OSHA recordkeeping guide: the Part 1904 system, end to end
Short answer
Under 29 CFR Part 1904, many employers with more than 10 employees log each recordable injury or illness on Form 300, file a Form 301 for each, and post a Form 300A yearly. Keep records five years. Report deaths within 8 hours, and hospitalizations, amputations and eye losses within 24.
Most employers over 10 employees must keep records
You must keep records if you had more than 10 employees at any time last year, unless the establishment is in a partially exempt industry. The size test counts the whole company's peak employment. The industry test applies to each establishment, by NAICS code.
The exempt list is Appendix A to Subpart B of Part 1904. In healthcare it includes offices of physicians (6211), dentists (6212) and other health practitioners (6213), outpatient care centers (6214), and medical and diagnostic laboratories (6215).
Hospitals (6221 to 6223) and nursing care facilities (6231) are not on it.
Freestanding surgery centers generally fall under NAICS 621493, inside 6214, so many are partially exempt. Confirm your code with the Census Bureau lookup the rule points to.
Recording a case does not mean anyone was at fault, that a rule was broken, or that workers' compensation applies.
Three forms: 300 log, 301 report, 300A summary
| Form | Name | What it holds | When |
|---|---|---|---|
| OSHA 300 | Log of Work-Related Injuries and Illnesses | One or two lines per recordable case | Within 7 calendar days of learning of the case |
| OSHA 301 | Injury and Illness Incident Report | Details of each case. An equivalent form, such as an insurance form with the missing fields, is allowed | Within 7 calendar days |
| OSHA 300A | Summary of Work-Related Injuries and Illnesses | Totals, average employees and hours worked, certified by a company executive | After year end; post February 1 to April 30 |
Keep a separate log for each establishment expected to run a year or longer. Short-term sites may share one. You may keep records centrally if you can send case information to the central office within 7 days.
Electronic records are fine if they can produce equivalent forms.
The certifier is an owner, a corporate officer, the top official at the establishment, or that person's immediate supervisor. Keep the log, privacy case list, summary and 301 forms five years after the year they cover. Update the log, but not the 300A or 301.
The injury rate most employers quote is cases times 200,000, divided by hours worked. BLS says 200,000 equals 100 full-time employees working 40 hours for 50 weeks. See the TRIR and DART calculator.
Five questions decide if a case is recordable
- Is the person a covered employee?Anyone on your payroll, plus agency or leased workers you supervise daily. Self-employed people and owners of sole proprietorships and partnerships are not covered.
- Is it work-related?Something at work caused or added to it. Work events are presumed work-related unless an exception applies. Examples: a visit as a member of the public, voluntary wellness activity, your own food, off-shift tasks, colds and flu.
- Is it a new case?It is new if the worker had no earlier recorded case of the same type and body part, or had fully recovered.
- Does it meet the general criteria?Death, days away, restricted work or transfer, treatment beyond first aid, or loss of consciousness. Cancer, chronic irreversible disease, a cracked bone and a punctured eardrum count at diagnosis.
- Do special criteria apply?Needlestick and sharps injuries, hearing loss, tuberculosis and medical removal have their own rules.
Mental illness counts only if a licensed professional says it is work-related. A commuting crash on the company lot is also an exception.
OSHA's first aid list is complete
Treatment not on the list is medical treatment, whatever the provider's license. Visits only for observation or counseling, and diagnostic tests such as x-rays and blood tests, are not medical treatment. See first aid and first aid vs medical treatment.
| First aid (not recordable on its own) | Medical treatment (recordable) |
|---|---|
| Non-prescription medication at non-prescription strength | Prescription medication, including advice to use a non-prescription drug at prescription strength |
| Tetanus immunization | Other vaccines, such as hepatitis B or rabies |
| Cleaning, flushing or soaking surface wounds; bandages, gauze, butterfly bandages | Sutures, staples and other wound-closing devices |
| Hot or cold therapy; non-rigid wraps and supports | Rigid supports or devices that immobilize a body part |
| Temporary splints, slings or collars while transporting someone; eye patches; finger guards | Physical therapy or chiropractic treatment |
| Removing splinters or eye foreign bodies by irrigation or swab; draining a blister; massage; fluids for heat stress | Any treatment not on the first aid list |
Example. A nurse hurts a wrist moving a patient. The clinic gives a cold pack and an elastic wrap. That is first aid, so the case is not recordable.
If the clinic instead applies a rigid splint to immobilize the wrist, that is medical treatment, and the case is recordable.
A case that meets a criterion is recordable even if the worker declines the recommended treatment. See recordable vs first aid.
Count days away and restricted days this way
- Start the day after the injury. Count calendar days, weekends included.
- You may stop at 180 days, or if the worker leaves for another reason.
- Record a case that spans two years once, in the year it began.
- Count days a physician recommends, even if the worker comes in.
- Restricted work: a routine function (done weekly) or a full shift is off limits.
- Producing less while doing every routine function is not a restriction.
- For a vague "light duty" note, ask if all routine functions are possible.
Key deadlines at a glance
| What | Deadline | Rule |
|---|---|---|
| Enter case on 300 Log and 301 | 7 calendar days after learning of it | 1904.29(b)(3) |
| Report an employee death to OSHA | 8 hours; only if death is within 30 days of the incident | 1904.39 |
| Report inpatient hospitalization, amputation or loss of an eye | 24 hours; only if it occurs within 24 hours of the incident | 1904.39 |
| Post the annual summary | By February 1; keep through April 30 | 1904.32 |
| Keep records | 5 years after the end of the covered year | 1904.33 |
| Give an employee or representative the 300 Log, or an employee their own 301 | By the end of the next business day | 1904.35 |
| Give a union representative 301 forms | Within 7 calendar days, case description only | 1904.35 |
| Give records to OSHA or other inspectors | Within 4 business hours | 1904.40 |
| Retest hearing loss | Within 30 days; if confirmed, record within 7 days of the retest | 1904.10 |
| Electronic submission, if covered | March 2 of the following year | 1904.41 |
The reporting clock runs from when you or any agent learns of the event and that it was work-related (1904.39(b)(7), (b)(8)). Report by phone to the nearest area office, at 1-800-321-OSHA, or online.
If the area office is closed, use the toll-free line or website, not voicemail or email.
Highway crashes outside construction work zones and incidents on commercial transportation need not be reported, though they may be recordable. See severe injury reporting.
Some employers submit data to OSHA each year
Three groups submit through OSHA's Injury Tracking Application (ITA). Part-time, seasonal and temporary workers count toward headcounts.
- 20 to 249 employees, Appendix A to Subpart E industries: Form 300A data.
- 250 or more employees that must keep records: Form 300A data.
- 100 or more employees, Appendix B industries: 300A, plus 300 and 301 data.
Hospitals, nursing care facilities and many residential care facilities are on both appendices. Partially exempt sites do not submit unless OSHA notifies them in writing.
The window is January 2 to March 2. The ITA takes a web form, CSV upload or API. Data for 2025 was due March 2, 2026. Data for 2026 is due March 2, 2027.
The rule was amended in 2016, 2017, 2019 and 2023, so check OSHA's injury tracking page each January.
Employees may report freely, without retaliation
Give employees a reasonable way to report injuries and illnesses. Tell them how, tell them they have the right to report, and tell them they may not be fired or punished for it.
A procedure is not reasonable if it would deter a reasonable employee from reporting accurately. Section 11(c) of the OSH Act separately protects people who report or ask for records.
Privacy concern cases get "privacy case" in the name column, with a separate confidential list of names.
The rule's list is complete: intimate body parts or the reproductive system, sexual assault, mental illness, HIV, hepatitis, tuberculosis, contaminated needlesticks and sharps injuries, and illnesses where the employee asks for privacy.
Healthcare and other special cases have their own rules
- Needlesticks and sharps. Record every work-related cut from a blood-contaminated sharp, as an injury.
- Sharps injury log. Part 1904 employers also keep one under the bloodborne pathogens standard.
- Splashes. Record as an illness only if it leads to a bloodborne diagnosis.
- Patient injuries. Presumed work-related. See workplace violence reporting.
- Hearing loss. Record a 10 dB average shift at 2000, 3000 and 4000 Hz, at 25 dB total.
- Temporary workers. Whoever supervises them daily records the case, once.
- Several sites. Record it where it happened, or at the home site.
How IncidentKit supports OSHA recordkeeping
OSHA 300, 300A and 301 exports are rolling out. They are not live yet. Today the incident record can hold the facts a recordability decision needs, such as treatment, days away and restricted days. The audit trail shows who decided what and when.
As exports arrive, compliance packets will draw the forms from the same record.
See OSHA 300 log automation and workplace injury reporting. OSHA rules change, so check each requirement against the cited section.
Frequently asked questions
Does my company need to keep an OSHA 300 log?
Probably, if you had more than 10 employees at any time last year and your establishment is not in a partially exempt industry. The size test counts the whole company. The industry test applies by establishment, using NAICS code. Exempt employers must still report deaths, hospitalizations, amputations and eye losses.
What is the difference between OSHA Forms 300, 300A and 301?
Form 300 is the log, one line per recordable case. Form 301 is the incident report with details of each case. Form 300A is the annual summary, certified by a company executive and posted February 1 to April 30. Keep all three for five years.
When must I report a hospitalization or fatality to OSHA?
Report an employee death within 8 hours, and an inpatient hospitalization, amputation or loss of an eye within 24 hours, from when you learn it was work-related. A death counts only if it occurs within 30 days of the incident. The others count only if they occur within 24 hours.
Is a case recordable if the worker only received first aid?
No. A case needing only first aid, with no other criterion such as days away, restricted work or loss of consciousness, is not recordable. OSHA's first aid list is complete. Any treatment not on it, such as prescription medication or sutures, is medical treatment and makes the case recordable.
How long must OSHA records be kept?
Five years after the end of the calendar year they cover. That applies to the 300 Log, the privacy case list, the 300A summary and the 301 forms. Update the log for new cases and changed outcomes. You do not need to update the summary or 301 forms.
When is the OSHA electronic submission deadline?
March 2 of the year after the data year. Data for 2025 was due March 2, 2026, and data for 2026 is due March 2, 2027. Covered employers submit through OSHA's Injury Tracking Application, which opens January 2. Check OSHA's notice each January, because the rules have changed several times.
Sources
- 29 CFR Part 1904, Recording and Reporting Occupational Injuries and Illnesses (eCFR)
- 29 CFR 1910.1030, Bloodborne pathogens, including the sharps injury log (eCFR)
- OSHA, Injury and Illness Recordkeeping and Reporting Requirements
- OSHA, Injury Tracking Application (ITA) Information
- U.S. Bureau of Labor Statistics, Compute nonfatal incidence rates
Reviewed against the sources above on Oct 5, 2026. Rules change: confirm current requirements with the issuing body or your counsel before relying on any summary.
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