This is the most common way a covered employer misses the deadline
The logic feels right — nothing happened, so there is nothing to report — and it is wrong. The obligation attaches to the establishment meeting the size and industry criteria, not to whether anything was recorded. A year with zero cases is reported as a year with zero cases.
What you submit in a zero year
The 300A summary with zeroes in the case-count fields, and the establishment information, hours worked and average employee count as normal. The hours and headcount matter: they are what the rate calculations are built from.
Safety Sherpa is software, not a safety consultancy. This page quotes the cited regulation and links to the source text so you can read it yourself. It is not legal advice and does not replace a qualified person's judgment about a genuinely unclear case — our tools walk you through the decisions the regulations require and record your reasoning. The determination is yours to make.
Safety Sherpa