The two thresholds are separate
The 300A summary and the case-level 300/301 data are governed by different rules, and it is common to owe one and not the other. Most specialty trade contractors between 25 and 100 employees fall into the 20-to-249 band, which means the 300A summary is owed if the trade appears in Appendix A. Construction trades generally do. The 100-employee Appendix B threshold for case-level data catches fewer companies at this size, but it catches them abruptly the year headcount crosses it.
Count by establishment, not by company
The thresholds apply to the establishment — the individual physical location — rather than to the company as a whole. A company with three yards of 40 people each is three establishments of 40, not one of 120.
If you are not sure which industry list you are in
The industry lists are by NAICS code, and the code that matters is the one describing what that establishment actually does. OSHA publishes both appendices as part of Subpart E.
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