10.1 Recordkeeping Forms: OSHA 300, 301, & 300A

10.1 Recordkeeping Forms: OSHA 300, 301, & 300A

Regulatory Framework of 29 CFR Part 1904

Under the Occupational Safety and Health (OSH) Act of 1970, employers are legally required to track and record occupational injuries and illnesses to help identify hazards, target resources, and prevent future occurrences. The specific regulations governing these requirements are codified in 29 CFR Part 1904 (Recording and Reporting Occupational Injuries and Illnesses).

Routine recordkeeping is not required for all businesses. OSHA provides two main exemptions from the routine recordkeeping requirement:

1. Size Exemption: Employers with 10 or fewer employees at all times during the last calendar year are exempt from keeping OSHA injury and illness records.
2. Industry Exemption: Employers in certain low-hazard industries (such as retail, finance, insurance, or real estate) are exempt from routine recordkeeping. These exempt industries are listed in Appendix A to Subpart B of Part 1904.

[!IMPORTANT] Even if an employer is exempt from routine recordkeeping due to size or industry, they must still comply with 29 CFR 1904.39 (reporting fatalities, inpatient hospitalizations, amputations, and losses of an eye to OSHA) and must participate in annual surveys if selected by OSHA or the Bureau of Labor Statistics (BLS).

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The Core Recordkeeping Forms

Employers who are required to maintain records must use three specific OSHA forms to log, track, and summarize workplace injuries and illnesses.

1. OSHA Form 300: Log of Work-Related Injuries and Illnesses

The OSHA 300 Log is used to record the details of all recordable injuries and illnesses that occur in the workplace. It is a running log for the calendar year and must be completed for each individual establishment.

• Information Logged: For each case, the employer must record the case number, employee’s name (except for privacy cases), job title, date of injury or onset of illness, specific location where the event occurred, a description of the injury or illness (including parts of the body affected), and how the incident occurred.
• Classification (Columns G through J): The employer must classify each case into one of four mutually exclusive categories based on the most serious outcome:
  • Column G (Death): The case resulted in a work-related fatality.
  • Column H (Days away from work): The employee was unable to work for one or more full calendar days.
  • Column I (Job transfer or restriction): The employee was kept from performing their routine job functions or transferred to another job.
  • Column J (Other recordable cases): The case met the recording criteria but did not result in death, days away, or job restriction.
• Tracking Time (Columns K and L): The employer must record the exact number of calendar days the employee was away from work (Column K) or on job transfer/restriction (Column L).
  • Rules for Counting Days: Begin counting days on the day after the injury or illness occurred. Do not count the day of the injury. Count calendar days, which includes weekends, holidays, vacation days, or other scheduled days off, if the employee would have been restricted or unable to work.
  • Day Capping: Stop counting days when the count reaches 180 calendar days for days away, restricted work, or a combination of both. Employers are not required to track days or cap them beyond the 180-day limit for a single case.
• Categorizing the Case (Column M): The case must be classified as an injury, skin disorder, respiratory condition, poisoning, hearing loss, or all other illnesses.

2. OSHA Form 301: Injury and Illness Incident Report

The OSHA 301 Form is a detailed incident report completed for each individual case recorded on the OSHA 300 Log.

• Timeframe: The employer must complete the OSHA 301 (or an equivalent form, such as a state workers' compensation first report of injury) within 7 calendar days of receiving information that a recordable case has occurred.
• Content: It collects detailed information about the injured employee, the healthcare provider, the treatment received, and a narrative of the incident (what the employee was doing, how it happened, and what tools, equipment, or substances were involved).

3. OSHA Form 300A: Summary of Work-Related Injuries and Illnesses

The OSHA 300A Summary compiles the annual totals of all injuries and illnesses from the Form 300 Log.

• Information Included: The summary shows the total number of cases, the total number of days away from work and days of restriction, the total number of illnesses by category, the establishment’s average annual employee count, and the total hours worked by all employees during the year.
• Executive Certification: A company executive must certify that they have reviewed the OSHA 300 Log and that the annual summary is true, accurate, and complete. A "company executive" is strictly defined as:
  • An owner of the company (if a sole proprietorship or partnership),
  • An officer of the corporation,
  • The highest-ranking company official working at the establishment, or
  • The immediate supervisor of the highest-ranking company official.
• Posting Period: The certified OSHA 300A must be posted in a conspicuous location where employee notices are normally posted. It must remain posted from February 1 to April 30 of the year following the calendar year covered by the records (e.g., the 2025 summary must be posted from February 1, 2026, through April 30, 2026).

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Determining Work-Relatedness (29 CFR 1904.5)

An injury or illness is considered work-related if an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing condition. The "work environment" includes the physical location of work as well as equipment, materials, and company-provided transport.

Work-Relatedness Exceptions

OSHA lists specific situations where an injury occurring in the work environment is not considered work-related:

• The employee is present in the work environment as a member of the general public rather than as an employee.
• The injury or illness involves signs or symptoms that surface at work but result solely from a non-work-related event or exposure.
• The injury or illness results solely from voluntary participation in a wellness program, medical exam, physical fitness activity, or blood donation.
• The injury or illness is solely the result of an employee eating, drinking, or preparing food or drink for personal consumption (e.g., choking on lunch or spilling hot coffee).
• The injury or illness is solely the result of an employee doing personal tasks (unrelated to their employment) at the establishment outside of assigned working hours.
• The injury or illness is solely the result of personal grooming, self-inflicted wounds, self-medication (such as taking non-prescription medication), or a motor vehicle accident in a company parking lot during the employee’s normal commute.

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Recording Criteria and Special Cases (29 CFR 1904.7)

An injury or illness must be recorded on the OSHA 300 Log if it is work-related, represents a new case, and meets one or more of the following general recording criteria:

• Death: Any work-related fatality.
• Days Away from Work: The employee cannot work their normal shift.
• Restricted Work Activity or Job Transfer: The employee cannot perform all of their routine job functions.
• Loss of Consciousness: Always recordable, regardless of the duration of the loss of consciousness or the treatment administered.
• Medical Treatment Beyond First Aid: Any medical care that does not fall under the strict definition of first aid.
• Significant Diagnosis: Any serious or significant injury/illness diagnosed by a physician or licensed health care professional (PLHCP), such as fractures, punctured eardrums, or cancer, even if it does not result in lost time or medical treatment.

First Aid vs. Medical Treatment

OSHA defines "first aid" exhaustively under 29 CFR 1904.7(b)(5)(ii). Any treatment not included in this list is considered "medical treatment" for recordkeeping purposes.

Special Recordkeeping Rules

• Needle-sticks and Sharps: Employers must record all work-related needle-stick injuries and cuts from sharp objects that are contaminated with another person's blood or other potentially infectious material (OPIM).
• Hearing Loss: A work-related hearing loss case must be recorded if the employee experiences a Standard Threshold Shift (STS) of 10 decibels (dB) or more in one or both ears (averaged at 2000, 3000, and 4000 Hz) AND the employee's total hearing level is 25 dB or more above audiometric zero in the same ear(s).
• Medical Removal: If an employee is medically removed under the medical surveillance requirements of an OSHA standard (such as the Lead or Benzene standards), the case must be recorded on the OSHA 300 Log.
• Retention & Access: Logs and forms must be retained for 5 years following the end of the calendar year covered. The employer must update the Form 300 during the retention period to reflect any changes. Upon request, employers must provide copies of the OSHA 300 Log to employees, former employees, or representatives by the end of the next business day.