OSHA 300 Recordkeeping Rules & Requirements

Under OSHA’s recordkeeping regulation, certain covered employers are required to prepare and maintain records of serious occupational injuries and illnesses using the OSHA 300 Log. This information is important for employers, workers and OSHA in evaluating the safety of a workplace, understanding industry hazards, and implementing worker protections to reduce and eliminate hazards.

Did You Know? Employers must electronically submit 2022 injury and illness data from OSHA Form 300A by March 2 if they have: 250 or more employees and are currently required to keep OSHA injury and illness records. 20-249 employees classified in specific industries with historically high rates of occupational injuries and illnesses. Visit OSHA’s Injury Tracking Application webpage for more information and to submit data online. When electronically submitting OSHA Form 300A, you must provide your Employer Identification Number.

Is your organization required to prepare and maintain records under current rules?

To find out if you are required to prepare and maintain records under the updated rule, first determine your NAICS code by:

1. Using the search feature at the U.S. Census Bureau NAICS main webpage.  In the search box for the most recent NAICS, enter a keyword that describes your business. Choose the primary business activity that most closely corresponds to you, or refine your search to get more choices.
2. Viewing the most recent complete NAICS tables on the U.S. Census Bureau NAICS main webpage. Select the two-digit sector code and choose a six-digit industry code to read its definition.
3. Using an old SIC code to find your NAICS code using the detailed conversion tables on the U.S. Census Bureau Concordances page.
4. Contacting your nearest OSHA office or State agency for help.

Once you have found your NAICS code, you can use the following table to determine if your industry is exempt from the recordkeeping rule.

• New list of industries exempt from OSHA recordkeeping requirements

NOTE: Establishments in companies with 10 or fewer employees at all times in the previous year continue to be exempt from keeping OSHA records, regardless of their industry classification.  The partial exemption for size is based on the number of employees in the entire company.

Forms Needed for Completion:

The OSHA injury and illness recordkeeping forms are:

• the Log of Work-Related Injuries and Illnesses (OSHA Form 300),
• the Summary of Work-Related Injuries and Illnesses (OSHA Form 300A), and
• the Injury and Illness Incident Report (OSHA Form 301).

Employers must fill out the Log and the Incident Report only if a recordable work-related injury or illness has occurred. Employers must fill out and post the Summary annually, even if no recordable work-related injuries or illnesses occurred during the year.

In place of the OSHA forms, employers may also use equivalent forms (forms that have the same information, are as readable and understandable, and are completed using the same instructions as the OSHA forms they replace). Many employers use an insurance form instead of the Incident Report, or supplement an insurance form by adding information required by OSHA.

Additional Information:

OSHA Fact Sheet

OSHA Exempt Industries FAQ Sheet

OSHA Recordkeeping Forms

OSHA 300 & 300A PDF Forms

Step 1: Determine the Establishment Locations

A Form 300 log is required for each physical establishment location that is expected to be in operation for at least one year. For employees who work from home, OSHA does not consider the worker’s home to be an establishment for record-keeping purposes. OSHA considers the worker’s establishment to be the office to which he or she reports, from which he or she receives direction or supervision, collects pay, and otherwise stays in contact with the employer. It is at this establishment that the log is kept.

Step 2: Identify Required Recordings

Work-related injuries and illnesses that result in the following must be recorded:

• Death.
• Loss of consciousness.
• Days away from work.
• Restricted work activity or job transfer.
• Medical treatment beyond first aid.
• Any work-related case involving cancer, chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum.

In addition to the above cases, employers must record the following conditions when work-related:

• Any needle-stick injury or cut from a sharp object that is contaminated with another person’s blood or other potentially infectious material.
• Any case requiring an employee to be medically removed under the requirements of an OSHA health standard.
• Tuberculosis (TB) infection as evidenced by a positive skin test or diagnosis by a licensed health care professional after exposure to a known case of active TB.
• An employee’s hearing test result that the employee has experienced a standard threshold shift in hearing in one or both ears.

The OSHA Regulation 29 C.F.R. §1904.7 contains an in-depth overview of recordable injuries and illnesses. Additional information on determining medical treatment and first aid can be located at 29 C.F.R. §1904.7(b)(5).

Step 3: Determine Work-Relatedness

When an accident occurs, an employer must document a recordable injury or illness on the OSHA Form 300 log within seven days. An injury or illness is considered work-related and must be recorded on the log unless an exception applies. Some exceptions include:

• At the time of the injury or illness, the employee was at work as a member of the general public and not as an employee. For example, if an employee returns to work after the end of his or her shift to pick up an item the employee forgot to take home and is injured during this visit.
• The injury or illness surfaces while at work, but results solely from a nonwork-related event or exposure. For example, an employee suffers a heart attack while at work but has a history of heart disease.
• The injury or illness results solely from voluntary participation in a wellness program. For example, an employee is injured while working out in the company gym.
• The injury or illness is the result of eating or drinking or preparing food or drink for personal consumption. For example, an employee chokes while eating a sandwich for lunch.
• The injury is the result of an employee doing personal tasks outside of work hours. For example, the employee sustains an injury while visiting with co-workers after his or her work shift.

Step 4: Complete the OSHA Form 300

Employers must take the following steps to fill out the OSHA Form 300:

1. Fill in the year, establishment name, city and state.
2. Assign each event an employer-created case number on the OSHA log. This can be as simple as number 1, 2, 3, 4 and so on. The only requirement is that each case number for a given year is unique.
3. Identify the employee, the employee’s job title, the date of the injury or onset of the illness and the exact location where the event occurred.
4. Specifically describe the case, along with the parts of the body affected and the object/substance that directly injured or made the employee ill, using more than one line if necessary.
5. Classify the case by choosing only one of the categories. The most serious outcome will need to be recorded; the employer should revise the log if the injury or illness progresses or the outcome is more serious than was originally recorded. The original entry must be crossed out, deleted or concealed with correctional fluid.
6. Enter the number of days the employee was on restricted work or job transfer, the number of days away from work, or both.
7. Indicate whether the case is an injury or an illness.
8. Total all columns at the end of the year.

The Form 300 will contain information related to an employee’s health and must be kept confidential to the extent possible while using the information for occupational safety and health purposes. OSHA provides guidance that includes the forms needed for maintaining occupational injury and illness records along with step-by-step instructions.

Step 5: Complete and Post the OSHA 300A Annual Summary

The information from the OSHA Form 300 Log is transferred onto the 300A Summary by matching the corresponding lettered column on the log with the lettered blank space on the summary.

The employer must complete the establishment information section and have the summary signed by an authorized executive of the company.

Employers must complete the 300A summary form and post the summary in the workplace from February 1 to April 30 of the year following the year covered by the form at each job site in a conspicuous area where notices to employees are customarily placed. For example, accidents occurring in 2022 will be summarized on the Form 300A and posted from February through April 2023. Copies of the 300A summary should be provided to any employees who may not see the posted summary because they do not regularly report to a fixed location.

Step 6: Submit Electronic Reports to OSHA

Employers with 20 or more employees that are subject to OSHA’s recordkeeping regulation must electronically submit to OSHA information from Form 300A (Summary of Work-Related Injuries and Illnesses) by March 2.

Employers with fewer than 20 employees at all times during the year do not have to submit information electronically to OSHA.

The requirement to electronically submit information from OSHA Form 300 (Log of Work-Related Injuries and Illnesses), and OSHA Form 301 (Injury and Illness Incident Report) was eliminated in 2019. However, OSHA issued a proposed rule in 2022 that could, if finalized, require establishments with 100 or more employees in the highest-hazard industries to submit the Form 300 and the Form 301 information once a year to OSHA. See Improve Tracking of Workplace Injuries and Illnesses. 

Step 7: Retain the Log and Summary

The OSHA Form 300 Log and the OSHA 300A Summary must be kept for five years following the year that the log and summary pertain to. (SHRM)

How to Calculate OSHA Case Rates and Day Rates

The typical injury and illness rates monitored by OSHA include case rates such as:

• Recordable case rate (RCR)—also called total recordable case rate (TRCR) or total recordable incident rate (TRIR)
• Days away, restricted, or transferred rate (DART)
• Lost time case rate (LTCR)
• Days away case rate (DACR)

The basic equation for these rates is:

Number of cases x 200,000

Case Rate TRIR or DART =       ____________________________________

 Number of hours worked

Some safety rating groups will use day rates as well as case rates to prescreen companies bidding for jobs. Using data on logs and 300A forms, calculate the day rate by using the sum of days of lost time or days of job transfer instead of the count of cases with lost days or job transfer.

Days lost or days of restricted duty x 200,000

Day Rate =               ___________________________________________

                                                  Number of hours worked

To keep all these rates low, employers should, of course, seek to prevent injuries and keep non-OSHA recordable cases off the logs. In addition, they should also actively monitor and manage cases to minimize the number of cases that end up triggering recordability and accumulating unnecessary days away from work or job transfer (modified duty) days.

Six Steps to Reduce OSHA Injury and Illness Rates

The methods discussed below are commonly used as workers’ compensation controls, but they are also central to lowering OSHA rates.

1. Determining Recordability

The first and most important question is whether the injury or illness in question is work-related. If it is not work-related, the case is not recordable and those keeping the log can simply stop here. We cover more about determining if the injury or illness is work-related in another article in this series.

2. Ensuring Prompt Return to Work and Normal Duties

Returning employees to work and normal duties as quickly as possible after an injury helps decrease the number of cases and days that accumulate toward the rates outlined above. In a limited number of cases, the only thing that makes a case OSHA recordable can be the loss of days itself. Some employers unintentionally make a case recordable and accumulate days because they take an employee off work or assign them modified duty when the medical professional treating them does not prescribe it. OSHA considers that case and those days as recordable.

To keep rates legitimately low, have an expedited process to ensure the employee is brought back to work and returned to their regular job duties as quickly as possible. Work with medical providers who are familiar with your company and your employees’ roles to streamline this process:

• Ensure medical providers know you offer modified duty
• Send an accurate job description to the clinic with the employee
• Get to know the occupational medical providers in your area
• Provide them with job descriptions ahead of time
• Have them visit your sites or workplace

3. Using Nurse Triage and First Aid When Possible

Cases that do not result in medical treatment are non-recordable, barring any other triggers. For injuries and illnesses that are not severe, consider using nurse triage and or first aid treatment to help prevent unnecessary trips to a medical provider—this can potentially keep some cases off your logs. Remember that OSHA has a prescriptive list of first aid treatments, and any treatment that falls outside of that list is considered medical treatment. It’s also important to remember that if treatments are on that list but are administered by a medical doctor or other medical professional, it’s still counted as first aid. Knowing what counts as first aid versus medical treatment will help you ensure you don’t over-record (or under-record).  Getting your employees the most appropriate and best care after an injury is the first priority. Having a nurse triage service help you make that call and help you know when first aid treatment is best is a solid strategy. For more information on this topic, see our article, OSHA 300 Logs: How to Determine Whether to Record an Injury or Illness.

4. Reporting Claims Quickly

While it may sound counterintuitive, if first aid is not appropriate, reporting claims quickly and getting an adjuster involved is another way to help shorten case length, limit days lost, decrease days of modified duty, and expedite good medical outcomes. Delaying reporting and access to medical care tends to lengthen off-work and modified duty periods in the long run.

Workers’ compensation case acceptance and payment are not the same as OSHA recordability decision-making. Each has its own criteria, so ensure you are using OSHA’s criteria for recordkeeping rather than assuming a WC case acceptance merits automatic OSHA reporting.

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How does OSHA define a recordable injury or illness?

• Any work-related fatality.
• Any work-related injury or illness that results in loss of consciousness, days away from work, restricted work, or transfer to another job.
• Any work-related injury or illness requiring medical treatment beyond first aid.
• Any work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums.
• There are also special recording criteria for work-related cases involving: needlesticks and sharps injuries; medical removal; hearing loss; and tuberculosis.

How does OSHA define first aid?

• Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes);
• Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment); Cleaning, flushing or soaking wounds on the surface of the skin
• Using wound coverings such as bandages, Band-Aids™, gauze pads, etc.; or using butterfly bandages or Steri-Strips™ (other wound closing devices such as sutures, staples, etc., are considered medical treatment);
• Using hot or cold therapy;
• Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes);
• Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards, etc.). Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister;
• Using eye patches;
• Removing foreign bodies from the eye using only irrigation or a cotton swab;
• Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means;
• Using finger guards;
• Using massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes); or
• Drinking fluids for relief of heat stress.