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📋 OSHA Recordkeeping

OSHA requires most employers to keep records of work-related injuries and illnesses. This guide covers what you need to track, how to track it, and common mistakes to avoid.

Key Principle

Record accurately and promptly. Falsifying records or failing to record injuries is a serious OSHA violation.

Who Must Keep Records​

Covered Employers​

You must keep OSHA records if you have more than 10 employees at any time during the previous year.

Exemptions​

Partially exempt industries (some low-hazard industries) don't need to keep records unless asked by OSHA or BLS.

Construction is NOT exempt - all construction employers with 11+ employees must keep records.

When Exemption Doesn't Apply​

Even exempt employers must:

  • Report fatalities within 8 hours
  • Report amputations, loss of eye, inpatient hospitalizations within 24 hours
  • Keep records if requested by OSHA/BLS

OSHA Forms Overview​

OSHA Form 300 - Log​

Purpose: Record each recordable injury/illness When: Within 7 days of learning of recordable case Keep: 5 years following the year it covers

OSHA Form 300A - Summary​

Purpose: Annual summary of injuries/illnesses When: Post February 1 - April 30 Certify: Company executive must sign Display: Where employees can see it

OSHA Form 301 - Incident Report​

Purpose: Detailed information about each case When: Within 7 days of learning of recordable case Keep: 5 years

Note: Workers' comp first report of injury can substitute if it has the same information.

What's Recordable?​

General Recording Criteria​

A work-related injury or illness is recordable if it results in:

  • Death
  • Days away from work
  • Restricted work or job transfer
  • Medical treatment beyond first aid
  • Loss of consciousness
  • Significant injury/illness diagnosed by medical professional

An injury is work-related if an event or exposure in the work environment:

  • Caused the injury
  • Contributed to the injury
  • Significantly aggravated a pre-existing condition

First Aid vs. Medical Treatment​

First Aid (NOT recordable):

  • Bandages, butterfly closures, Steri-Strips
  • Wound cleaning
  • Hot or cold therapy
  • Non-prescription medications at nonprescription strength
  • Tetanus shots
  • Eye patches
  • Finger guards
  • Massages
  • Drinking fluids

Medical Treatment (recordable):

  • Sutures (stitches)
  • Prescription medications
  • Physical therapy
  • Wound care requiring medical professional
  • X-rays for diagnostic purposes
  • Removal of foreign bodies by physician

How to Complete Form 300​

Case Information​

Column A - Case Number

  • Unique number for each case
  • Sequential through the year
  • Example: 2024-001, 2024-002

Column B - Employee Name

  • Full name
  • Privacy cases: Note "Privacy Case" and keep separate log

Column C - Job Title

  • Employee's regular job title
  • Not the task being performed

Column D - Date of Injury

  • When injury occurred
  • When illness was diagnosed

Column E - Location

  • Where the injury occurred
  • Be specific enough to identify

Column F - Description

  • Brief description of injury and how it occurred
  • What the employee was doing
  • What happened
  • What part of body affected

Classification​

Column G - Death

  • Mark if employee died

Column H - Days Away from Work

  • Mark if employee missed work
  • Enter number of days in Column K

Column I - Restricted Work/Transfer

  • Mark if restricted duty or transferred
  • Enter number of days in Column L

Column J - Other Recordable

  • All other recordable cases
  • Medical treatment beyond first aid
  • Loss of consciousness

Days Counted​

Column K - Days Away

  • Calendar days (not work days)
  • Don't count day of injury
  • Cap at 180 days

Column L - Restricted/Transfer Days

  • Calendar days on restricted duty
  • Don't count day of injury
  • Cap at 180 days

Injury/Illness Type​

Column M - Check one:

  1. Injury
  2. Skin disorder
  3. Respiratory condition
  4. Poisoning
  5. Hearing loss
  6. All other illnesses

Completing Form 300A (Annual Summary)​

When to Complete​

  • Summarize previous year by February 1
  • Post from February 1 through April 30
  • Keep posted in visible location

What to Include​

  1. Total cases from each column (G-M)
  2. Total days away and restricted
  3. Average employees during year
  4. Total hours worked during year
  5. Establishment information
  6. Executive signature (certifying accuracy)

Calculation Tips​

Average employees:

  • Add up total employees each pay period
  • Divide by number of pay periods

Total hours worked:

  • Include all employees
  • Include overtime as actual hours
  • Don't include vacation, sick, holiday

Privacy Cases​

When to Use Privacy Protection​

  • Intimate body parts or reproductive system
  • Sexual assault
  • Mental illness
  • HIV, hepatitis, TB
  • Needlestick injuries
  • Other illnesses where employee requests privacy

How to Handle​

  • Enter "Privacy Case" in Column B
  • Keep separate confidential list linking case numbers to names
  • Don't include name on posted 300A

Common Mistakes​

Recording Errors​

Mistake: Not recording cases because no lost time Correct: Medical treatment beyond first aid is recordable

Mistake: Recording all injuries Correct: Only work-related injuries requiring more than first aid

Mistake: Waiting until year end to complete Correct: Record within 7 days of learning of case

Calculation Errors​

Mistake: Counting work days for days away/restricted Correct: Count calendar days

Mistake: Starting count on day of injury Correct: Start the next day

Mistake: Counting days after employee quits Correct: Stop counting when employment ends (use actual or estimate)

Administrative Errors​

Mistake: Summary not signed Correct: Company executive must certify

Mistake: Posted in break room only managers use Correct: Post where all employees can see

Mistake: Discarding records too early Correct: Keep for 5 years

Reporting Requirements​

Report Within 8 Hours​

Fatalities (work-related deaths)

  • Report even if death occurs days after injury
  • Call OSHA or report online

Report Within 24 Hours​

  • Inpatient hospitalization (admitted, not just ER visit)
  • Amputation (loss of body part)
  • Loss of an eye

How to Report​

What to Report​

  • Establishment name
  • Location of incident
  • Time of incident
  • Type of incident
  • Number of employees affected
  • Names of employees affected
  • Contact person and phone number

Multi-Site Employers​

Separate Establishments​

Keep separate 300 logs for each location that is:

  • A fixed worksite
  • Has employees working there regularly
  • Reasonably distinct from other operations

Construction Complications​

If you have:

  • Home office + multiple job sites
  • Keep separate logs if job lasts over 1 year
  • Short-term sites can roll up to office log