OSHA 300, 300A and 301 Recordkeeping
OSHA injury and illness recordkeeping requires most employers with more than 10 employees to log every recordable work-related injury and illness on Form 300, document each one on Form 301, and summarise the year on Form 300A - which must be posted at every establishment from February 1 to April 30, and for many employers electronically submitted to OSHA by March 2.
Two deadlines, six weeks apart, every establishment, every year. Most of the work is not safety work - it's pulling hours and headcount out of your payroll system and reconciling them by location.
Who has to keep these records?
Two separate exemptions, and they work differently.
The size exemption applies company-wide. If your company had 10 or fewer employees at all times during the previous calendar year, you don't keep routine records. The test is peak employment, not an average and not a headcount on a given date - if you hit 11 employees for one week in July, you're covered for the whole year.
The industry exemption applies per establishment. Certain industry classifications are partially exempt regardless of size - offices of physicians, computer systems design, full-service restaurants, gasoline stations, religious organisations and others. Because this test runs establishment by establishment, a single company can have some locations that must keep records and some that don't.
Neither exemption removes the duty to report severe incidents. Every employer, exempt or not, must report:
| Event | Report to OSHA within |
|---|---|
| Work-related fatality | 8 hours |
| In-patient hospitalisation | 24 hours |
| Amputation | 24 hours |
| Loss of an eye | 24 hours |
Whose injuries do you record?
Everyone on your payroll - labour, executive, hourly, salaried, part-time, seasonal and migrant workers. Plus workers who aren't on your payroll at all, if you supervise them day to day.
For temporary agency workers, leased employees and contractor staff, the recording duty follows day-to-day supervision, not the paycheck. If you direct the work, you record the injury - even though that person never appears in your payroll system. If the supplying employer supervises them, they record it. Coordinate so the case is recorded exactly once.
This is the first place recordkeeping and payroll diverge, and it catches employers out constantly.
What are the three forms?
| Form | What it is | When |
|---|---|---|
| 300 | Log of Work-Related Injuries and Illnesses. One line per case: employee, job title, date, location, description, classification, day counts, injury type. | Within 7 calendar days of learning a recordable case occurred |
| 301 | Injury and Illness Incident Report. One per case: treatment details, what the employee was doing, what happened, what the injury was. | Within 7 calendar days |
| 300A | Annual Summary. One per establishment: case counts by classification, total days, counts by injury type, annual average employees, total hours worked. | Posted February 1 - April 30 |
On the 300 Log, classify each case by its most serious outcome only - death, days away, job transfer or restriction, or other recordable. One box, not several.
Electronic and equivalent forms are permitted, as long as they carry the same information, are as readable, and are completed using the same instructions.
What makes an injury recordable?
Three tests, all of which must be met: the case is work-related, it is a new case, and it meets at least one recording criterion.
Work-relatedness is presumed for anything resulting from events or exposures in the work environment. You have to affirmatively rebut it, and the exceptions all turn on the word solely - which is a high bar. The main ones: the employee was present as a member of the general public; symptoms surfaced at work but resulted solely from a non-work cause; voluntary wellness or recreational activity; eating or preparing personal food; personal grooming or self-medication; commuting accidents in a company car park; common cold or flu.
A case is recordable if it results in any one of:
- Death
- Days away from work
- Restricted work or job transfer
- Medical treatment beyond first aid
- Loss of consciousness, any duration
- A significant injury or illness diagnosed by a physician or licensed health care professional
Cancer, chronic irreversible disease, a fractured or cracked bone, and a punctured eardrum are always recordable when work-related.
First aid is a closed list, and this is where most judgment calls go wrong. If a treatment is on the list, it is not medical treatment. If it isn't on the list, it is. Non-prescription medication at non-prescription strength; tetanus shots; cleaning or flushing surface wounds; bandages and wound coverings; hot or cold therapy; non-rigid supports like elastic wraps; temporary immobilisation for transport; draining a blister or relieving nail pressure; eye patches; removing foreign bodies by irrigation or swab; finger guards; massage; fluids for heat stress.
Note the counter-intuitive edges: prescription-strength anything is medical treatment even at a single dose, and a rigid support is treatment while an elastic wrap is first aid.
How do you count days away and restricted days?
- Begin counting the day after the injury. The day of injury is never counted.
- Count calendar days, not scheduled workdays. Weekends, holidays and scheduled days off count if the employee couldn't have worked.
- Cap at 180 calendar days. Once away plus restricted reaches 180, stop counting.
- If the job is permanently modified, the restricted count may stop.
Moving someone to light duty does not remove the case from your DART rate. It moves the case from one column to another, and both columns feed DART.
How are TRIR and DART calculated?
Incidence rate = (Number of cases × 200,000) / Total hours workedThe 200,000 represents 100 employees working 40 hours a week for 50 weeks - so every rate is expressed per 100 full-time-equivalent workers per year.
| Rate | Cases counted |
|---|---|
| TRIR / Total Case Rate | Days away + restricted/transferred + other recordable |
| DART | Days away + restricted/transferred |
The denominator is total hours actually worked - not scheduled hours, not FTE × 2,080. It excludes vacation, sick leave and holidays, and includes overtime. It has to be produced per establishment.
That single number is where most of the year's pain concentrates. It lives in payroll and timekeeping, not in HR, and for salaried-exempt populations there are often no recorded hours at all - forcing an estimate that then has to be defensible.
What does the February 1 posting actually require?
Posting is the last of four steps, and the first three are the ones that get skipped:
- Review the 300 Log and verify entries are complete and accurate, correcting any deficiencies
- Create the annual summary on Form 300A
- Certify it
- Post it, February 1 through April 30, in each establishment, where notices to employees are customarily posted
Certification is restrictive. Only a company executive may sign: an owner, a corporate officer, the highest-ranking company official working at that establishment, or that person's immediate supervisor. A safety manager or HR generalist signing is not compliant unless they occupy one of those roles.
For a multi-site employer, that means chasing signatures from every site leader in January.
Who has to submit electronically, and by when?
The current rules took effect 1 January 2024 and created three tiers. Employee counts here are per establishment, based on peak employment in the previous calendar year.
| Establishment size | Industry test | Must submit |
|---|---|---|
| 19 or fewer | - | Nothing |
| 20-249 | In the designated industry list for this tier | 300A only |
| 250+ | Any industry, if you keep records at all | 300A only |
| 100+ | In the high-hazard industry list added by the 2024 rule | 300, 301 and 300A |
That third tier is what changed in 2024. It covers roughly 129 industry classifications - agriculture, logging, construction, manufacturing, warehousing and transportation, waste management, hospitals and nursing facilities, hotels, food services, and performing arts and amusement.
The window opens 2 January and closes 2 March, for the previous calendar year's data. Submissions go through OSHA's Injury Tracking Application, by webform, CSV upload, or API.
Submissions must include your legal company name. You may code establishment names, but the legal name has to appear.
When submitting 300 and 301 data, exclude employee names, employee addresses, treating physician names, and the name and address of the treatment facility. OSHA doesn't collect them.
Watch the two different employee-count tests. Whether you keep records at all is a company-wide test at 10 employees. What you must transmit is a per-establishment test at 19 / 20 / 100 / 250. Same word, different unit of analysis. Confusing them is the most common structural error in this area.
How long do you keep the records?
Five years after the end of the calendar year the records cover. Four things: the 300 Log, the privacy case list if you have one, the 300A summary, and the 301 reports.
There's an asymmetry that catches people. The 300 Log alone must be actively updated during the retention period - if you discover a new recordable case, or a case's classification changes, you go back and correct the stored Log. The 300A and 301 forms carry no mandatory update duty.
So a case recorded as "other recordable" in year one that becomes a lost-time case in year three requires you to correct an archived Log, potentially five years back.
What are the penalties?
| Violation | Maximum |
|---|---|
| Serious | $16,550 |
| Other-than-serious | $16,550 |
| Posting requirements | $16,550 |
| Failure to abate | $16,550 per day |
| Willful | $11,823 minimum, $165,514 maximum |
| Repeated | $165,514 |
These are 2025 figures, and they are still current - there was no 2026 increase. The annual inflation adjustment did not happen this year, because the inflation data the statute requires wasn't published. Agencies were directed to continue using the 2025 amounts.
Any page telling you OSHA penalties rose in January 2026 is repeating an assumption rather than checking. Recordkeeping citations are usually written as other-than-serious, and the posting line reaches a missing or un-posted 300A directly.
What are privacy concern cases?
Six categories require entering "Privacy Case" instead of the employee's name on the 300 Log, with a separate confidential list linking case numbers to names:
- Injury to an intimate body part or the reproductive system
- Injury resulting from sexual assault
- Mental illness
- HIV, hepatitis or tuberculosis
- A needlestick or sharps injury contaminated with another person's blood
- Any other illness where the employee voluntarily asks that their name be withheld
That confidential list is a second record system that must survive five years and be producible on request.
Where teams actually lose time
Drawing establishment boundaries. An establishment is a single physical location where business is conducted. Locations merge into one establishment only if they're under common management and in close proximity - both, not either. One location splits into two only if each is a distinctly separate business in a different economic activity. Cost centres, payroll locations, legal entities and OSHA establishments are four different groupings that rarely line up. And because the electronic submission thresholds are per-establishment, drawing the boundaries wrong changes which tier each site falls into.
Producing total hours worked per establishment. Actual hours, excluding leave, including overtime, matched to establishment boundaries. This is a payroll extract, and it's the classic handoff failure.
Reclassifying cases across a year end. Only one classification box may be checked. A case that starts restricted and becomes days-away has to be reclassified - with the earlier entry removed - against a Log that may already be archived.
Chasing executive certifications across every site in January.
Frequently asked questions
Do I have to post a 300A if we had no recordable injuries?
Yes. The summary is posted showing zeros. (Verify against current OSHA guidance before relying on this.)
Does the 300A get posted at every location, or just headquarters?
Every establishment, in a conspicuous place where notices to employees are customarily posted.
Can a safety manager sign the 300A?
Only if they're an owner, a corporate officer, the highest-ranking company official at that establishment, or that person's immediate supervisor. Otherwise no.
We're in a partially exempt industry. Do we submit anything electronically?
No. Partially exempt establishments are excluded from electronic submission regardless of size.
Do temporary agency workers go on our log or the agency's?
Whoever supervises them day to day records the case. If you direct their work, it's your log - even though they're not on your payroll.
Is the day of the injury counted as a day away?
No. Counting begins the following day.
Do weekends count toward days away?
Yes, if the employee wouldn't have been able to work. The count is in calendar days.
Does light duty keep a case out of our DART rate?
No. Restricted and transferred days are in the DART numerator alongside days away.
Did OSHA penalties go up in 2026?
No. There was no inflation adjustment this year; the 2025 amounts remain in effect.
How far back do we have to correct records?
The 300 Log must be updated throughout the five-year retention period. The 300A and 301 do not require updating.
This guide is general information about reporting requirements, not legal advice. Verify current deadlines, thresholds and penalty amounts against the issuing agency before you file.