OSHA Recordkeeping and Reporting Updates Employers Should Know

OSHA recordkeeping requirements apply to most employers with 11 or more employees. Proper documentation of workplace injuries and illnesses is not just a compliance obligation; it provides data that drives safety improvements and protects you in the event of an OSHA inspection. Here are the current requirements and best practices.

Who Must Keep Records

Most employers with 11 or more employees at any time during the prior calendar year must maintain OSHA injury and illness records. Exemptions include:

• Employers with 10 or fewer employees throughout the prior year (though they must still report certain severe injuries)
• Establishments in specific low-hazard industries listed in OSHA's partially exempt industries list (updated periodically). Even partially exempt employers must report fatalities, hospitalizations, amputations, and losses of an eye.

Required Forms

OSHA Form 300 (Log of Work-Related Injuries and Illnesses)

A running log maintained throughout the year recording each recordable injury or illness:

• Case number, employee name, job title, date of injury, where the event occurred
• Description of the injury or illness, including the body part affected and the object or substance that directly harmed the employee
• Classification (death, days away from work, job transfer or restriction, other recordable case)
• Number of days away from work and/or days of restricted or transferred duty

OSHA Form 301 (Injury and Illness Incident Report)

A detailed report for each recordable case containing:

• Information about the employee, the physician or health care professional, and the employer
• Details about the incident (date, time, what happened, what the employee was doing)
• Information about the injury or illness and treatment

Employers may use an equivalent form (such as a workers' compensation first report of injury) if it contains all required information.

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

An annual summary that must be:

• Completed based on the year's Form 300 data
• Certified by a company executive
• Posted in a visible location from February 1 through April 30 of the following year
• Made available to employees and their representatives upon request

What Is Recordable

An injury or illness is recordable if it is:

1. Work-related (the work environment caused or contributed to the condition or significantly aggravated a pre-existing condition), AND
2. Results in one or more 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 physician or licensed health care professional

First aid vs. medical treatment

This distinction determines recordability for many cases. First aid includes:

• Non-prescription medications at nonprescription strength
• Tetanus immunizations
• Cleaning, flushing, or soaking wounds on the surface of the skin
• Wound coverings (bandages, butterfly bandages, Steri-Strips)
• Hot or cold therapy
• Non-rigid means of support (elastic bandages, wraps)
• Temporary immobilization devices used during transport
• Drilling of a fingernail or toenail, draining fluid from a blister
• Eye patches, removal of foreign bodies from the eye using irrigation or a cotton swab
• Finger guards, massages, drinking fluids for heat-related illness, oxygen administration

Anything beyond this list is considered medical treatment and makes the case recordable.

Electronic Reporting Requirements

OSHA's electronic reporting rule requires certain employers to submit injury and illness data electronically:

• Establishments with 250+ employees in industries covered by the recordkeeping regulation must submit Form 300A data annually through OSHA's Injury Tracking Application (ITA)
• Establishments with 20-249 employees in designated high-hazard industries must also submit Form 300A data annually
• Submissions are typically due by March 2 of the year following the calendar year covered

OSHA has proposed expanding electronic reporting to include Form 300 and Form 301 data for larger establishments. Monitor rulemaking developments for changes to reporting requirements.

Best Practices for Recordkeeping

Timely recording

Record injuries and illnesses within seven calendar days of learning about them. Delays create compliance risk and reduce the accuracy of your records.

Consistent classification

Train the individuals responsible for recordkeeping on the definitions of recordable cases, first aid versus medical treatment, and work-relatedness. Inconsistent classification undermines data quality and can result in citations.

Annual review

Before certifying the Form 300A summary, review the year's records for accuracy and completeness. Verify that all cases were properly classified and that day counts are correct.

Record retention

Maintain OSHA 300 logs, 301 incident reports, and 300A summaries for five years following the year they cover. Update the 300 log during the five-year retention period if previously recorded cases have changes in outcomes.

Privacy concerns

For certain types of cases (those involving intimate body parts, sexual assault, mental illness, HIV, needlestick injuries, and tuberculosis), do not enter the employee's name on the 300 log. Use "privacy case" instead.

Severe Injury Reporting

All employers, regardless of size or industry exemption, must report:

• Fatalities: Within 8 hours of learning about the death
• In-patient hospitalizations, amputations, or losses of an eye: Within 24 hours

Report by calling OSHA's toll-free number, calling or visiting the nearest OSHA area office, or using OSHA's online reporting portal. Failure to report within the required timeframes can result in significant penalties.

Using Your Data

Beyond compliance, OSHA records provide valuable safety management data:

• Track injury rates over time to measure the effectiveness of safety programs
• Identify departments, job functions, or tasks with disproportionate injury rates
• Analyze root causes to prevent recurrence
• Benchmark your rates against industry averages using data published by the Bureau of Labor Statistics

Accurate recordkeeping is the foundation of an effective workplace safety program. Treat it as a management tool, not just a regulatory burden.