Q1 2026 is a high-risk window for recordkeeping compliance, and many organizations underestimate how quickly deadlines arrive. OSHA requires most covered employers to post the prior year’s OSHA Form 300A from February 1 through April 30 and to ensure the summary is visible to employees even if no injuries occurred, a fundamental step that is often missed during winter turnarounds and project ramp-ups (Occupational Safety and Health Administration, 2003). For electronic reporting, OSHA’s Injury Tracking Application sets March 2, 2026, as the submission deadline for required establishments; since OSHA’s 2023 final rule, many employers with 100 or more employees in designated high-hazard industries must also transmit case-specific data from Forms 300 and 301 in addition to the 300A summary, which expands the data preparation burden early in the year (OSHA, n.d.-a; OSHA, 2023). Multi-state employers should also confirm state-plan alignment: for example, Cal/OSHA reiterates the same posting period and maintains the March 2 electronic submission date for covered employers, which can affect corporate calendars and internal cutoffs (California Division of Occupational Safety and Health, 2025); (Cal/OSHA, 2021).

Beyond OSHA, federal data calls can overlap Q1 workloads. The Bureau of Labor Statistics’ Survey of Occupational Injuries and Illnesses typically contacts selected establishments in January with instructions to return the survey within 30 days, making it essential to have complete 2025 records, signed 300A summaries, and a designated respondent ready when the packet arrives (U.S. Bureau of Labor Statistics, 2025); (BLS, 2025). Sector-specific rules also matter. Rail operators, for example, continue reporting accidents and incidents to FRA on Form 6180.54 and should note FRA’s special study blocks in effect through December 31, 2026, which may change data elements they must capture in real time even as Q1 deadlines approach (Federal Railroad Administration, 2025a); (FRA, 2025b).

This matters across construction, transportation, general industry, and environmental services because late or incomplete reporting can trigger citations, invite audits, and delay prequalification with owners who increasingly require verified safety metrics at bid time. Tying Q1 to the four safety pillars helps teams execute: safety and health training clarifies who signs the 300A and who uploads to ITA; hazard prevention and control ensures logs capture medical criteria correctly; worksite analysis reconciles cases to payroll hours; management commitment and employee involvement establishes a calendar with internal audits and visible postings. At Key Safety LLC, our Document Development for Start-up Projects builds year-end to Q1 checklists, sign-off matrices, and ITA data maps; Service on Demand provides rapid reviews of 2025 logs and 300A attestations before posting and upload; Regular Consultation Service monitors federal and state updates, validates eligibility under OSHA’s expanded electronic rule, and prepares teams for BLS or sector data calls.

References

California Division of Occupational Safety and Health. (2025, January 29). Cal/OSHA reminder to employers: Post 2024 annual summary of work-related injuries and illnesses by February 1. https://www.dir.ca.gov/DIRNews/2025/2025-11.html

California Division of Occupational Safety and Health. (n.d.). Electronic submission of workplace injury & illness records.https://www.dir.ca.gov/dosh/calosha-updates/log300-reporting.html

Federal Railroad Administration. (2025a). New instructions for completing Form FRA F6180.54—Rail equipment accident/incident report. https://railroads.dot.gov/safety-data/forms-guides-publications/new-instructions-completing-form-fra-f618054-rail-equipment

Federal Railroad Administration. (2025b). Form FRA F 6180.54—Rail equipment accident/incident.https://railroads.dot.gov/safety-data/forms-guides-publications/forms/618054-rail-equipment-accidentincident

Occupational Safety and Health Administration. (2003, December 18). Posting requirements for the OSHA 300 Log and summary. https://www.osha.gov/laws-regs/standardinterpretations/2003-12-18-0

Occupational Safety and Health Administration. (2023, July 17). Final rule to improve tracking of workplace injuries and illnesses. https://www.osha.gov/injuryreporting/final-rule

Occupational Safety and Health Administration. (n.d.-a). Injury Tracking Application (ITA).https://www.osha.gov/injuryreporting

U.S. Bureau of Labor Statistics. (2025). Survey of Occupational Injuries and Illnesses (SOII) pre-note leaflet [PDF]. U.S. Department of Labor. https://www.bls.gov/respondents/iif/forms/2025_soii_prenote_leaflet.pdf

U.S. Bureau of Labor Statistics. (2025, July 21). Instructions for Survey of Occupational Injuries and Illnesses respondents. https://www.bls.gov/respondents/iif/instructions.htm