OSHA's recordkeeping regulations under 29 CFR Part 1904 require most employers to maintain records of work-related injuries and illnesses. Proper recordkeeping is not just a regulatory obligation; it is the foundation of an effective safety program. The data you collect drives your TRIR and DART rates, identifies hazard trends, and helps prioritize resources where they are needed most.
Common Recordkeeping Challenges
Who Must Keep Records?
Most employers with 11 or more employees at any time during the previous calendar year must keep OSHA injury and illness records. There are two categories of exemptions:
Size Exemption
Employers with 10 or fewer employees at all times during the previous calendar year are exempt from routine recordkeeping requirements, unless specifically directed by OSHA or the Bureau of Labor Statistics to keep records.
Industry Exemption
Certain low-hazard industries listed in Appendix A to Subpart B of 29 CFR 1904 are partially exempt from routine recordkeeping. However, all employers, regardless of size or industry, must report fatalities within 8 hours and severe injuries (hospitalizations, amputations, eye losses) within 24 hours.
The Three OSHA Recordkeeping Forms
OSHA Form 300 - Log of Work-Related Injuries and Illnesses
The 300 Log is a running record of each recordable injury and illness that occurs during the calendar year. Each entry includes the employee name, job title, date and location of the event, description, classification (death, days away, restricted, other recordable), and the number of days away or restricted.
- Must be updated within 7 calendar days of learning about a recordable event
- Maintained on a calendar-year basis (January 1 - December 31)
- Must be retained for 5 years following the year covered
OSHA Form 300A - Summary of Work-Related Injuries and Illnesses
The 300A is a year-end summary that totals the entries from the 300 Log. It must be certified by a company executive and posted where employees can see it.
- Must be posted February 1 through April 30 of the following year
- Must be certified by a company executive (owner, officer, or highest-ranking official at the establishment)
- Certain employers must submit 300A data electronically to OSHA via the Injury Tracking Application (ITA)
OSHA Form 301 - Injury and Illness Incident Report
The 301 form captures detailed information about each individual incident, including how the injury occurred, what the employee was doing, and what object or substance caused the harm. An equivalent form (such as a workers' compensation first report of injury) may be used if it contains all the same data elements.
What Makes an Injury or Illness Recordable?
An injury or illness is OSHA recordable if it is work-related and results in any of the following outcomes:
- Death
- Days away from work (any day after the day of injury the employee cannot work)
- Restricted work or job transfer (employee cannot perform routine job functions)
- Medical treatment beyond first aid (prescription medications, sutures, physical therapy, etc.)
- Loss of consciousness
- Significant injury or illness diagnosed by a physician or licensed healthcare professional (e.g., cancer, chronic conditions, fractures)
Severe Injury Reporting Requirements
Electronic Submission Requirements
OSHA's electronic reporting rule requires certain employers to submit injury and illness data electronically via the Injury Tracking Application (ITA):
Who Must Submit Electronically?
- Establishments with 250 or more employees in the previous year (not partially exempt) must submit data from Forms 300, 300A, and 301
- Establishments with 20-249 employees in designated high-hazard industries must submit Form 300A data
- Submissions are due by March 2 of each year for the prior calendar year
Common Recordkeeping Mistakes
How Software Simplifies OSHA Recordkeeping
Ecesis Incident Management Software
Incident Management
Report, investigate, and track incidents with automated OSHA form generation.
Safety Inspections
Identify hazards proactively with standardized inspection checklists.
Employee Training
Ensure workers complete required OSHA safety training on time.
Task Management
Track corrective actions from incidents through to verified completion.
Compliance Obligations
Never miss a posting deadline or electronic submission requirement.
Mobile EHS App
Report incidents immediately from the field using any mobile device.
