OSHA Recordkeeping: The Basics
The Occupational Safety and Health Administration (OSHA) requires covered employers to record and report work-related injuries and illnesses under 29 CFR Part 1904. These records serve two purposes: they give OSHA the data it needs to identify high-hazard industries and enforcement priorities, and they give employers the information they need to identify and eliminate workplace hazards.
The recordkeeping system has three core forms:
The running log where each recordable case is entered within seven calendar days of learning about it. One log per establishment, maintained throughout the calendar year.
The annual summary completed at year-end, posted February 1–April 30, and retained for five years. Must be signed by a company executive.
The detailed first report for each individual recordable case. Contains extensive information about the worker, the incident circumstances, and the medical outcome.
For the digital tools that automate this process, see HSETrack's incident reporting software — which automatically populates your OSHA 300 log from digital incident reports.
Who Must Keep OSHA Records?
Not every employer is required to maintain OSHA injury and illness records. The applicability rules are based on employer size and industry:
Covered: Employers with more than 10 employees
Employers with more than 10 employees at any time during the prior calendar year, in most industries, must maintain OSHA Form 300 logs, 300A summaries, and 301 incident reports for each recordable case. The 10-employee threshold is counted across all establishments of the employer — not per individual work location.
Partially Exempt: Small employers (10 or fewer employees)
Employers with 10 or fewer employees at all times during the previous calendar year are exempt from routine OSHA recordkeeping. However, they are still required to report fatalities within 8 hours and in-patient hospitalizations, amputations, and eye loss within 24 hours. They may also be required to participate in OSHA's annual survey if selected.
Industry-exempt: Certain low-hazard sectors
Employers in specific low-hazard industries listed in Appendix A to Subpart B of 29 CFR 1904 are exempt from routine recordkeeping regardless of size. These industries include many retail, financial services, insurance, real estate, and professional services sectors. Note: these exemptions apply to routine recordkeeping only — fatality and severe injury reporting is still required for all employers.
Universal Obligation: Severe Injury Reporting
All employers — regardless of size or industry — must report to OSHA:
- 8 hrs:Any work-related fatality
- 24 hrs:Any in-patient hospitalization, amputation, or loss of an eye
Reports can be made online at OSHA's website, by phone to the nearest OSHA Area Office, or via OSHA's 24-hour hotline: 1-800-321-OSHA.
What Makes an Injury or Illness OSHA Recordable?
A case must meet three threshold criteria before you apply the recordability test:
Recordability Criteria
| Criterion | Detail |
|---|---|
| Days away from work | Any case requiring one or more days away from work after the day of injury or onset of illness |
| Restricted work or job transfer | Any case where the worker is assigned to restricted duties or transferred to another job |
| Medical treatment beyond first aid | Treatment requiring prescription medication, sutures, X-rays (diagnostic use), splinting beyond first aid, physical therapy, etc. |
| Loss of consciousness | Any loss of consciousness, regardless of duration or whether medical treatment was provided |
| Significant diagnosed condition | A significant injury or illness diagnosed by a healthcare professional, even if it does not result in days away or restricted work |
| Needlestick / sharps injuries | All work-related needlestick injuries and cuts from sharp objects contaminated with another person's blood or OPIM (29 CFR 1904.8) |
| Medical removal under OSHA standard | Any case involving medical removal under an OSHA health standard (e.g., lead, cadmium, methylene chloride) |
| Occupational hearing loss | A Standard Threshold Shift (STS) in hearing in one or both ears, plus a total hearing level of 25 dB HL or more (29 CFR 1904.10) |
| Work-related tuberculosis | Positive TB test following occupational exposure to a known TB case (29 CFR 1904.11) |
What Is First Aid? (Not Recordable)
First aid treatment alone does not make a case OSHA recordable. OSHA defines first aid as:
The Three OSHA Recordkeeping Forms
OSHA Form 300: Log of Work-Related Injuries and Illnesses
Form 300 is the running log where you record each work-related injury or illness that is recordable under 29 CFR 1904. You must enter each case within seven calendar days of learning about it. The form captures:
- Case number, employee name, job title, and date of injury
- Location where the event occurred
- Description of the injury/illness and the object/substance involved
- Classification checkboxes: death, days away, restricted/transferred, other recordable
- Number of days away from work and days on restricted/transfer duty
- Injury type: injury, skin disorder, respiratory condition, poisoning, hearing loss, all other illnesses
Privacy cases: For cases involving sensitive injuries (e.g., sexual assault, mental illness, HIV/AIDS, needlestick with identified source), enter "privacy case" in the employee name column and maintain a separate confidential list of the case numbers and names.
OSHA Form 300A: Annual Summary
Form 300A is completed at the end of each calendar year and summarises the totals from your 300 log. It must be posted even if there were zero recordable injuries or illnesses during the year.
When to Complete
After January 1 for the prior year. Review the 300 log, verify accuracy, and certify the totals on the 300A.
Posting Requirement
Post from February 1 through April 30 in a conspicuous location where employees can see it. Must remain posted for the full three months.
Signature Requirement
Must be certified by a company executive: owner, corporate officer, or highest-ranking company official at the establishment. Electronic signatures are accepted.
Retention
Retain for five years following the end of the calendar year they cover. Records must be accessible to employees, former employees, and employee representatives upon request.
OSHA Form 301: Injury and Illness Incident Report
Form 301 is the detailed first report completed for each individual recordable case. It must be completed within seven calendar days of learning about the injury or illness. Form 301 captures significantly more detail than the 300 log:
Worker Information
- Full name, address, date of birth, date hired
- Gender, job title, department
- Time of work assignment and shift
Incident Information
- Date and time of injury
- Location where event occurred
- What the employee was doing when injured
- How the injury occurred (narrative)
- Object or substance that directly harmed the employee
Medical Information
- Name and address of treating physician/facility
- Was the employee treated in an emergency room?
- Was the employee hospitalised overnight?
Physician / Case Completion
- Date of death (if applicable)
- Days away from work
- Days on job transfer or restriction
Employers may use an equivalent workers' compensation first report of injury form in place of Form 301, provided it captures all required data fields.
OSHA Recordkeeping Penalties
OSHA recordkeeping violations are actively enforced. The agency has increased its penalty structure multiple times in recent years, and recordkeeping violations are frequently identified during programmed and unprogrammed inspections.
| Violation Type | Penalty Range (2026) | Examples |
|---|---|---|
| Other-Than-Serious | Up to $16,550 per violation | Minor recordkeeping errors; late 300A posting |
| Serious | $1,000–$16,550 per violation | Failure to maintain Form 300; incomplete 301 forms |
| Willful | $11,162–$156,259 per violation | Intentional failure to record injuries; record manipulation to suppress TRIR |
| Repeated | $11,162–$156,259 per violation | Same violation cited in a prior inspection within 5 years |
| Failure to report fatality | Up to $16,550 per violation | Not reporting a fatality within 8 hours; not reporting amputation within 24 hours |
Note on Injury Rate Manipulation
OSHA has significantly increased enforcement of deliberate recordkeeping suppression — where employers discourage reporting, retaliate against reporters, or classify recordable cases as first-aid to keep TRIR low. These practices are treated as wilful violations and can result in the maximum penalty schedule, plus additional citations under OSHA's anti-retaliation provisions (Section 11(c)).
Automate Your OSHA Recordkeeping with HSETrack
HSETrack automatically generates your OSHA 300 log from digital incident reports, calculates TRIR and LTIFR in real time, and reminds you when the 300A must be posted. No more manual spreadsheets or missed deadlines.
Frequently Asked Questions
Who is required to keep OSHA records?
Employers with more than 10 employees in most industries must maintain OSHA injury and illness records under 29 CFR 1904. Employers with 10 or fewer employees are exempt from routine recordkeeping, as are employers in certain low-hazard industries. However, all employers must report fatalities within 8 hours and hospitalizations, amputations, and eye loss within 24 hours.
What is an OSHA recordable injury?
A case is OSHA recordable if it is work-related, is a new case, and meets one or more criteria: results in days away from work, restricted work or job transfer, requires medical treatment beyond first aid, involves loss of consciousness, involves a significant diagnosed condition, or meets specific criteria for needlestick injuries, hearing loss, or tuberculosis. First aid treatment alone does not make a case recordable.
What is the difference between OSHA Forms 300, 300A, and 301?
Form 300 is the running log of all recordable cases. Form 300A is the annual summary posted February 1–April 30. Form 301 is the detailed incident report for each individual recordable case. All three must be retained for five years.
When must the OSHA 300A be posted?
The Form 300A must be posted in a conspicuous workplace location from February 1 through April 30 each year, covering the prior calendar year's cases. It must be certified by a company executive.
What are the penalties for failing to maintain OSHA records?
OSHA can issue citations ranging from up to $16,550 for Other-Than-Serious violations to up to $156,259 per violation for Willful or Repeated violations. Deliberate suppression of injury reporting is treated as a willful violation and carries the highest penalties.
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