsheets), you can:
1. Gather all documents in one place
2. Use automation to extract incident data from unstructured records
3. Generate Form 300A with calculated rates
4. Review, sign, and submit
This is the approach our tool takes - it accepts messy input and generates compliant OSHA forms.
Option 3: Request Help from Your Workers Comp Provider
Many workers compensation insurance providers offer OSHA recordkeeping services. Contact them immediately and ask if they can:
- Provide a list of all 2025 claims
- Help determine which claims are OSHA recordable
- Assist with Form 300A preparation
Some providers offer this as a free service, others charge a fee.
Common Mistakes to Avoid
Mistake 1: Confusing Recordability with Reportability
Recordable means you must log it on Form 300 and include it in your Form 300A annual summary.
Reportable means you must report it to OSHA within 8-24 hours (deaths, hospitalizations, amputations, loss of an eye).
Most injuries are neither recordable nor reportable (first aid only). Some are recordable but not reportable (sprain requiring physical therapy). Few are both recordable AND reportable (amputation).
Mistake 2: Counting First Aid Cases as Recordable
First aid is NOT recordable, even if an employee visits a doctor. First aid includes:
- Bandages and wound dressings
- Hot/cold therapy (ice packs, heating pads)
- Non-prescription medications at non-prescription strength
- Drinking fluids for heat stress
- Eye wash or flushing
- Removing splinters or foreign material without incision
- Finger guards, elastic bandages
- Massages
- Vaccines (tetanus, hepatitis B, flu)
If the treatment goes beyond first aid (prescription medication, stitches, physical therapy, etc.), it's likely recordable.
Mistake 3: Excluding Parking Lot Injuries
Many fleet owners assume parking lot injuries aren't work-related. This is WRONG.
Parking lot injuries ARE work-related if:
- The employee was arriving at or leaving work
- The injury occurred in the employer's parking lot or access road
- The employee was performing work duties (unloading, checking vehicle, etc.)
Example: A driver slips on ice in your parking lot while walking to their van at the start of their shift. This is work-related and likely recordable if it requires medical treatment beyond first aid.
Mistake 4: Using Old Years' Forms
OSHA updates forms periodically. Ensure you're using the current version:
- Form 300 (Log of Work-Related Injuries and Illnesses)
- Form 300A (Summary of Work-Related Injuries and Illnesses)
- Form 301 (Injury and Illness Incident Report)
Download current forms from https://www.osha.gov/recordkeeping/forms
Mistake 5: Not Keeping Records for 5 Years
You must retain:
- Form 300 (Log) for 5 years
- Form 301 (Incident Report) for 5 years
- Form 300A (Annual Summary) for 5 years
Even though you only post Form 300A from February-April each year, you must keep all three forms for 5 years following the end of the year to which they relate.
Penalties for Missing the Deadline
OSHA can issue citations for recordkeeping violations:
Failure to post Form 300A:
- Up to $16,550 per violation (effective January 15, 2025)
- Multiplied by the number of days not posted (February 1 - April 30 = 89 days)
- Potential penalty: $1.4 million+ for willful violations
Failure to submit electronically (by March 2):
- Up to $16,550 per violation
- Each day late can be a separate violation
Inaccurate or incomplete recordkeeping:
- Up to $16,550 per violation
- OSHA takes recordkeeping seriously - intentional falsification can result in criminal penalties
Realistic enforcement: OSHA typically targets employers with histories of violations or those in high-hazard industries. Small employers meeting the deadline in good faith are less likely to face maximum penalties.
After February 1: Maintaining Your OSHA Log
Once you've submitted Form 300A, you're not done. You must:
1. Continue maintaining Form 300 (Log) throughout 2026 for new injuries
2. Keep Form 300A posted until April 30, 2026
3. Retain all 2025 records (Forms 300, 300A, 301) for 5 years
4. Update your log within 7 days of learning about a new recordable case
Best practice: Set a recurring task to review injury reports monthly. This prevents last-minute scrambling before next year's February 1 deadline.
Quick Checklist: Are You Ready for February 1?
- [ ] Gathered all 2025 injury/illness records (comp claims, emails, incident reports)
- [ ] Determined which injuries are OSHA recordable
- [ ] Counted total cases, days away, restricted duty cases
- [ ] Calculated total hours worked by all employees in 2025
- [ ] Calculated TCIR and DART rates
- [ ] Filled out Form 300A with accurate data
- [ ] Had a company executive sign and date Form 300A
- [ ] Posted Form 300A in a visible common area (or will post by Feb 1)
- [ ] Submitted electronically via ITA (if required for your business)
- [ ] Set a calendar reminder to keep Form 300A posted through April 30
Need Help Fast?
If you're scrambling to meet the deadline and your records are scattered across workers comp claims, emails, and text messages, you're not alone. Most small fleet owners face this exact challenge.
Our tool accepts messy input (PDFs, email threads, text messages, spreadsheets) and generates OSHA-compliant Form 300A with calculated rates in minutes.
Join the waitlist at smallbizautomations.com to get early access.
Key Takeaways
- February 1, 2026 is the deadline to post Form 300A at your workplace
- March 2, 2026 is the deadline to submit Form 300A electronically (if required)
- Form 300A must stay posted through April 30, 2026
- Only recordable cases are included (work-related + new case + severity criteria)
- Company executive must sign Form 300A - administrative staff cannot sign
- Keep records for 5 years - don't throw away old logs
- Penalties are steep - up to $16,550 per violation
The February 1 deadline is firm, but preparing accurate records doesn't have to be painful. Start now, gather your scattered documents, and get your Form 300A ready to post.