Recordkeeping violations are among the most common OSHA citations every year. Most of them happen not because employers are hiding injuries, but because they genuinely don't know what counts as recordable, when to record it, and what forms to use. This guide covers all of it.
Who Must Keep OSHA Records?
The basic rule: employers with 11 or more employees in most industries must maintain OSHA injury and illness records. Employers with 10 or fewer employees in any industry are partially exempt from routine recordkeeping requirements — but are still required to report severe injuries and fatalities.
There is also an industry-based exemption. Employers in certain low-hazard industries are exempt from OSHA recordkeeping even if they have more than 10 employees. Exempt industries include most retail trade, finance, insurance, real estate, and service industries with low historical injury rates.
The Three Forms Explained
OSHA Form 300: Log of Work-Related Injuries and Illnesses
The Form 300 is your running log of all recordable work-related injuries and illnesses during the calendar year. Each recordable case gets its own line entry with the following information:
- Employee name and job title
- Date and location of injury or onset of illness
- Description of the injury or illness
- Classification of the case (death, days away from work, restricted work, job transfer, or other recordable)
- Number of calendar days away from work or on restricted duty
The log must be completed within 7 calendar days of receiving information that a recordable case occurred. It must be maintained for 5 years following the end of the calendar year it covers.
OSHA Form 300A: Summary of Work-Related Injuries and Illnesses
The Form 300A is an annual summary derived from your Form 300 log. It totals up all the cases from the year and must be signed by a company executive — specifically, an owner, officer, or the highest-ranking company official working at the establishment — certifying the accuracy of the information.
Posting requirement: The Form 300A must be posted in a visible location at the worksite from February 1 through April 30 each year, covering the prior calendar year. This is one of the most commonly missed requirements. The Form 300 log itself does not need to be posted — only the 300A summary.
OSHA Form 301: Injury and Illness Incident Report
The Form 301 is a more detailed report completed for each individual recordable case. It includes information about how the injury occurred, what the employee was doing, what object or substance was involved, and the nature of the injury. It must be completed within 7 calendar days of receiving information that a recordable case occurred.
Workers' compensation forms or equivalent state forms can substitute for Form 301 if they contain the same information.
What Counts as a Recordable Incident?
This is where most employers make mistakes. An injury or illness is recordable if it is work-related, is a new case, and meets one or more of the following recording criteria:
- Results in days away from work
- Results in restricted work or job transfer
- Requires medical treatment beyond first aid
- Involves loss of consciousness
- Results in a diagnosis of a significant injury or illness by a healthcare professional
- Results in death
What Does NOT Need to Be Recorded
Not every workplace injury is recordable. An injury or illness that requires only first aid treatment is not recordable. OSHA defines first aid as:
- Using non-prescription medications at nonprescription strength
- Tetanus immunizations
- Cleaning, flushing, or soaking wounds on the skin surface
- Wound closures (bandages, butterfly strips, Steri-Strips)
- Hot or cold therapy
- Non-rigid means of support (elastic bandages, wraps)
- Temporary immobilization of a body part during transport
- Drilling a fingernail or toenail to relieve pressure, or draining fluid from a blister
- Eye patches
- Removing debris from the eye using irrigation or a cotton swab
- Removing splinters or foreign material from areas other than the eye
- Finger guards
- Massages
- Drinking fluids for relief of heat stress
Work-Relatedness: When an Injury at Work Isn't "Work-Related"
An injury is work-related if an event or exposure in the work environment caused or contributed to the condition, or significantly aggravated a pre-existing condition. The work environment is your establishment and other locations where employees are working.
Certain injuries that occur at work are not considered work-related for recordkeeping purposes:
- Injuries from personal tasks at the establishment outside assigned working hours
- Voluntary participation in wellness programs or recreational activities
- Symptoms solely from a non-work-related event or exposure outside the workplace
- Mental illness, unless the employee voluntarily provides a medical opinion establishing work-relatedness
- Injuries from eating, drinking, or preparing food for personal consumption
- Common colds or flu
- Motor vehicle accidents in a parking lot during commuting
Electronic Submission Requirements
OSHA requires electronic submission of injury and illness data through OSHA's Injury Tracking Application (ITA) for certain employers:
- Establishments with 250 or more employees that are required to keep records must electronically submit Form 300A data annually
- Establishments with 20–249 employees in certain high-hazard industries must also submit Form 300A data annually
- Establishments with 100 or more employees in designated high-hazard industries must submit Forms 300, 300A, and 301 data
The annual submission deadline is March 2 for the prior calendar year's data. Submit through ITA at osha.gov/ita.
The Annual Posting Requirement
Every employer required to keep records must post the OSHA Form 300A Summary in a conspicuous place where notices to employees are customarily posted from February 1 through April 30 each year. The posted form must cover the prior calendar year.
If you have no recordable cases for the year, you must still complete and post the Form 300A — with zeros entered in the totals.
How Long to Keep Records
OSHA requires you to keep Forms 300, 300A, and 301 for five years following the end of the calendar year they cover. During that period, you must provide access to employees, former employees, and their representatives who request to see the records.
Common Recordkeeping Mistakes That Trigger Citations
- Not posting the 300A by February 1. This is the single most common recordkeeping violation.
- Recording first-aid-only cases. Over-recording is less common than under-recording but still creates problems — including inaccurate data that could affect your inspection targeting.
- Failing to record cases within 7 days. The 7-day clock starts when you learn of the case, not when the incident occurred.
- Missing the executive signature on Form 300A. The summary must be certified by a company executive, not just a safety manager.
- Not maintaining records for 5 years. OSHA can inspect records from prior years during a current inspection.
- Failing to provide records on request. Employees and former employees have the right to access the 300 log. Denying that access is a violation.