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FEATURED NEWS
2026-01-02T06:00:00Z
NewsIndustry NewsElectronic Reporting of Injury and Illness RecordsSafety & HealthConstruction SafetyGeneral Industry SafetyIn-Depth ArticleInjury and Illness RecordkeepingEnglishFocus AreaUSA
Choosing a NAICS code for OSHA 300 e-filing
Employers that must electronically file their injury data with OSHA might engage in business activities that fall under more than one North American Industry Classification System (NAICS) code. Fortunately, OSHA recognized that more than one NAICS code could apply to a single establishment.
OSHA’s Injury Tracking Application (ITA) website includes a frequently asked question regarding multiple NAICS codes. OSHA advises, “Choose the code that represents the activity that generates the most revenue for your establishment and/or has the most employees, whichever is more applicable to your business.” If more than one NAICS code could apply, employers can choose which code to use for ITA reporting.
Choosing a NAICS code
OSHA does not assign NAICS codes. Employers know their operations best and must select the most applicable code. For example, suppose a company engages in both plastics manufacturing and chemical manufacturing. The plastics division has the most employees, but the chemical division generates the most revenue. Which NAICS code should the company use? The company could use either, but might consider the electronic filing obligations.
Plastics manufacturers must file the 300A, 300 Log, and 301 Forms if the establishment has 100 or more employees. However, chemical manufacturers file only the 300A regardless of employee count. This company might choose the NAICS code for chemical manufacturing since that generates the most revenue and would only have to file the 300A.
One location, two establishments?
Normally, a single physical location counts as one “establishment” for injury recordkeeping. In rare cases, a single location with more than one business operation might be divided into more than one establishment. If this happens, each establishment (operation) would maintain a separate 300 Log and could even have different electronic reporting obligations.
The previous example of a chemical and plastics manufacturer probably doesn’t qualify as two separate establishments. OSHA offers an example where two separate business establishments operate from the same physical address. The agency noted, “if an employer operates a construction company at the same location as a lumber yard, the employer may consider each business to be a separate establishment.”
According to the regulation at 1904.46, an employer might consider two or more separate businesses that share a single location to be separate establishments only when:
- Each of the establishments represents a distinctly separate business;
- Each business is engaged in a different economic activity;
- No single NAICS code applies to the joint activities; and
- Separate reports are routinely prepared for each establishment on the number of employees, their wages and salaries, sales or receipts, and other business information.
If these criteria do not apply, the employer must choose one NAICS code for the entire operation.
Employer Identification Number (EIN)
When preparing for electronic submission of injury records, employers also need to include their Employer Identification Number, or EIN. This is a tax identification number for a company, similar to a Social Security Number, but for a business.
Some locations might have more than one EIN. That does not automatically mean the location constitutes two or more “establishments” for OSHA recordkeeping and reporting. However, if each operation meets the criteria for separate businesses, the employer might maintain separate 300 Logs (and potentially have different e-reporting obligations) for each business operation.
Key to remember: If more than one NAICS could apply, the employer chooses which code to use for electronic filing of injury data. Though unusual, a single location might be divided into separate business operations and treated as two establishments.
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RECENT INDUSTRY HIGHLIGHTS
2026-01-02T06:00:00Z
NewsChange NoticesChange NoticeIowaCAA ComplianceEnvironmentalAir PermittingFocus AreaEnglishAir ProgramsAir Programs
Iowa adds fees for Title V, asbestos air programs
Effective date: January 14, 2026
This applies to: Entities required to obtain a Title V operating permit and owners or operators of sites subject to asbestos notifications
Description of change: The Iowa Environmental Protection Commission added a new annual base fee for Title V operating permit holders, due by July 1.
Additionally, the commission added a fee for revising asbestos notifications. It applies to sites required by the National Emission Standards for Hazardous Air Pollutants to submit asbestos demolition or renovation notifications.
Related state info: Clean air operating permits state comparison
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2026-01-02T06:00:00Z
NewsMinnesotaChange NoticesChange NoticeWater ProgramsWater ReportingCAA ComplianceEnvironmentalFocus AreaWater ProgramsEnglishAir ProgramsAir ProgramsCWA Compliance
Minnesota establishes PFAS reporting, fees rule
Effective date: December 8, 2025
This applies to: Manufacturers of products with intentionally added PFAS
Description of change: The Minnesota Pollution Control Agency added rules that require manufacturers that sell, offer for sale, or distribute products in the state that contain intentionally added per- and polyfluoroalkyl substances (PFAS) to:
- Submit annual reports, and
- Pay a fee.
The initial report is due by July 1, 2026. Thereafter, annual reports will be due by February 1. Reports will be submitted electronically through the PFAS Reporting and Information System for Manufacturers (PRISM).
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2026-01-02T06:00:00Z
NewsUnderground Storage TanksChange NoticesChange NoticeCaliforniaEnvironmentalStorage TanksFocus AreaEnglishTank Systems
California updates UST regulations
Effective date: January 1, 2026
This applies to: UST owners and operators
Description of change: The California State Water Resources Control Board updated the underground storage tank (UST) construction, monitoring, and testing requirements. Significant changes include:
- Replacing the classification of new and existing USTs with a three-category classification system based on the installation date;
- Requiring testing notifications to be sent to Unified Program Agencies (UPAs);
- Requiring USTs installed on or after January 1, 2027, to be anchored;
- Requiring UPA approval before repairing UST systems;
- Reducing the timeline to submit enhanced leak detection test results to 30 days; and
- Changing closure requirements.
Related state info: Underground storage tanks (USTs) — California
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2026-01-02T06:00:00Z
NewsAir QualityMarylandChange NoticesChange NoticeCAA ComplianceEnvironmentalFocus AreaEnglishAir ProgramsAir Programs
Maryland establishes fuel provider reporting program
Effective date: December 22, 2025
This applies to: Heating fuel providers delivering heating fuel in Maryland
Description of change: The Maryland Department of the Environment established the Maryland Heating Fuel Provider Reporting Program. It requires heating fuel providers to submit an annual report by April 1 that covers the monthly amount of fuel delivered in the state, organized by fuel type, sector, and county.
Heating fuel providers should begin gathering data in January 2026. The initial report for calendar year 2026 will be due by April 1, 2027. The department plans to publish the annual reporting template in Spring 2026.
Related state info: Clean air operating permit state comparison
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2026-01-02T06:00:00Z
NewsDistrict of ColumbiaChange NoticesChange NoticeWater ProgramsWater QualityEnvironmentalWater ProgramsEnglishFocus AreaCWA Compliance
District of Columbia adds nonwoven disposable product regulations
Effective date: November 14, 2025
This applies to: Manufacturers of nonwoven disposable products sold in D.C.
Description of change: The Washington, D.C. Department of Energy and Environment (DOEE) added regulations (21 DCMR Chapter 24) for nonwoven disposable products labeling to implement the Nonwoven Disposable Products Act of 2016.
The chapter sets the standards for determining whether a nonwoven disposable product may be labeled as flushable, including testing and labeling requirements for flushable and nonflushable products. It applies to all nonwoven products that may potentially be used in a bathroom and flushed (e.g., baby wipes, disinfecting wipes, makeup removal wipes, general purpose cleaning wipes, etc.).
Compliance requirements start in May 2027.
Related state info: Industrial water permitting — District of Columbia
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