Injury and Illness RecordKeeping: Tips and Best Practices
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Injury and illness recordkeeping is one of the more complex OSHA regulations that employers must follow. Under OSHA’s recordkeeping requirements, certain covered employers are required to prepare and maintain records of serious occupational injuries and illnesses using the OSHA 300 Log. OSHA will ask for this information during an inspection, and may be required to submit a summary report to OSHA annually. Employers that fail to record injuries and illnesses properly may face heavy fines and increased scrutiny from regulatory authorities.
Join us for an information-packed, 90-minute webinar where we will provide tips to develop and implement an effective program, insight into trends in OSHA enforcement, share commonly overlooked program elements, and so much more!
Proper Recordkeeping Means Understanding:
- Who is an employee, including temporary workers
- What makes a workplace injury or illness recordable
- How to fill out OSHA’s Form 300 Log
- When to finish and post OSHA’s Form 300A Summary of Work-Related Injuries and Illnesses
- When and how to complete OSHA’s Form 301 Injury and Illness Incident Report or equivalent forms
- How long to retain the required records
- When you must produce the records for employees, employee representatives, or government officials
- Who must electronically submit 300A Summary data to OSHA
- The deadlines for electronically submitting data to OSHA
Additional topic areas covered:
• Common violations of the standard (29 CFR 1904)
• Exemptions to the rule
• General recording criteria: recordable vs. non-recordable
• How to avoid recordable incidents while providing appropriate care
• OSHA logs
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Todd B. Logsdon
Todd Logsdon is a partner in the firm’s Louisville office and co-chair of the firm's Workplace Safety and Catastrophe Practice Group. His practice is devoted to advising and representing employers regarding labor and employment law matters.Todd is regarded as a leader on Occupational Safety and He [...]
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Frequently Asked Questions
OSHA's recordkeeping requirements under 29 CFR 1904 apply to most employers with 11 or more employees in industries not classified as partially exempt low-hazard sectors. Partially exempt industries—including many retail, finance, insurance, and real estate sectors—are listed in OSHA's recordkeeping standard appendix and generally do not need to maintain OSHA 300 Logs. However, even exempt-industry employers must report fatalities and in-patient hospitalizations to OSHA and must comply if OSHA or the Bureau of Labor Statistics contacts them requesting participation in an official data collection survey. Covered employers using temporary workers must understand that temporary employees are included in recordkeeping obligations when the host employer supervises them on a day-to-day basis—meaning injuries to those workers belong in the host employer's records, not the staffing agency's. Understanding your organization's NAICS industry classification, applicable employee headcount, and temporary worker status is the essential first step in determining your specific OSHA recordkeeping obligations under the standard.
Under OSHA's general recording criteria, a work-related injury or illness is recordable when it results in: death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or diagnosis by a healthcare professional of a significant injury or illness. The 'work-related' determination is critical: an injury is work-related if an event or exposure in the work environment caused or contributed to the condition, or significantly aggravated a pre-existing condition. First aid treatments are NOT recordable—OSHA defines a specific list of first aid interventions including use of non-prescription medications, cleaning and bandaging minor wounds, applying heat or cold, and using non-rigid means of support. The move from first aid to medical treatment beyond first aid triggers recordability. HR professionals and safety managers frequently struggle with this line: when in doubt, document the situation thoroughly and consult OSHA's recordkeeping regulations or employment counsel before making the determination. Systematic training for supervisors on recordability criteria is the most effective prevention for both over-recording and under-recording violations.
The OSHA 300 Log is the master record of all recordable work-related injuries and illnesses for a calendar year. Each recordable incident must be entered within 7 calendar days of learning it is recordable. The log captures the case number, employee name, job title, date of injury or illness onset, event location, injury/illness description, type of case (days away, restricted work, or other recordable), and number of days away or restricted. The description should be specific and accurate: 'laceration to left index finger from saw blade' rather than simply 'hand injury.' Form 301—the detailed incident record for each case—captures comprehensive information including the employee's personal information, treating healthcare provider, and a narrative description of how the incident occurred. Form 301 must also be completed within 7 calendar days. The Form 300A Annual Summary must be completed, signed by a company executive certifying accuracy, and posted in the workplace from February 1 through April 30 of the following year. All three forms must be retained for 5 years following the calendar year they cover, and must be provided to authorized employees, representatives, and government officials upon request.
OSHA recordkeeping violations under 29 CFR 1904 are among the most frequently cited employer compliance failures. Common violations include: failing to record cases that meet recordability criteria (under-recording), entering inaccurate or incomplete case descriptions, missing the 7-day entry deadline, failing to post the 300A Summary during the required February 1 through April 30 window, not retaining records for the full 5-year period, and failing to provide records to authorized employees or representatives within the required timeframe. Electronic submission failures—not submitting 300A data through OSHA's Injury Tracking Application by the March 2 annual deadline—are increasingly cited as OSHA has expanded electronic reporting requirements. Training gaps are a common root cause: supervisors who don't understand recordability criteria will either over-record or under-record. Establishing a clear internal process—who receives incident notifications, who makes recordability determinations, who enters data within 7 days—and training all supervisors consistently on that process is the most effective prevention strategy for avoiding costly citations and increased enforcement scrutiny.
OSHA has progressively expanded electronic submission requirements for injury and illness data through its Injury Tracking Application (ITA). Currently, covered establishments in high-hazard industries with 100 or more employees must electronically submit Form 300 Log and Form 301 data in addition to the 300A Summary. Establishments with 20 to 99 employees in designated high-hazard industries must submit the 300A Summary electronically. Establishments with 250 or more employees in any industry that is required to maintain OSHA records must also submit the 300A Summary electronically. The submission deadline is March 2 of the year following the data year. Submitting accurate, complete data is critical: OSHA uses this data for enforcement targeting, hazard analysis, and strategic planning. Employers should verify their establishment's NAICS code, employee count, and industry classification annually to confirm whether electronic submission applies. With OSHA's enhanced focus on recordkeeping enforcement and the public transparency created by electronic submission, accurate recordkeeping is not just a compliance obligation—it is a reputational and enforcement risk management priority for every covered employer.