Understanding Your OSHA 300 Log Obligations
A practical guide for employers on maintaining OSHA injury and illness records, including who must file, what to record, and how to avoid common mistakes.
AEA Editorial Team
Who Needs to Keep OSHA Records?
Most employers with 11 or more employees at any point during the previous calendar year are required to maintain OSHA injury and illness records. Certain low-hazard industries in retail, finance, insurance, and real estate are partially exempt, but this exemption only applies to routine recordkeeping — not to reporting fatalities or severe injuries directly to OSHA.
Even if you are normally exempt, OSHA can require you to keep records during a specific survey year. Always check the current list of partially exempt industries published in 29 CFR 1904.2.
The Three Core Forms
OSHA's recordkeeping system revolves around three forms:
- OSHA Form 300 (Log of Work-Related Injuries and Illnesses): This is the running log you maintain throughout the year. Each qualifying incident gets its own line entry.
- OSHA Form 301 (Injury and Illness Incident Report): A detailed supplementary report for each individual case. An equivalent form, such as a workers' compensation first report of injury, may substitute if it contains all required data points.
- OSHA Form 300A (Summary of Work-Related Injuries and Illnesses): This annual summary must be posted in a visible workplace location from February 1 through April 30 of the following year. A company executive must certify the form.
What Counts as a Recordable Incident?
An injury or illness is recordable if it is work-related and results in any of the following:
- Death
- Days away from work
- Restricted work activity or job transfer
- Medical treatment beyond first aid
- Loss of consciousness
- A significant injury or illness diagnosed by a physician or licensed healthcare professional
The distinction between first aid and medical treatment is critical. First aid includes wound cleaning, bandaging, non-prescription medications, tetanus shots, and similar minor treatments. Anything more — stitches, prescription medications, physical therapy — makes the case recordable.
Common Employer Mistakes
Failing to record near-misses that resulted in treatment. If an employee trips, falls, and receives prescription painkillers, that is recordable even if the employee returns to work the same day.
Recording too late. You must enter each recordable case on the OSHA 300 Log within seven calendar days of learning about it.
Not updating entries. If an employee's condition changes — for example, a restricted duty case turns into days away from work — you must update the original log entry.
Discouraging reporting. Under 29 CFR 1904.35(b)(1)(iv), employers may not retaliate against employees for reporting injuries or illnesses. Incentive programs that penalize workers for reporting can violate this provision.
Posting the 300A late or not at all. The annual summary must be posted by February 1 and remain posted through April 30. Missing this window is a citable violation.
Retention and Access Requirements
You must retain OSHA Forms 300, 300A, and 301 for five years following the end of the calendar year they cover. During this retention period, you must update the 300 Log to reflect any newly discovered cases or changes in previously recorded cases.
Current and former employees, as well as their authorized representatives, have the right to access the OSHA 300 Log and 301 forms (with certain personal information redacted for privacy cases). OSHA inspectors and representatives from the Bureau of Labor Statistics also have access rights.
Practical Steps
- Designate a specific person responsible for OSHA recordkeeping at each establishment.
- Train supervisors to recognize recordable events and report them promptly.
- Conduct a quarterly review of your 300 Log to catch omissions and errors.
- Set a calendar reminder for mid-January to prepare and certify the 300A summary for posting by February 1.
- Keep completed forms in an organized, accessible file for the full five-year retention period.
Maintaining accurate OSHA records is not just a compliance obligation — it gives you data to identify injury trends and target your safety improvement efforts where they matter most.