No Products in the Cart
We have been busy creating new products - Take a look here New Products
OSHA recordkeeping of work-related injuries and illnesses can seem complicated. But the basic purpose is straightforward: employers use accurate records to understand workplace hazards, identify trends, and take action to prevent future injuries and illnesses. The important thing is knowing whether your organization is required to keep OSHA records, which forms to use, what information belongs on each form, and when information must be reported to OSHA.
OSHA's recordkeeping requirements are primarily found in 29 CFR Part 1904, and the rules distinguish between recording an injury or illness, reporting a severe incident directly to OSHA, and electronically submitting annual recordkeeping data through OSHA's Injury Tracking Application, or ITA. Listen also Mighty Line Minute's S1 E3 podcast on OSHA Recordkeeping Requirements!
Who Must Keep OSHA Injury and Illness Records?
Not every employer is required to routinely maintain OSHA injury and illness records. Generally, employers that had 10 or fewer employees during all of the previous calendar year are partially exempt from routine OSHA recordkeeping. Certain establishments in designated low-hazard industries are also partially exempt, regardless of size. These exemptions are found in 29 CFR 1904.1 and 1904.2, including the industries listed in Appendix A to Subpart B. OSHA or the Bureau of Labor Statistics can nevertheless require a partially exempt employer to keep records by notifying the employer in writing.
The 10-employee exemption should not be confused with OSHA's electronic-reporting thresholds. Having 20 or more employees does not automatically mean an employer must submit injury and illness information electronically to OSHA. Electronic submission is determined at the establishment level and depends on both employee count and, for certain categories, the establishment's industry.
The Three Primary OSHA Recordkeeping Forms
Employers that are required to keep OSHA injury and illness records generally use three forms: OSHA Form 300, OSHA Form 300A, and OSHA Form 301. OSHA permits equivalent forms or electronic systems when they contain the required information and meet the applicable requirements.
OSHA Form 300 — Log of Work-Related Injuries and Illnesses
The Form 300 is the ongoing log of recordable work-related injuries and illnesses. Employers enter a description of each recordable case and classify the case according to OSHA's requirements, such as cases involving days away from work, restricted work or job transfer, or other recordability criteria. A recordable case generally must be entered on the Form 300 within seven calendar days after the employer receives information that a recordable injury or illness has occurred.
OSHA Form 301 — Injury and Illness Incident Report
Form 301 provides additional information about each recordable injury or illness entered on the Form 300. It captures details about the incident, the affected employee, the injury or illness, and how the event occurred. Employers must complete a Form 301—or an equivalent form—for each recordable case.
OSHA Form 300A — Summary of Work-Related Injuries and Illnesses
At the end of each calendar year, employers summarize the information from the Form 300 on Form 300A. The annual summary must be certified by a company executive and posted in a conspicuous location where employee notices are normally posted. The posting period is February 1 through April 30 of the year following the year covered by the form. Importantly, employers must complete, certify, and post the Form 300A even when there were no recordable cases during the year.
The Form 300 and Form 301 are maintained throughout the year, while the Form 300A summarizes the previous year's recordkeeping information. Employers generally must retain the Form 300 Log, privacy case list when applicable, Form 300A, and Form 301 records for five years following the end of the calendar year covered by the records. OSHA also requires certain updates to the Form 300 during that five-year retention period when new information or changes to previously recorded cases become known.
Who Must Submit Records Electronically to OSHA?
Electronic submission is a separate requirement from maintaining the OSHA forms. OSHA states that only three categories of establishments routinely must submit injury and illness recordkeeping information electronically.
First, establishments with 20 to 249 employees at any time during the previous calendar year must electronically submit Form 300A information if their industry is listed in Appendix A to Subpart E of 29 CFR Part 1904. Appendix A identifies the covered industries by NAICS code. Construction, manufacturing, utilities, wholesale trade, and numerous other industries are included in the designated list.
Second, establishments with 250 or more employees at any time during the previous calendar year must electronically submit Form 300A information if they are required to keep OSHA injury and illness records. This is an establishment-level determination, so the employee count for electronic reporting is not simply the total number of employees across an entire organization.
Third, establishments with 100 or more employees in industries listed in Appendix B to Subpart E must electronically submit more detailed information from their Forms 300 and 301, in addition to the Form 300A information required under the applicable electronic-reporting rules. OSHA expanded this requirement in its 2023 final rule, which applies to designated high-risk industries identified in Appendix B.
For covered establishments, the annual electronic submission is generally due March 2 of the following year. For example, required data for calendar year 2025 was due by March 2, 2026. Establishments that do not fall into one of the three routine electronic-reporting categories generally submit information only if OSHA specifically notifies them that they must participate in an individual data collection.
Recording an Injury Is Not the Same as Reporting It to OSHA
One of the most important distinctions in OSHA recordkeeping is that recording a case on the OSHA forms does not necessarily mean the incident must immediately be reported to OSHA. Most recordable injuries and illnesses are documented through the employer's OSHA recordkeeping system. Certain serious incidents, however, must be reported directly to OSHA regardless of whether the employer is normally required to maintain OSHA injury and illness records.
Under 29 CFR 1904.39, all employers must report a work-related fatality within eight hours. A work-related inpatient hospitalization, amputation, or loss of an eye must be reported within 24 hours. Reports can be made through OSHA's reporting system, by telephone, or to the nearest OSHA office. These severe-incident reporting requirements apply even to employers that are otherwise exempt from routine OSHA recordkeeping.
Employers should also remember that OSHA requirements may not be the only reporting obligations that apply. State OSHA plans can have requirements that differ from Federal OSHA, and workers' compensation laws may impose separate notification or documentation requirements. Employers should therefore evaluate the requirements that apply to their specific location and industry.
Why Accurate OSHA Records Matter
OSHA recordkeeping is more than a compliance exercise. Properly maintained records can reveal patterns that might otherwise go unnoticed—such as repeated injuries involving the same machine, task, location, or type of hazard. Reviewing the Form 300 and other safety information can help employers identify where additional training, engineering controls, housekeeping, floor marking, personal protective equipment, or other corrective measures may be needed.
The goal is simple: record injuries accurately, report serious incidents when required, submit electronic information when required, and use the information to make the workplace safer.
For facilities looking to improve safety communication and workplace organization, Mighty Line products can also help. Durable floor marking tape and adhesive floor signs can help identify work areas, communicate hazards, organize traffic and storage areas, and improve visual safety throughout a facility. Learn more at MightyLineTape.com.
A few important updates from the podcast are reflected here: Form 301 must be completed for each recordable case within seven calendar days, the 300A must be certified and posted even when there are zero recordable cases, and the 20-employee electronic-reporting threshold is explicitly tied to Appendix A and the individual establishment. Those points are directly supported by OSHA's current regulations and guidance.
Have a safe day!
