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OSHA Record Keeping Requirements

Document Number: 183

OSHA's existing recordkeeping requirements have been in place since 1971, and have long been criticized as being complicated and confusing. In January 2002, OSHAs revised recordingkeeping rule became effective. The revised rule will generate more accurate information about occupational injuries and illnesses, while simplifying the overall recordkeeping system for employers. The rule will also better protect employees rivacy.

Additionally, recent legislation required OSHA to address the recording of needlestick/sharps injuries and Musculoskeletal Disorders (MSDs). The revised recordkeeping standard now provides a provision for recording both needlestick injuries and MSDs.

Like the 1971 rule, employers with 10 or fewer employees are exempt from most requirements of the new rule. However, one fatality or the hospitalization of three or more employees must still be reported to OSHA within eight hours, regardless of the number of workers a business employs.

Old vs. New

The revised recordkeeping standard still requires employers to track, record and report workplace injuries and illnesses. The revision ultimately makes it easier for employers to successfully meet the requirements of this standard. Some notable requirement changes were made to the revised rule:

  • Maintain three recordkeeping forms.
    1. OSHA 300 form: log of work-related injuries and illnesses; simplified and printed on smaller legal sized paper.
    2. OSHA 300A form: summary of work-related injuries and illnesses; a separate form updated to make it easier to calculate incidence rates.
    3. OSHA 301 form: injury and illness incident report.
  • Complete OSHA 301 incident report form, or an equivalent form, for each entry on the OSHA 300 log.
  • Use one set of criteria to record both work-related injuries and illnesses.
  • Record all needlestick and sharps injuries.
  • Record all standard threshold shift (STS) hearing loss cases in a separate column of the OSHA 300 log.
  • Record all MSDs in a separate column of the OSHA 300 log.
  • Record all cases of tuberculosis transmission.
  • Eliminate the term lost workdays and replace with days away or days restricted. Days count-ed are based on calendar days, (including week-ends, vacations and holidays) not just workdays.
  • Establish a procedure for employees to report injuries and illnesses and instruct them on how to report.
  • Protect employee privacy by not entering an individuals name on Form 300 for certain types of injuries/illnesses (e.g. do not describe the nature of sensitive injuries that may reveal the identity of the individual; only give access to the OSHA 301 form, which contains no personal identifiers; remove employees names before providing the data to persons not given access rights under this rule).
  • Post an annual summary (OSHA form 300A) and certification by a company executive, for three months from February 1st to April 30th of each year.
  • Recording of a light-duty or restricted case is clarified.
  • Medical treatment, first aid and restricted work definitions are modified to simplify recording decisions.
  • A significant degree of aggravation must exist before a preexisting injury or illness becomes recordable.

As an employer, you are classified by OSHAs injury and illness recordkeeping requirements into one of three groups: Employers regularly exempt from OSHA recordkeeping, employers exempted from preparing and maintaining injury and illness records and employers that are not classified under groups one or two.

Employers regularly exempt from OSHA recordkeeping includes small businesses with fewer than 11 full- or part-time employees during the previous calendar year and employers classified in low-hazard industries. However, these employers are required to report multiple hospitalizations and fatalities as required by 29 CFR 1904.8. In addition, if the employer is notified in writing by OSHA to participate in a statistical survey, the employer must maintain injury and illness records in accordance with 29 CFR 1904.

Employers exempted from preparing and maintaining injury and illness records includes industries listed in Appendix A of Subpart B of the revised recordkeeping standard.

Employers that are not classified under groups one or two are required to comply with the guidelines of 29 CFR 1904.

OSHA Log 300

The new OSHA 300 log is used by each employers establishment to record and maintain information about employee injuries and illnesses and is now printed on 8 1 /2" x 11" paper. An establishment, as defined by OSHA, is, A single physical location where business is conducted, or where services or industrial operations are performed; the place where employees report for work, operate from or from which they are paid.

The form itself is divided into three general sections: Identity (e.g. name, case number, job title, etc.), Descriptive (e.g. date, injury location, description of incident, etc.) and Classification (e.g. type of injury, days away from work, days on restriction, etc.). The following is a list of guidelines to use for maintaining an OSHA 300 og:

  • Maintain OSHA 300 log on a calendar year cycle (not fiscal).
  • Record cases within seven calendar days of receiving information that a recordable case has occurred.
  • Retain OSHA 300 log for five years following the calendar year to which it relates.
  • Maintain OSHA 300 log during those five years and add or delete cases as necessary.
OSHA Form 301

If an injury or illness is recordable, a supplementary form (e.g. OSHA 301) must be completed. This new form provides more information about the case and is printed on 8 1 /2" x 11" paper. Such information as the events leading up to the injury or illness, body parts affected, object(s) or substance(s) involved, etc., must be included on this form.

The OSHA 301 form is only suggested. A different form may be used if it contains the same information as the OSHA 301 form. Other suitable forms are: state workers compensation reports, insurance claim reports or the employers accident report form.

The following is a list of guidelines to use for maintaining supplementary records:

  • Record cases within seven calendar days of receiving information that a recordable case has occurred.
  • Keep the OSHA 301 form current within 45 days at any given time.
  • Each establishment must maintain an OSHA 301 form or similar form.
  • Retain records for five years following the calendar year to which they relate.
Process to Determine if a Case is Recordable

As an employer, you are responsible for reporting all recordable injuries and illnesses. To help determine if an injury or illness is recordable, refer to the flow chart below. If you are unable to determine if an injury or illness is recordable, call the OSHA area office nearest you.

Figure 1

Medical vs. First Aid Treatment

One of the most confusing aspects of recordkeeping is determining if an injury or illness is recordable, based upon first aid or medical treatment. The revised standard sets new definitions of medical treatment and first aid to simplify recording decisions.

Medical Treatment is defined as:

  • Administering immunizations, such as Hepatitis B or rabies (does not include tetanus)
  • Using wound closing devices, such as sutures, staples, etc.
  • Using rigid means of support to immobilize parts of the body
  • Physical therapy or chiropractic treatment

Medical Treatment does not include:

  • Visits to a physician or other licensed health care professional solely for observation or counseling
  • The conduct of diagnostic procedures, such as X-rays and blood tests, including the administration of prescription medications used solely for diagnostic purposes

First Aid is defined as:

  • Using a nonprescription medication at nonprescription strength
  • Administration of tetanus immunizations
  • Cleaning, flushing or soaking wounds on the surface of the skin
  • Use of wound coverings, such as bandages, Band-Aids, gauze pads, etc.
  • Application of hot or cold therapy
  • Use of any nonrigid means of support, such as elastic bandages, wraps, nonrigid back belts, etc.
  • Use of 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
  • Use of eye patches
  • Removal of foreign bodies from the eye using only irrigation or a cotton swab
  • Removal of splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means
  • Use of finger guards
  • Administration of massage
  • Drinking fluids to relieve heat stress

This is a complete list of all treatments defined as first aid under the revised standard.

OSHA Form 300A (Annual Summary)

The employer is responsible for preparing an annual summary of injuries and illnesses that occurred during the calendar year. The annual summary, OSHA form 300A, displays the totals from columns G through M of OSHA log 300. The summary also displays the calendar year covered, company name and address,

annual average number of employees and total hours worked by all employees covered by the OSHA 300 log. Form 300A is a separate form and does not display any personal information, as shown on OSHA log 300. Form 300A also makes it easier to calculate incident rates. The annual summary must be:

  • Posted by February 1 and remain posted until April 30th
  • Posted in areas where other notices are normally placed
  • Certified (signed) by a company executive, stating that the information is correct and complete to the best of the employers ability
  • Retained for five years following the calendar year to which they relate

If no cases are recorded during a reporting period, a summary must still be posted. Zeros should be entered into all spaces provided on form 300A.

Commonly Asked Questions
Q.   Where can I get a copy of the 300, 301 and 300A forms?
A.   Contact the area OSHA office nearest you, or download the information off of the OSHA Web site at
Q.   What is restricted work activity?
A.   When the employee is kept from performing one or more routine (regularly performed at least once per week) functions of his or her job or when employee is kept from working a full workday. Production of fewer goods or services is not considered restricted work activity.
Q.   Our company is closed on Saturday and Sunday. Do these still need to be counted as days away?
A.   Yes, all calendar days the employee was unable to workincluding weekend days, holidays, vacation days, etc.must be counted. Cap day count at 180 days. The day the illness or injury occurred is not counted as a day away.
Q.   If an employee is injured and misses the remainder of the work shift, is this a day away?
A.   No, injuries and illnesses are not considered lost-time cases until they affect the employee beyond the day of injury or onset of illness.
Q.   How are days away calculated if an employee works a normal shift that is longer than 8 hours?
A.   A single workday for recordkeeping purposes is 12 hours.
Q.   How should a partial lost workday be recorded?
A.   If an employee is unable to work a full workday or shift (beyond the initial day of injury or onset of an illness), the day should be recorded as a job transfer of restriction.


Sources for More Information

Recordkeeping Guidelines for Occupational Injuries and Illnesses
U.S. Department of Labor
O.M.B. No. 1220-029
September 1986

A Brief Guide to Recordkeeping Requirements for Occupational Injuries and Illnesses
U.S. Department of Labor
O.M.B. No. 1220-029
April 1986

Draft OSHA Proposed Rule For Recordkeeping, Reporting Occupational Injuries and Illnesses
U.S. Department of Labor
Docket No. R-02
February 22, 1995

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Please Note:
The content in this newsletter is intended for general information purposes only. This publication is not a substitute for review of the applicable government regulations and standards, and should not be construed as legal advice or opinion. Readers with specific compliance questions should refer to the cited regulation or consult with an attorney.

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