It’s That Time of Year Again: OSHA Recordkeeping Season

Effective OSHA recordkeeping does more than meet regulatory requirements. It can:

• Ensure compliance and help reduce the risk of costly penalties.
• Support accurate injury trend analysis for proactive safety improvements.

Whether you operate a single establishment or multiple locations, understanding your obligations is essential. Here’s what employers should know to properly maintain OSHA injury and illness logs and stay prepared for inspections.

Only recordable workplace incidents must be logged.

Not all injuries or illnesses are recordable. An injury or illness becomes OSHA-recordable if it meets one or more of the following:

• Requires medical treatment beyond first aid
• Results in days away from work
• Causes restricted duty or job transfer
• Involves loss of consciousness
• Is a significant diagnosed injury or illness (e.g., cancer, fractured bones, hearing loss)

Accurate classification is critical! Misclassification is one of the most common OSHA recordkeeping violations.

Covered employers must:

• Log recordable incidents within 7 calendar days
• Ensure all required fields are complete and correct
• Attach supporting documentation such as medical reports, supervisor statements, or investigative findings

A consistent recordkeeping process can help improve accuracy and promote reliability during audits.

• Prepare OSHA Form 300A after year-end.
• Have the 300A certified by a company executive.

• Post the 300A summary in a conspicuous location from February 1 – April 30 where employees can easily see it.

  OSHA requires each Establishment—defined as a single physical location where business is conducted—to post its own 300A.

  For operations where employees do not work at a single physical location, the Establishment is the main or branch office that supervises personnel or serves as their base of operations.

• Retain the 300A (along with Forms 300 and 301) for at least five years.
• Ensure all OSHA injury and illness records are stored securely but remain accessible for review.

During an inspection, OSHA will request your current and previous years’ 300A summaries. Employers must provide the information within four business hours.

To prepare:

• Keep records organized in a centralized location
• Ensure staff understand the recordkeeping process
• Maintain supporting documentation for all entries

Proactive organization helps reduce stress and speeds up the inspection process.

Some Establishments must electronically submit OSHA data each year via the OSHA Injury Tracking Application (ITA). The deadline is March 2 for the previous year’s data.

Electronic Submission Requirements:

Form 300A

Establishments with 250+ employees (non-exempt industries), or

Establishments with 20–249 employees in defined industries listed here: https://www.osha.gov/recordkeeping/naics-codes-electronic-submission

Forms 300 and 301

Establishments with 100+ employees and listed here must submit Forms 300, 300A and 301.

Failing to submit electronically when required is a common citation—confirm your NAICS code and stay compliant.

How to report: Use the Injury Tracking Application (ITA)