OSHA Recordkeeping Requirements: Complete Guide to Workplace Injury and Illness Reporting
The Occupational Safety and Health Administration (OSHA) mandates that certain employers maintain accurate workplace injuries and illnesses records. These recordkeeping requirements serve multiple purposes: they help employers identify hazardous conditions, allow OSHA to monitor industry trends, and provide crucial data for improving workplace safety standards.
This comprehensive guide, “OSHA Recordkeeping Requirements: Complete Guide to Workplace Injury and Illness Reporting,” outlines everything businesses need to know about OSHA recordkeeping obligations, ensuring compliance while fostering safer work environments.
Who Must Maintain OSHA Records?
OSHA recordkeeping requirements don’t apply to all businesses. Employers must comply with these regulations if:
- They have over 10 employees at any point during the calendar year (with some exceptions).
- They are not classified as a partially exempt industry as listed in OSHA’s low-hazard exemption list.
Specific retail, service, finance, insurance, and real estate industries are partially exempt. However, even exempt businesses must report severe injuries and fatalities to OSHA directly.
Understanding OSHA Recordkeeping Forms
OSHA requires three primary forms for injury and illness documentation:
OSHA Form 300: Log of Work-Related Injuries and Illnesses
The Form 300 serves as a running log of all recordable workplace incidents throughout the year. For each incident, employers must record:
- The employee’s name and job title.
- The date and location of the incident.
- A brief description of injury or illness.
- Classification of the case (death, days away from work, job transfer, etc.).
- Number of days the employee was away from work or on restricted duty.
Privacy cases (involving sensitive issues like sexual assaults or mental illnesses) require special handling, with the employee’s name omitted from this log.
OSHA Form 301: Injury and Illness Incident Report
Form 301 contains detailed information about each specific incident, including:
- More comprehensive information about the injured employee.
- A detailed description of how the illness or injury occurred.
- Specific body parts affected.
- Objects or substances involved in the incident.
- Medical treatment is provided.
This form must be completed within seven calendar days of learning about a recordable workplace incident.
OSHA Form 300A: Summary of Work-Related Injuries and Illnesses
Form 300A summarizes the total number of cases, days away from work, and types of injuries documented on Form 300 for the entire year. This form must be:
- Certified by a company executive.
- Posted in a visible location at the workplace from February 1st to April 30th of the year following the year covered.
- Maintained for five years following the year it covers.
What Qualifies as a Recordable Incident?
Not all workplace injuries or illnesses need to be recorded. An incident is OSHA-recordable if it:
- Is work-related (exposure or event in the work environment contributed to the condition)
- Is a new case (not an exacerbation of a previously recorded injury)
- Meets one or more of these severity criteria:
- Death
- Days away from work
- Restricted work or transfer to another job
- Medical treatment beyond first aid
- Loss of consciousness
- Significant illness or injury diagnosed by a healthcare professional
First Aid vs. Medical Treatment
Understanding the distinction between first aid (non-recordable) and medical treatment (recordable). OSHA specifically defines first aid to include:
- Using non-prescription medications at non-prescription strength.
- Administering tetanus immunizations.
- Cleaning, flushing, or soaking wounds on the skin surface.
- Using wound coverings, bandages, or butterfly bandages.
- Using hot or cold therapy.
- Using non-rigid means of support.
- Drilling a toenail or fingernail to relieve pressure.
- Draining fluid from a blister.
- Using eye patches.
- Removing foreign bodies from the eye using cotton swabs.
- Using finger guards.
- Using massages.
- Drinking fluids for heat stress.
Treatments beyond this list typically constitute medical treatment, making the incident recordable.
Electronic Submission Requirements
In addition to maintaining physical records, many employers must submit their Form 300A data electronically through OSHA’s Injury Tracking Application (ITA). This requirement applies to:
- Establishments with 250 or more employees.
- Establishments with 20 to 249 employees in particularly high-risk industries.
- Establishments specifically requested to submit data by OSHA.
Electronic submissions are typically due by March 2, following the calendar year covered by the records.
Common OSHA Recordkeeping Mistakes to Avoid
Many businesses struggle with OSHA recordkeeping compliance. Common mistakes include:
- Misclassifying incidents: Incorrectly determining whether an injury is recordable or not.
- Incomplete documentation: Missing crucial details on required forms.
- Late recording: Failing to document incidents within the seven-day requirement.
- Improper posting: Not displaying Form 300A during the required February-April timeframe.
- Inadequate retention: Not keeping records for the mandatory five-year period.
- Privacy violations: Not properly handling confidential cases.
- Inconsistent criteria: Using different standards to determine recordability across the organization.
Best Practices for OSHA Recordkeeping
Implementing these best practices can streamline compliance efforts:
Establish Clear Procedures
Develop written procedures for reporting, investigating, and recording workplace incidents. Clearly define roles and responsibilities. This will ensure that everyone understands their part.
Train Key Personnel
Provide comprehensive training to supervisors, HR staff, and safety professionals on OSHA recordkeeping requirements. Ensure they understand what constitutes a recordable incident and how to document it properly.
Implement Regular Reviews
Conduct periodic audits of your OSHA logs to ensure accuracy and completeness. Consider quarterly reviews to catch and correct potential issues before year-end.
Leverage Technology
Use digital safety management systems to streamline documentation and consistently apply recordkeeping criteria. Many modern EHS software solutions can automate much of the recordkeeping process.
Foster a Reporting Culture
Encourage employees to report all incidents, no matter how minor. Creating a blame-free reporting environment helps ensure complete data collection while promoting safety awareness.
Legal Implications of Non-Compliance
Failing to meet OSHA recordkeeping requirements can result in:
- Citations and financial penalties (up to $15,625 per violation as of 2025).
- Enhanced scrutiny from OSHA, potentially leading to more frequent inspections.
- Difficulty defending against citations or workers’ compensation claims.
- Reputational damage and potential liability concerns.
More importantly, accurate recordkeeping provides valuable data for identifying and addressing workplace hazards, potentially preventing future incidents.
Industry-Specific Considerations
Different industries face unique challenges in OSHA recordkeeping. For example:
- Construction: Must account for multiple contractors and temporary worksites.
- Healthcare: Needlestick injuries and bloodborne pathogen exposures.
- Manufacturing: Often deals with repetitive motion injuries requiring careful evaluation.
- Transportation: Must distinguish between traffic accidents and workplace incidents.
Understanding the nuances of your specific industry can help ensure proper compliance with all applicable regulations.
Your Path to OSHA Recordkeeping Excellence
Maintaining accurate OSHA records requires diligence, but the benefits extend beyond regulatory compliance. Proper recordkeeping provides crucial insights into workplace safety trends, helps identify preventable hazards, and demonstrates your commitment to employee well-being.
By following these “OSHA Recordkeeping Requirements: Complete Guide to Workplace Injury and Illness Reporting guidelines, businesses can meet their legal obligations and leverage safety data to create healthier, more productive work environments.
Need Expert Guidance? We’re Here to Help
Navigating the complexities of OSHA recordkeeping requirements doesn’t have to be overwhelming. Phase Associates (formerly Atlantic Environmental) provides comprehensive environmental health and safety (EHS) services, including consulting, training, and professional outsourcing to meet various occupational health and safety challenges.
Our team of certified safety professionals will help you implement effective recordkeeping systems, conduct compliance audits, and develop customized safety programs that protect your employees while minimizing regulatory risks.
Contact Phase Associates today to ensure your business complies with all OSHA recordkeeping requirements.