OSHA Recordkeeping: 300 Log Requirements and Common Mistakes
If you have ever certified a 300A in February only to realize an old case was misclassified, or scrambled to figure out whether your establishment owes an electronic submission by March 2, you already know that OSHA recordkeeping is less about paperwork and more about judgment. The forms are simple. Deciding what goes on them — and proving you did it consistently — is where most organizations get into trouble.
This guide covers what the OSHA 300 log actually requires, how Forms 300, 300A, and 301 fit together, who must submit data electronically, and the recordkeeping mistakes that show up most often in citations. Everything here reflects the rules in effect as of 2026.
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What OSHA Recordkeeping Requires Under 29 CFR 1904
OSHA recordkeeping is the legal obligation under 29 CFR Part 1904 to record and report work-related injuries and illnesses on standardized forms. It applies to most employers with more than 10 employees, unless their industry is classified as partially exempt (generally lower-hazard sectors such as many retail, finance, and professional service codes).
The regulation sets three distinct obligations that organizations often blur together:
- Recording — maintaining the OSHA 300 log and supporting Form 301 reports throughout the year for every recordable case.
- Posting — displaying the Form 300A annual summary in the workplace for employees to see.
- Reporting — submitting injury and illness data to OSHA electronically, and reporting severe events (fatalities, hospitalizations, amputations, eye loss) by phone within fixed windows.
A common misconception is that small employers and partially exempt employers have no obligations. Even employers who are exempt from routine recordkeeping must still report a work-related fatality within 8 hours and a work-related in-patient hospitalization, amputation, or loss of an eye within 24 hours. The recording exemption does not cancel the severe-event reporting duty.
The other point worth internalizing early: the 300 log is a calendar-year document, but the decisions feeding it happen all year. Organizations that treat recordkeeping as a January-only task accumulate errors that surface during certification, when there is no longer time to investigate them properly.
The Three Forms: 300, 300A, and 301
OSHA recordkeeping runs on three forms that serve different purposes, and using them correctly depends on understanding how they relate. The 300 log is the running list, the 301 is the detail behind each entry, and the 300A is the public summary.
| Form | Purpose | When it is used | Who sees it |
|---|---|---|---|
| Form 300 | The "Log of Work-Related Injuries and Illnesses" — one line per recordable case, with classification, days away/restricted, and case type | Updated throughout the year as cases are recorded | Internal; provided to OSHA on request and (for some establishments) submitted electronically |
| Form 301 | The "Injury and Illness Incident Report" — detailed record of a single case: what happened, what the worker was doing, the nature of injury | Completed for each recordable case | Internal; submitted electronically by larger high-hazard establishments |
| Form 300A | The "Summary of Work-Related Injuries and Illnesses" — annual totals from the 300 log, certified by a company executive | Completed and certified at year-end | Posted in the workplace; submitted electronically by covered establishments |
A few mechanics that trip people up:
Form 301 has a deadline of its own. You must complete a Form 301 incident report (or an equivalent record) within 7 calendar days of learning that a recordable injury or illness has occurred. The 300 log entry and the 301 detail are not interchangeable — auditors expect both.
The 300A must be certified by a company executive. Not the safety coordinator who maintains the log. The regulation requires certification by a company official — typically an owner, an officer, the highest-ranking company official at the site, or that person's immediate supervisor.
The 300A posting window is fixed. The certified 2025 summary must be posted in a conspicuous location from February 1 through April 30, 2026, even if there were zero recordable cases that year. Posting "zero" is still posting.
What Counts as a Recordable Case
A case is OSHA-recordable when it is work-related and results in one of the outcomes defined in 29 CFR 1904.7 — and getting this determination right is the single most consequential recordkeeping skill. Over-recording inflates your rates; under-recording is a citation risk.
A work-related injury or illness must be recorded if it results in any of the following:
- Death
- Days away from work (one or more calendar days the employee cannot work)
- Restricted work or transfer to another job
- Medical treatment beyond first aid
- Loss of consciousness
- A significant injury or illness diagnosed by a physician or other licensed health care professional (e.g., a fractured bone, even if no other criterion is met)
The phrase doing most of the work is "medical treatment beyond first aid." OSHA maintains a specific, closed list of what qualifies as first aid (in 1904.7). If the treatment provided is on that first-aid list, the case is not recordable on that basis alone. If it goes beyond the list — prescription medication, sutures, physical therapy beyond a single visit — it crosses into recordable territory.
The practical difficulty is that this is a judgment call made repeatedly, often by different people, under time pressure, with incomplete medical information. When the person triaging the case in March applies different logic than the person who handled a similar case in August, your log becomes inconsistent — and inconsistency is exactly what an auditor reverse-engineers. A documented decision trail for each case (what happened, what treatment was given, why it was or was not recorded) is the defense.
For the investigation behind each recordable case, see our guide to OSHA-aligned incident investigation, which connects the recordability decision to a defensible root cause analysis.
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Electronic Submission Rules: Who Must Submit and When
Electronic submission is the requirement to upload injury and illness data to OSHA's Injury Tracking Application (ITA) each year, and the scope expanded under the rule that took effect January 1, 2024. Many employers who only had to maintain forms internally now also have to transmit detailed case data.
As of 2026, three categories of establishments must submit data electronically by March 2 each year:
| Establishment | What must be submitted electronically |
|---|---|
| 250+ employees in industries covered by routine recordkeeping | Form 300A summary data |
| 20–249 employees in designated high-hazard industries (Appendix A) | Form 300A summary data |
| 100+ employees in designated high-hazard industries (Appendix B) | Forms 300, 300A, and 301 — detailed case-level data |
The 2024 rule added the third row. Establishments with 100 or more employees in the industries listed in Appendix B to Subpart E of 29 CFR Part 1904 — including food and beverage manufacturing, plastics product manufacturing, hospitals, and waste treatment facilities — must now electronically submit the case-level detail from their 300 logs and 301 reports, not just the annual summary totals.
Two operational points matter here:
OSHA accepts data only through the ITA. The agency does not accept completed paper forms by mail or electronic forms by email. Submission means uploading through the ITA portal (by manual entry, CSV upload, or API).
"Establishment" means the physical location, and employee count is measured per establishment. A company with 5,000 total employees spread across small sites may have no establishment that meets a threshold; a single 120-person plant in an Appendix B industry triggers the full case-level submission. Companies regularly misjudge this by counting at the enterprise level instead of the site level.
The key 2026 dates to put on the calendar:
| Date | Action |
|---|---|
| February 1, 2026 | Complete and certify 2025 Forms 300, 300A, and 301 |
| February 1 – April 30, 2026 | Post the certified 2025 Form 300A in the workplace |
| March 2, 2026 | Submit covered 2025 data electronically through the ITA |
The Most Common OSHA Recordkeeping Mistakes
Recordkeeping citations rarely come from missing forms — they come from wrong decisions and broken processes. The same patterns appear across industries and are predictable enough to audit yourself against.
Misclassifying recordable vs. first aid. The most frequent substantive error. Treating a recordable case as first aid (under-recording) creates citation exposure; the reverse inflates your TRIR and DART rates and can affect insurance and bidding. The fix is a documented first-aid reference and a consistent decision process, not individual memory.
Missing the 7-day Form 301 window. Organizations log the case on the 300 but never complete the matching 301 incident report, or complete it weeks later. The 7-calendar-day requirement is specific and easy to miss when investigation drags.
Certifying without executive sign-off. The 300A certified by the safety coordinator rather than a company official does not meet the requirement. This is a documentation defect auditors catch immediately.
Not posting "zero." Establishments with no recordable cases assume there is nothing to post. The 300A must still be posted from February 1 to April 30, showing zeros.
Counting employees at the wrong level for electronic submission. Using enterprise headcount instead of per-establishment headcount causes both missed submissions and unnecessary ones.
Inconsistent day counts. Days-away and restricted-day counts that are estimated, capped incorrectly, or not updated as a case evolves produce a log that does not reconcile. Counts are based on calendar days and have a 180-day cap per case.
No retention discipline. OSHA records must be retained for 5 years following the end of the calendar year they cover, and updated during that period if new information about a case emerges. Logs that are archived and never revisited miss required updates.
Treating recordkeeping as separate from investigation. When the log entry lives in one system and the investigation in another, the rationale behind each classification is lost. Reconstructing it during an inspection is exactly the scramble that produces errors. Linking each recorded case to its underlying investigation keeps the reasoning attached to the record — the same closed-loop discipline that strong corrective action management depends on.
The financial stakes give these mistakes weight. As of 2026, OSHA penalties reach up to $16,550 per serious or other-than-serious violation, and up to $165,514 for willful or repeat violations. Recordkeeping citations are frequently issued in groups when an inspector finds a systemic pattern rather than a single error.
Frequently Asked Questions
Q. Do small businesses have to keep an OSHA 300 log?
Most employers with 10 or fewer employees at all times during the previous calendar year are exempt from routine recordkeeping, as are employers in certain partially exempt low-hazard industries regardless of size. However, every employer — including exempt ones — must still report a work-related fatality within 8 hours and a work-related hospitalization, amputation, or loss of an eye within 24 hours.
Q. What is the difference between Form 300 and Form 300A?
The Form 300 is the running log with one line per recordable case and its details. The Form 300A is the annual summary that totals those cases by category, is certified by a company executive, and is the document posted in the workplace and submitted electronically by covered establishments. The 300A contains no individual case details.
Q. Who has to submit injury data electronically to OSHA?
As of 2026, establishments with 250+ employees in covered industries and establishments with 20–249 employees in designated high-hazard industries must submit Form 300A data through the ITA by March 2. Establishments with 100+ employees in the Appendix B high-hazard industries must additionally submit case-level data from Forms 300 and 301.
Q. What counts as "medical treatment beyond first aid"?
OSHA maintains a specific, closed list of what qualifies as first aid in 29 CFR 1904.7. Anything not on that list — such as prescription medication, sutures, or physical therapy beyond a single visit — is considered medical treatment beyond first aid and makes a work-related case recordable.
Q. How long must OSHA 300 logs be kept?
OSHA recordkeeping forms must be retained for 5 years following the end of the calendar year that the records cover. During that retention period, you must update the 300 log if you learn of new information that changes a recorded case (for example, additional days away from work).
Key Takeaways
- OSHA recordkeeping under 29 CFR 1904 has three distinct obligations — recording (300 and 301), posting (300A), and electronic reporting (ITA) — and they are not interchangeable.
- A case is recordable when it is work-related and results in death, days away, restricted work or transfer, medical treatment beyond first aid, loss of consciousness, or a physician-diagnosed significant injury or illness.
- The 2024 rule (in effect through 2026) requires establishments with 100+ employees in Appendix B high-hazard industries to submit case-level data from Forms 300 and 301 — not just the 300A summary.
- Key 2026 dates: certify by February 1, post the 300A February 1 to April 30, and submit electronically by March 2.
- The costliest mistakes are classification errors, missing the 7-day Form 301 deadline, certifying without executive sign-off, and disconnecting the log from the investigation that justifies each entry — with penalties up to $16,550 (serious) and $165,514 (willful/repeat) as of 2026.
Related Resources
| Resource | Description | Best For |
|---|---|---|
| OSHA Incident Investigation: A Practical Guide | How to run a defensible investigation behind each recordable case | EHS managers connecting recordability decisions to root cause |
| Corrective Action Management: Stop Losing Track of Your CAPA Items | Building a closed-loop process from finding to verified effectiveness | Teams linking recorded incidents to corrective actions |
| Incident Trend Analysis: Finding Patterns in Safety Data | Turning your 300 log data into actionable seasonal and shift patterns | Safety teams using recordkeeping data beyond compliance |
For organizations where recordkeeping connects to broader safety reporting, related tools in the GenbaCompass ecosystem can help. Field teams can streamline hazard and incident intake with near-miss and 4M safety reporting workflows (AnzenPost Plus), and safety managers focused on prevention can review AI-assisted KY activity and hazard prediction (AnzenAI) to reduce the number of recordable cases in the first place.
Stop reconstructing your 300 log in February. WhyTrace Plus records each incident with its recordability decision, classification, days-away count, and linked investigation in a single auditable record — so your 300, 301, and 300A reconcile by design and your ITA submission is ready on time. Start free with WhyTrace Plus →
Sources:
- 29 CFR Part 1904 — Recording and Reporting Occupational Injuries and Illnesses | eCFR
- OSHA's Recordkeeping Requirements | OSHA
- Injury & Illness Recordkeeping Forms — 300, 300A, 301 | OSHA
- Recordkeeping Final Rule to Improve Tracking of Workplace Injuries and Illnesses | OSHA
- OSHA 300 Log Deadlines and 300A Posting Requirements for 2026 | LP Insurance
- OSHA Recordkeeping Requirements (Updated for 2026) | U.S. Compliance
- New OSHA Rule Expands Scope of Records Required to be Electronically Submitted | Crowell & Moring
- OSHA Penalties 2026: Fine Amounts by Category | OccuPros