OSHA Record-keeping Rules: Compliance Guide

Provided by the Wisconsin Safety and Health Consultation Program

According to OSHA regulations (29 CFR 1904), most employers with 11 or more employees are required to maintain OSHA injury and illness records.

Exceptions:

• Small Employers: If your company had 10 or fewer employees at all times during the last calendar year, you are exempt from keeping these records unless OSHA or the Bureau of Labor Statistics (BLS) informs you in writing that you must do so.
• Low-Risk Industries: Certain low-hazard industries (defined by specific NAICS codes, such as certain retail, finance, or service sectors) are exempt from maintaining records, regardless of size. Note: Even if exempt from routine record-keeping, all employers must report any worker fatality to OSHA within 8 hours and any amputation, loss of an eye, or inpatient hospitalization within 24 hours.

If you are covered by the record-keeping rule, you must complete three specific forms:

• Log of Work-Related Injuries and Illnesses (OSHA 300 Log): This is a running list of injuries and illnesses throughout the calendar year. It must include a detailed account of each incident, including the employee’s name, job title, date of injury, description of the injury/illness, and the result (death, days away, restricted work, etc.).
• Summary of Work-Related Injuries and Illnesses (OSHA Form 300A): This form is a summary of the information from Form 300 and must be posted in a visible location in the workplace from February 1 through April 30 of the following year. Injury and Illness Incident Report (OSHA Form 301): This form records the specific details of each individual case. It requires more in-depth information than the Form 300 log, such as what the employee was doing just before the incident, how the injury occurred, and information about the physician or healthcare professional.

How to Fill Out the OSHA Logs

• OSHA 300 Log: You must record work-related injuries or illnesses that result in death, loss of consciousness, days away from work, restricted work activity or job transfer, or medical treatment beyond first aid.
• OSHA Form 300A: At the end of the year, total the columns from your Form 300. A company executive must certify that they have examined the OSHA 300 Log and that the 300A Summary is accurate.
• OSHA Form 301: Complete this form within 7 calendar days of receiving information that a recordable work-related injury or illness has occurred.

Deadlines and Submission Requirements

1. Posting Requirement (Form 300A)

• Who: All employers who are required to keep injury and illness records.
• When: The signed OSHA Form 300A must be posted in a visible location in the workplace from February 1 through April 30 of the year following the recorded year.

Note: You should not post the Form 300 (Log) or Form 301 (Incident Report) publicly, as they contain private employee information.

2. Electronic Submission to OSHA (Updated for 2024/2025) Certain employers must electronically submit their injury and illness data to OSHA via the Injury Tracking Application (ITA).  Who Must Submit?

• Establishments with 20–249 Employees: If you are in a designated industry with historically high rates of injuries (e.g., construction, manufacturing, utilities, grocery stores), you must submit information from Form 300A annually.
• Establishments with 250 or More Employees: All establishments of this size that are required to keep records must submit information from Form 300A annually.
• Establishments with 100 or More Employees in High-Hazard Industries: As of January 1, 2024, if your establishment is on the “Appendix B” list of high-hazard industries, you must submit information from Forms 300 and 301, in addition to Form 300A. This requirement allows OSHA to collect more specific details on how injuries are occurring.

Still unsure about what you may have to electronically report? Consider using the ITA Coverage Application to help determine what or if you need to submit. Submissions for 2025 begin January 2, 2025 and should be completed by March 2, 2025.