Mastering OSHA Recordkeeping Requirements

Accurate paperwork might not seem like the most exciting part of workplace safety, but when it comes to OSHA compliance, it's one of the most important. Proper recordkeeping is more than just a bureaucratic task; it's a fundamental tool for understanding, tracking, and preventing workplace injuries and illnesses. It provides the data needed to identify hazard trends and make informed decisions that protect your employees.

This guide will break down the essential recordkeeping requirements under OSHA's CFR 1910 (General Industry) and 1926 (Construction). We'll cover why it matters, which forms you need to know, and how to maintain accurate records that benefit your business far beyond just staying compliant.

Why Accurate Recordkeeping is Crucial

OSHA's recordkeeping rule (29 CFR 1904) is designed to create a clear picture of workplace safety. For employers, maintaining these records is not optional—it's a legal obligation that serves several key functions:

• Identifies Hazard Trends: By tracking injuries and illnesses, you can spot patterns. Are most back injuries happening in a specific department? Are there frequent cuts from a certain type of machine? This data helps you pinpoint where to focus your safety efforts.

• Improves Safety Programs: The information gathered through recordkeeping helps you evaluate the effectiveness of your existing safety programs. High incident rates in one area might indicate that training or procedures need to be revised.

• Ensures Compliance: During an OSHA inspection, one of the first things an officer will ask to see is your injury and illness records. Having complete and accurate logs demonstrates a commitment to safety and helps you avoid citations.

• Empowers Employees: OSHA requires that employees have access to these records. This transparency allows them to be more aware of the hazards in their workplace and participate more actively in safety initiatives.

Who Needs to Keep OSHA Records?

Not every business is required to keep OSHA injury and illness records. There are two main exemptions:

1. Size Exemption: If your company had 10 or fewer employees at all times during the last calendar year, you are generally exempt from routinely keeping OSHA records.

2. Industry Exemption: Certain low-hazard industries (like some retail stores, law offices, and banks) are also exempt. OSHA provides a list of these partially exempt industries.

However, it is critical to understand that no business is ever exempt from reporting a fatality, in-patient hospitalization, amputation, or loss of an eye. All employers, regardless of size or industry, must report these severe incidents to OSHA directly.

The Three Key OSHA Forms

For businesses that are required to keep records, the process revolves around three specific forms. These documents work together to create a detailed log of work-related injuries and illnesses.

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

This is the central document for your recordkeeping. The OSHA 300 Log is where you list every recordable injury and illness that occurs throughout the year. For each case, you must detail:

• The employee's name and job title.

• The date the injury or illness occurred.

• Where the event happened.

• A description of the injury or illness, including the parts of the body affected.

• The outcome of the case (e.g., days away from work, job restriction or transfer, or other recordable outcome).

You must start a new log for each establishment or location and update it within seven calendar days of learning about a recordable incident.

OSHA Form 301: Injury and Illness Incident Report

This is the most detailed report for each individual case. For every incident you record on the Form 300 Log, you must also complete a Form 301. This form captures specific information about what happened, asking questions like:

• What was the employee doing just before the incident occurred?

• What happened? Tell us how the injury occurred.

• What was the injury or illness?

• What object or substance directly harmed the employee?

The level of detail in Form 301 is essential for conducting a thorough accident investigation and understanding the root cause of the incident. Equivalent forms, such as a state workers' compensation form, can be used if they contain the same information.

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

At the end of the year, you use the data from your Form 300 Log to create the Form 300A Summary. This form provides a total count of all work-related injuries and illnesses in different categories. It does not include any employee names.

The Form 300A serves two purposes:

1. Posting: You must post a copy of the summary in a common area where employees can see it (like a break room) from February 1 to April 30 of the following year.

2. Electronic Submission: Many establishments are required to electronically submit their Form 300A data to OSHA through the Injury Tracking Application (ITA).

Tips for Organized and Compliant Recordkeeping

Maintaining accurate records requires a systematic approach. Disorganization can lead to mistakes, missed deadlines, and potential OSHA citations.

1. Know What Makes an Incident "Recordable"

Not every cut or bruise needs to be logged. An injury or illness is considered recordable by

OSHA if it is work-related and results in any of the following:

• Death

• Days away from work

• Restricted work or transfer to another job

• Medical treatment beyond first aid

• Loss of consciousness

• A significant injury or illness diagnosed by a licensed health care professional

Understanding the difference between first aid (e.g., using a bandage, cleaning a wound) and medical treatment (e.g., getting stitches, receiving a prescription) is essential.

2. Centralize Your Documentation

Keep all your safety records—Forms 300, 301, and 300A, as well as training records and inspection logs—in one accessible location. This could be a physical binder in the office or a secure digital folder. Centralization makes it easier to manage updates, respond to requests, and prepare for audits.

3. Maintain Confidentiality

The OSHA 300 Log contains sensitive employee medical information. You must protect this privacy. When providing copies to anyone who doesn't have a right to see the entire log (such as for posting), you must conceal the names for "privacy concern cases," which include injuries to intimate body parts, sexual assaults, and other sensitive situations.

4. Set Calendar Reminders

Avoid missing key deadlines. Set calendar reminders for important dates:

• February 1: Post the previous year's Form 300A Summary.

• March 2: Deadline for electronically submitting your 300A data to OSHA, if required.

• April 30: Last day to have the Form 300A Summary posted.

Also, remember the 7-day rule for updating your logs after an incident.

Common Recordkeeping Mistakes to Avoid

Simple errors can lead to big problems. Be mindful of these common pitfalls:

• Under-reporting: Mistaking medical treatment for first aid and failing to record an incident.

• Over-reporting: Logging every minor incident, even those that don't meet OSHA's recordability criteria.

• Incorrectly Calculating Days Away: Miscounting the number of calendar days an employee was unable to work.

• Forgetting to Post the 300A Summary: This is a common and easily avoidable citation.

• Failing to Certify the Summary: A company executive must review the logs and certify that the annual summary is true and complete.

Beyond Compliance: The Business Benefits of Good Records

Proper OSHA recordkeeping does more than just keep you out of trouble. It's a powerful business management tool. Accurate data allows you to perform trend analysis, which can justify investments in new equipment, training programs, or engineering controls.

By tracking incidents, you can calculate your company's incident rates and benchmark them against your industry average. A low incident rate can be a selling point for customers and can help lower your workers' compensation insurance premiums. Most importantly, it fosters a culture of safety, showing your employees that their well-being is a top priority. In the end, good records don't just count injuries—they help prevent them.

How Must Be Safety Can Help with OSHA Recordkeeping

Must Be Safety, LLC is your trusted partner in navigating OSHA compliance and mastering recordkeeping requirements. Our team offers expert-led training and hands-on consulting to ensure your business not only understands the intricacies of Forms 300, 300A, and 301 but also maintains accurate and accessible records year-round. Whether you need tailored recordkeeping workshops, guidance on implementing OSHA-compliant systems, or ongoing support to avoid common compliance pitfalls, Must Be Safety provides practical solutions to protect your team and strengthen your safety culture. Services are available in both English and Spanish to serve your entire workforce.