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OSHA Recordkeeping Requirements (Updated for 2015)

Document Number: 183

The Occupational Safety and Health Administration’s (OSHA’s) recordkeeping requirements have been in place since 1971 (29 Code of Federal Regulations CFR Part 1904). These requirements were updated in 2002 to make it easier for employers to comply. Notable changes made included:

  • 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 weekends, vacations and holidays) not just workdays.
  • Establish a procedure for employees to report injuries and illnesses and instruct them on how to make reports.
  • Protect employee privacy by not entering an individual’s 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) certified by a company executive, for three months from February 1 to April 30 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.
2015 Changes

OSHA has updated the recordkeeping rule to include two key changes. The first change updates the list of industries that are exempt from the requirement to routinely keep OSHA injury and illness records due to relatively low occupational injury and illness rates. The previous list of industries was based on the old Standard Industrial Classification (SIC) system and injury illness data from the Bureau of Labor Statistics (BLS) from 1996-1998. As of January 1, 2015, industries will be based on the North American Industry Classification System (NAICS) and injury and illness data from BLS from 2007-2009. As a result of this movement to the NAICS classification some industries that were previously covered will no longer be covered and some industries that were not previously covered will now be covered. It will be important to note the new exemption list of NAICS codes in Appendix A of the revised rule.

The second change expands the list of severe work-related injuries and illnesses that all covered employers must report to OSHA. This revision retains the current requirement to report all fatalities within 8 hours and adds the requirement to report all inpatient hospitalizations, amputations and loss of an eye within 24 hours to OSHA.

Reporting Flowchart

Worker is Injured
Source: OSHA


As an employer, you are classified by OSHA’s 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 the prior two groups.

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 all inpatient hospitalizations and fatalities as required by 29 CFR 1904.39. 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 either of the two groups mentioned above are required to comply with the guidelines of 29 CFR 1904.

OSHA Log 300

The new OSHA 300 log is used by each employer’s 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 log:

  • 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.

Source: OSHA

  1. Employee Report of Injury/Illness: Injury or illness reported assumes the individual reporting the injury or illness is an employee of host employer. If the employee is a temporary employee from a temporary staffing agency, incidents are to be recorded in the 300 log; however, the temporary staffing agency would be responsible for reporting workers’ compensation claims to the carrier.
  2. Occupational Hearing Loss: Defined as:
    1. A change in hearing threshold relative to the baseline audiogram as an average of 10dB or more in either ear at 2,000, 3,000 and 4,000 hertz.
    2. Employee’s total hearing level of 25 dB or more above audiometric zero in both ears at the same hertz levels.
  3. Medical Treatment: The management and care of a patient to combat disease or disorder. It does not include:
    1. Visits to practitioners for observation and/or evaluation only
    2. Diagnostic procedures
    3. First aid
  4. First Aid: Treatments that are considered first aid include:
    1. The use of nonprescription medication at nonprescription strength
    2. Tetanus immunizations
    3. Cleaning, flushing or soaking surface wounds
    4. Use of wound coverings, butterfly bandages, Steri-Strips
    5. Hot or cold therapy
    6. Use of non-rigid means of support
    7. Temporary immobilization devices used to transport victims
    8. Drilling of fingernails or toenails or draining fluid from a blister
    9. Eye patches
    10. Removal of foreign bodies from eye using irrigation or cotton swab
    11. Removal of splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means
    12. Finger guards
    13. Massage therapy
    14. Drinking fluids for relief of heat stress
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 300 Log. 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 of the personal information, shown on the OSHA 300 Log. 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. Zeroes should be entered into all spaces provided on Form 300A.

Commonly Asked Questions
Where can I get a copy of the 300, 301 and 300A forms?
Contact the area OSHA office nearest you, or download the information off of the OSHA Web site at
What is restricted work activity?
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.
Our company is closed on Saturday and Sunday. Do these still need to be counted as days away?
Yes, all calendar days the employee was unable to work including 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.
If an employee is injured and misses the remainder of the work shift, is this a day away?
No, injuries and illnesses are not considered lost-time cases until they affect the employee beyond the day of injury or onset of illness.
How are days away calculated if an employee works a normal shift that is longer than 8 hours?
A single workday for recordkeeping purposes is 12 hours.
How should a partial lost workday be recorded?
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

OSHA FactSheet: Updates to Recordkeeping Rule: An Overview
U.S. Department of Labor
September 2014

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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