The OSHA 300 log requirements come down to two questions asked in order. Was the case work related, and did it meet at least one of the general recording criteria: death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or a significant injury or illness diagnosed by a licensed health care professional. If the answer to both is yes, the case goes on the log within seven calendar days.

Everything else in Part 1904 follows from that: which employers keep records, which three forms are involved, when the annual summary goes on the wall, and how long the paperwork stays in the file. Below is the whole picture, plus the recording mistakes that turn up most often when we audit a client for the first time.

Table of Contents

1. The Short Answer on What Gets Recorded
2. The Three Forms and What Each One Does
3. Which Employers Have to Keep Records
4. The 7 Rules That Govern the OSHA 300 Log
5. What Must Be Reported to OSHA Immediately
6. The Recordkeeping Mistakes We See Most
7. Why the Log Matters Beyond Compliance
8. Frequently Asked Questions

The Short Answer on What Gets Recorded

Recording is a two step test and the order matters. First, is the case work related, meaning an event or exposure in the work environment either caused it or significantly aggravated a pre-existing condition. If it is not work related, the analysis stops there and nothing goes on the log.

Second, if it is work related, does it meet any one of the general recording criteria. Death. Days away from work. Restricted work or transfer to another job. Medical treatment beyond first aid. Loss of consciousness. Or a significant injury or illness such as a fracture or a punctured eardrum diagnosed by a physician or other licensed health care professional. Any single one of those triggers a recordable case.

Note what is not on that list. Pain alone is not recordable. An incident report is not recordable. A trip to the clinic is not automatically recordable, because what matters is what was done there, not that the employee went. Getting these distinctions right is most of recordkeeping, and OSHA publishes the full framework in its injury and illness recordkeeping requirements.

The Three Forms and What Each One Does

Employers covered by the rule maintain three forms, and they serve different purposes.

The OSHA Form 300 is the log itself, a running line by line list of every recordable case in the calendar year. Each line captures the employee, the job title, the date, where the event occurred, a description, and how the case is classified: death, days away, restricted or transferred, or other recordable.

The OSHA Form 300A is the annual summary. It totals the year and is the form that gets certified by a company executive and posted where employees can see it. It contains no individual case detail, which is why it is the one that goes on the wall.

The OSHA Form 301 is the individual incident report, one per recordable case, with the detail on how the injury or illness happened. An equivalent form such as a workers compensation first report of injury can substitute if it captures the same information.

A common misunderstanding is that the 301 is optional if the 300 is complete. It is not. The log is the index, the 301 is the record, and an inspector asking for case detail is asking for the 301.

Which Employers Have to Keep Records

Two exemptions narrow the field, and both are frequently misread.

The first is size. Employers with ten or fewer employees at all times during the previous calendar year are partially exempt from routinely keeping the log. The count is company wide, not per site, which is where multi location employers get caught out.

The second is industry. Certain lower hazard industries are partially exempt by classification. Construction is not among them. Manufacturing is not among them. If you are reading this because you run projects or a plant, assume you are covered until you have confirmed otherwise against the current exemption list.

Two important limits on both exemptions. Partially exempt employers must still report severe injuries and fatalities to OSHA, and they must still respond if selected for a federal survey. The exemption applies to routine recordkeeping, not to reporting.

Multi employer sites add a layer. The log follows the employer whose employee was injured, not the site. On a project with a general contractor and eight subcontractors, there are potentially nine separate logs, and each employer records its own people. Sorting out who records what is a routine part of the site safety audits we run on active projects in the Chicago area and around Houston.

The 7 Rules That Govern the OSHA 300 Log

Rule 1: Establish Work Relatedness Before Anything Else

A case is presumed work related if an event or exposure in the work environment either caused or contributed to the condition, or significantly aggravated a pre-existing condition. The work environment includes the establishment and any other location where an employee is present as a condition of employment.

There is a defined set of exceptions, including cases where the employee was present as a member of the general public, symptoms arising in the workplace that are solely due to a non-work event, and certain cases involving voluntary wellness programs, eating personal food, or personal grooming. These exceptions are specific. They are not a general judgment call, and treating them as one is a reliable way to under-record.

Rule 2: Apply the General Recording Criteria

Once work relatedness is established, any one of the following makes the case recordable: death, one or more days away from work, restricted work activity or transfer to another job, medical treatment beyond first aid, loss of consciousness, or a significant injury or illness diagnosed by a licensed health care professional.

Restricted work is the criterion employers miss most. If an employee cannot perform one or more routine functions of the job, or cannot work the full workday they would otherwise have worked, that is restriction, and it is recordable. Putting somebody on light duty is a restriction whether or not anyone uses that word.

Rule 3: First Aid Is a Defined List, Not an Opinion

Medical treatment beyond first aid is recordable. First aid is not. The critical detail is that OSHA defines first aid by a specific, closed list of treatments, and anything not on that list counts as medical treatment regardless of who provided it or where.

The list includes items such as using a non-prescription medication at non-prescription strength, cleaning or flushing wounds on the skin surface, using wound coverings, hot or cold therapy, and non-rigid means of support. What falls outside it includes prescription medication at prescription strength, sutures, rigid immobilization, and physical therapy. A physician calling something minor does not change the classification. What was actually done determines it.

Rule 4: Record Within Seven Calendar Days

Once you receive information that a recordable case occurred, you have seven calendar days to enter it on the log and complete the incident report. That clock starts when the employer learns of the case, not when a determination is finally made about it.

If a case classification changes later, for example an employee who initially returned to full duty subsequently goes out on days away, the log is updated. The 300 log is a living document during the year, not a form filled out once in January.

Rule 5: Post the Annual Summary February 1 Through April 30

The 300A annual summary must be reviewed and certified by a company executive, then posted no later than February 1 of the year following the records, and kept in place until April 30. The regulation is explicit: post the summary no later than February 1 of the year following the year covered by the records and keep the posting in place until April 30.

It goes where employee notices are customarily posted, and it stays legible for the full three months. A summary posted in February and quietly removed in March is a citation waiting to happen, and it is one of the easiest findings for an inspector to document.

Rule 6: Submit Electronically Between January 2 and March 2

Establishments meeting certain size and industry criteria must submit injury and illness data to OSHA electronically once per year, and the submission window runs January 2 through March 2. Which data you submit depends on your size and classification, and the criteria have changed in recent years, so verify your current obligation each year rather than assuming last year applies.

Posting the summary on the wall does not satisfy electronic submission, and submitting electronically does not satisfy the posting requirement. They are separate obligations with separate deadlines.

Rule 7: Retain the Records Five Years

The 300 log, the privacy case list, the 300A annual summary, and the 301 incident reports must be kept for five years following the end of the calendar year the records cover. During that period, records must be available to employees, former employees, their representatives, and OSHA on request.

Records also have to be updated during the retention period as new information about a recorded case comes in. Storing them and forgetting them is not sufficient.

What Must Be Reported to OSHA Immediately

Recording and reporting are two different obligations, and confusing them is a serious problem rather than a paperwork one.

Recording means entering a case on your own log. Reporting means picking up the phone and notifying OSHA directly. All employers are required to report certain severe events, including employers who are partially exempt from routine recordkeeping.

A work related fatality must be reported within 8 hours. A work related in-patient hospitalization, amputation, or loss of an eye must be reported within 24 hours. OSHA sets out the process on its severe injury reporting page.

Two definitions decide most of these calls. In-patient hospitalization means formal admission to the in-patient service of a hospital or clinic. Emergency room treatment and release is not a reportable hospitalization, even if the employee was there most of the night. And amputation includes the loss of a fingertip with bone loss, which surprises supervisors who assume the term only covers a whole digit or limb.

These clocks are short and they run on real time, not business hours. Every supervisor who could be the first to learn of a serious injury needs to know who makes the call and how fast. Building that into the escalation path is standard practice in the safety programs we implement, and it is exactly the kind of detail that gets tested during an accident investigation.

The Recordkeeping Mistakes We See Most

When we take on a new client and review their logs, the same handful of problems come up across construction and industrial employers alike.

• Under-recording restricted duty. An employee on light duty is on restricted work and the case is recordable, whether or not the paperwork uses that phrase.
• Treating any clinic visit as automatically recordable, or automatically not. What was administered decides it, not where the employee went.
• Waiting on a workers compensation determination. Recordability under Part 1904 and compensability under a state workers compensation system are separate tests with different criteria, and a denied claim can still be a recordable case.
• Letting the 300A come down early, or never certifying it. It needs an executive signature and it has to stay up through April 30.
• Recording a case but never completing the 301. The log is not a substitute for the incident report.
• Missing the count on multi location employers, where the ten employee threshold applies company wide rather than per site.
• Recording every near miss on the log. Near misses are valuable and should be captured, but they belong in your internal system, not on the OSHA 300. Our guide to near miss reporting covers how to run that program alongside the log.

None of these are exotic. They are the routine result of recordkeeping being assigned to whoever has time rather than to someone trained in Part 1904, and they are also among the first things an inspector looks at once on site. Our breakdown of what triggers an OSHA inspection covers how those visits usually start.

Why the Log Matters Beyond Compliance

Treating the 300 log as paperwork misses what it actually is, which is the only complete data set you have on how people get hurt in your operation.

Your incident rates come from it. Total recordable incident rate and the days away, restricted, or transferred rate are both calculated from log entries against hours worked, using the standard base of 200,000 hours representing 100 full time workers for a year. Those two numbers travel with your company.

They travel further than most employers expect. General contractors and project owners routinely require rates as part of prequalification, and a number outside the acceptable band can keep a qualified contractor off a bid list entirely. Insurance carriers look at the same figures. So does anyone doing due diligence on an acquisition.

There is a real risk in the other direction too. Under-recording produces a rate that looks better than reality, and it fails in two ways at once. It can become a citation if OSHA reviews the underlying cases, and more importantly it hides the pattern you needed to see. Three restricted duty back cases in one department is a signal. Three cases classified as first aid because nobody applied the definition correctly is silence.

Used properly, the log tells you which tasks, shifts, crews, and locations are generating injuries, and that is where a site audit and targeted training should be pointed. The compliance value is real. The prevention value is larger.

Frequently Asked Questions

Is every injury recordable on the OSHA 300 log?

No. Only work related cases that meet at least one of the general recording criteria go on the log. A cut cleaned and covered with a bandage is first aid and is not recordable. The same cut closed with sutures is medical treatment and is recordable. The severity of the injury is not the test. What was done about it is.

Does a case become recordable just because the employee went to a doctor?

Not by itself. A visit for observation, counseling, or diagnostic procedures alone is not medical treatment for recordkeeping purposes. What matters is whether the treatment provided falls outside the defined first aid list. A physician can see an employee, take an x-ray, find nothing, and the case remains non-recordable.

Do I record a case if the workers compensation claim was denied?

Possibly yes. Recordability under OSHA and compensability under a state workers compensation system are separate determinations with different standards. A denied claim does not remove a case from the log if it was work related and met the recording criteria. Employers who wait for the claim outcome before deciding also routinely blow the seven day recording deadline.

Who is allowed to see our injury records?

Employees, former employees, their personal representatives, and their authorized employee representatives have access rights, along with OSHA. The 300A summary is posted openly because it contains no individual case detail. The log and the 301 reports contain identifying information and include privacy case protections for certain sensitive categories, where the employee name is withheld from the log and kept on a separate confidential list.

Do we need a 300 log for every jobsite?

Records are kept by establishment. A fixed location such as a plant or a facility is its own establishment. Short term projects can generally be recorded at the establishment that supervises them rather than each maintaining a separate log. For contractors running many concurrent projects, deciding how establishments are defined is worth doing once, deliberately, rather than differently on each job. Our contract safety services clients typically have this settled as part of their program documentation.

Get Your Recordkeeping Reviewed Before Someone Else Does

A recordkeeping review is one of the fastest checks in safety. Pull last year of cases, apply the criteria honestly, and see whether the log matches what actually happened. Most employers find something. Sheffield Safety has been providing site audits, on-site safety personnel, accident investigations, industrial hygiene services, training, and OSHA compliance consulting since 2003, from our offices in Plainfield, Illinois and Houston, Texas, across more than a dozen states. Contact us and we will review your logs, your posting practice, and your escalation path for severe injury reporting.

This article is general information about OSHA recordkeeping and is not legal advice. Verify current requirements against 29 CFR Part 1904 and any state plan rules that apply to your operation.

More on OSHA compliance and safety program management on the Sheffield Safety blog.