OSHA Recordkeeping

OSHA recordkeeping is the set of requirements under which covered employers document work-related injuries and illnesses on standardized forms, certify and post an annual summary, retain the records, and in some cases submit data electronically.

The requirements are found in Part 1904 of Title 29 of the Code of Federal Regulations. They are administered by the Occupational Safety and Health Administration within the U.S. Department of Labor. Recordkeeping is a distinct obligation from the separate duty to report severe incidents to OSHA immediately, and the two are frequently confused.

The three forms

Each form has a different audience and a different rule about who may see it.

What makes a case recordable

A case is recordable when it is work-related, is a new case, and meets at least one general recording criterion.

• Death.
• Days away from work beyond the day of the incident.
• Restricted work activity or transfer to another job.
• Medical treatment beyond first aid. The regulation defines first aid as a specific closed list, so the distinction is a regulatory test rather than a clinical judgment.
• Loss of consciousness.
• A significant injury or illness diagnosed by a physician or other licensed health care professional, even without any of the above.
• Certain specific conditions have their own recording rules, including needlestick and sharps injuries, medical removal, hearing loss meeting a defined shift threshold, and tuberculosis exposure.
• Work-relatedness is presumed when an event or exposure in the work environment caused or contributed to the condition, or significantly aggravated a preexisting condition. The regulation lists narrow exceptions, and days counting continues even after the employee leaves employment.

The annual cycle and the posting window

The log runs through the calendar year. After it closes, the employer reviews the log for completeness and accuracy, totals the cases onto the Form 300A, and has a company executive certify that the summary is correct. The regulation defines who counts as a company executive narrowly: an owner, an officer of the corporation, the highest ranking official at the establishment, or that person's immediate supervisor. Certification by a safety coordinator or an HR manager who does not meet the definition is a common defect.

The certified summary is posted from February 1 through April 30 of the following year, in each establishment, in a conspicuous place where notices to employees are customarily posted. It must be posted even if there were no recordable cases during the year, with zeros entered. Posting it in a binder in an office nobody enters does not satisfy the requirement.

Records are retained for five years following the end of the calendar year they cover, and the Form 300 log must be updated during that retention period if the employer learns of a new recordable case or of a change to a recorded one, such as additional days away.

Separately, certain establishments submit injury and illness data electronically to OSHA through its Injury Tracking Application, with a submission deadline of March 2 for the prior calendar year. The rule designates which establishments must submit by size band and by industry: establishments at larger employee counts in industries that are not partially exempt, and establishments in a designated set of higher-hazard industries at lower counts. A 2024 amendment expanded submission for certain larger establishments in designated high-hazard industries to include case-level data from Forms 300 and 301, not only the summary. Because the covered industry lists and thresholds have been amended more than once, confirm the current rule for each establishment rather than relying on last year's determination.

Partial exemptions, and what they do not exempt

Two partial exemptions exist, and both are narrower than they are usually described.

• Size: an employer with ten or fewer employees at all times during the previous calendar year is partially exempt. The count is across the entire company, not per establishment, and the "at all times" test means a single peak above ten during the year ends the exemption.
• Industry: establishments in certain low-hazard industries, listed by classification code in an appendix to the regulation, are partially exempt. The determination is made per establishment, so a company can have some exempt establishments and some covered ones.
• Neither exemption removes the duty to report a work-related fatality, in-patient hospitalization, amputation, or loss of an eye to OSHA. That duty applies to all employers covered by the Occupational Safety and Health Act.
• Neither exemption removes the obligation to respond if the Bureau of Labor Statistics or OSHA sends a survey and asks for injury data. A partially exempt employer that receives such a request must keep and provide the records.
• Partial exemption is not a safety exemption. Every covered employer remains subject to the general duty clause and to applicable standards regardless of recordkeeping status.
• Exempt status is evaluated each year. An employer that grows past the size threshold begins recordkeeping in the following calendar year.

Reporting a severe incident

This is a separate, faster obligation than recordkeeping, and the clocks are short.

1. 1Determine whether the event is work-related and falls into a reportable category: a fatality, an in-patient hospitalization, an amputation, or the loss of an eye.
2. 2Report a work-related fatality within eight hours of learning of it.
3. 3Report a work-related in-patient hospitalization, amputation, or loss of an eye within twenty-four hours of learning of it.
4. 4Make the report by calling the nearest OSHA area office during business hours, calling the OSHA twenty-four hour hotline, or using the online reporting form.
5. 5Provide the required information: establishment name, location and time of the incident, type of event, number of employees affected, contact name and phone number, and a brief description.
6. 6Preserve the scene and any equipment involved to the extent it is safe and practical, and begin an internal investigation.
7. 7Record the case on the Form 300 and Form 301 as well, if the employer is subject to recordkeeping. Reporting and recording are separate duties and doing one does not satisfy the other.

Why it matters operationally

Recordkeeping is one of the most frequently examined areas in an inspection because it is easy to verify. An inspector can ask for the log and the certified summary and compare them against first aid records, workers compensation claims, and time records within an hour. Gaps between those sources are the usual finding, and they are documentary rather than arguable.

The data also has a second life. Injury rates derived from the log are used in contractor prequalification, insurance underwriting, and customer safety reviews, and the electronically submitted data becomes publicly available. An employer with sloppy case determination will find its own numbers used against it in a bidding process. The practical safeguard is a single owner for case determination, a written first aid versus medical treatment reference at the point of intake, and a log reviewed monthly rather than reconstructed in January.