OSHA Recordkeeping
29 CFR 1904 Compliance
Understanding OSHA injury and illness recordkeeping — the 300 Log, 300A Summary, recording criteria, and electronic submission requirements
Why Recordkeeping Matters
OSHA's recordkeeping requirements 29 CFR 1904 serve as the foundation of the nation's occupational safety and health surveillance system. Injury and illness records help employers identify patterns, measure the effectiveness of their safety programs, and direct resources to the most hazardous operations. They also provide OSHA, researchers, and the Bureau of Labor Statistics (BLS) with data to target inspections and develop new standards. Failure to maintain accurate records — or maintaining them improperly — can result in citations, penalties, and increased scrutiny during inspections.
Who Must Keep Records
Most employers with 11 or more employees at any point during the previous calendar year are required to maintain OSHA injury and illness records 1904.1. Two categories of exemptions exist:
Size Exemption
Employers with 10 or fewer employees at all times during the previous calendar year are exempt from routine recordkeeping 1904.1. However, all employers — regardless of size — must report fatalities, in-patient hospitalizations, amputations, and losses of an eye directly to OSHA.
Industry Exemption
Certain low-hazard industries are partially exempt from routine recordkeeping based on their NAICS code 1904.2. These include many retail, service, finance, and real estate businesses. The exemption does not apply if OSHA or BLS specifically requests records, and the severe-incident reporting obligation always applies.
Important: Even exempt employers must report within 8 hours any work-related fatality, and within 24 hours any work-related in-patient hospitalization, amputation, or loss of an eye 1904.39. This is a reporting obligation, not a recordkeeping obligation — it applies to every employer, period.
The Three OSHA Recordkeeping Forms
OSHA 300 Log — Log of Work-Related Injuries and Illnesses
The 300 Log is the ongoing record of each recordable injury or illness. For each case, the log captures: case number, employee name, job title, date of injury/illness, location and description of what happened, classification (death, days away from work, job transfer/restriction, or other recordable), and the number of days away or on restriction. A separate 300 Log is maintained for each establishment (physical location). The log must be updated within 7 calendar days of receiving information about a recordable case.
OSHA 300A Summary — Summary of Work-Related Injuries and Illnesses
The 300A is an annual summary that totals the year's recordable cases from the 300 Log. It includes total counts by category, total days away from work, total days of restriction, the annual average number of employees, and total hours worked. A company executive (owner, officer, or highest-ranking official at the establishment) must certify the summary by signing it. The 300A must be posted in a conspicuous place where notices are customarily posted from February 1 through April 30 of the following year 1904.32.
OSHA 301 Incident Report — Injury and Illness Incident Report
The 301 form provides detailed information about each individual recordable case. It captures what the employee was doing just before the incident, what happened, the object or substance that directly harmed the employee, and when and where the incident occurred. An equivalent form (such as a workers' compensation first report of injury) may be used if it contains the same information. The 301 must be completed within 7 calendar days of receiving information about the case.
Recording Criteria: What Makes a Case Recordable?
An injury or illness is recordable if it is work-related, it is a new case, and it meets one or more of the following general recording criteria 1904.7:
First Aid vs. Recordable: The Critical Distinction
The distinction between first aid and medical treatment is one of the most misunderstood aspects of OSHA recordkeeping. OSHA defines first aid as a closed list — if the treatment is on this list, it is first aid. If it is not on this list, it is medical treatment and the case is recordable 1904.7(a):
- Using non-prescription medications at nonprescription strength.
- Cleaning, flushing, or soaking wounds on the skin surface.
- Using wound closure devices (butterfly bandages, Steri-Strips) — but not sutures or staples.
- Using bandages, wraps, or elastic bandages during any visit.
- Applying hot or cold therapy.
- Using rigid or non-rigid means of support (splints, slings) — for the first visit only as a diagnostic measure.
- Drilling a fingernail or toenail to relieve pressure, draining fluid from a blister.
- Using eye patches.
- Removing foreign bodies from the eye with irrigation or a cotton swab.
- Removing splinters or foreign material from areas other than the eye with irrigation, tweezers, cotton swabs, or other simple means.
- Using finger guards.
- Using massages.
- Drinking fluids for heat stress relief.
- Using oxygen as a first aid measure.
Key rule of thumb: If a physician writes a prescription (any prescription medication at prescription strength), the case is recordable. If sutures or staples are used, the case is recordable. If the employee is referred to physical therapy, the case is recordable. The number of physician visits alone does not determine recordability — only the treatment provided matters.
Electronic Submission (ITA Rule)
The Improve Tracking of Workplace Injuries and Illnesses (ITA) rule requires certain employers to electronically submit injury and illness data to OSHA through the Injury Tracking Application (ITA) portal at osha.gov/injuryreporting.
OSHA publishes submitted data on its public website, with personally identifiable information removed. This data is used for enforcement targeting, research, and public transparency. Employers must also include their legal company name and Employer Identification Number (EIN) with each submission.
Record Retention and Access
Employers must retain OSHA 300 Logs, 300A Summaries, and 301 Incident Reports for five years following the end of the calendar year they cover 1904.33. During the retention period, the 300 Log must be updated to reflect newly discovered recordable cases and changes in previously recorded cases (such as additional days away from work).
- Current and former employees have the right to access the OSHA 300 Log and 300A Summary for any establishment where they currently work or have worked.
- Employee representatives (authorized union representatives) have the same access rights.
- Access to the OSHA 301 Incident Report is limited to the information about the employee section for that particular employee, or the entire report for authorized employee representatives.
- Records must be provided by the end of the next business day after a request is received.
Anti-Retaliation Protection
OSHA's recordkeeping regulation includes provisions prohibiting employers from retaliating against employees for reporting injuries or illnesses 1904.35(b)(1)(iv). Employers must establish a reasonable procedure for employees to report injuries and must inform employees of that procedure. Any program that has the effect of discouraging employees from reporting — such as incentive programs that reward injury-free periods at the team level — may violate the anti-retaliation provisions.
References
1. OSHA 29 CFR Part 1904 — Recording and Reporting Occupational Injuries and Illnesses.
2. OSHA: Injury and Illness Recordkeeping and Reporting Requirements.
3. OSHA Recordkeeping Handbook (OSHA Publication 3245-01R, 2005).
4. OSHA Final Rule: Improve Tracking of Workplace Injuries and Illnesses (ITA Rule, updated 2024).
Was this article helpful?
Rate this article to help us improve
Discussion (2)
The most common recordkeeping mistake I see is employers recording every workplace injury on the 300 Log when only recordable cases belong there. A minor cut that needs a Band-Aid is first aid, not a recordable. But a laceration that requires stitches or Steri-Strips IS recordable. The distinction matters because your DART and TRIR rates drive your experience modification rate, which drives your insurance premiums. Over-recording inflates your rates; under-recording triggers OSHA citations.
The recording criteria decision tree in 29 CFR 1904.7 is the key reference. If it results in death, days away from work, restricted duty, transfer, medical treatment beyond first aid, loss of consciousness, or a significant diagnosis by a physician — it is recordable. Everything else is first aid. We recommend keeping a first aid log separate from the 300 Log so you can demonstrate to OSHA that you evaluated each case and made a defensible determination.
Do not forget the electronic submission requirement. Establishments with 250+ employees in any covered industry, or 20-249 employees in certain high-hazard industries, must submit 300A data electronically through the OSHA ITA portal by March 2 every year. Missing the deadline is a separate violation. And starting with the 2024 reporting year, larger employers also submit the full 300 Log and 301 forms electronically — not just the summary.