OSHA 300 Log and Recordkeeping: A Plain-Language Guide for Small Business Owners

If you employ 10 or more people in most industries, federal law requires you to maintain records of workplace injuries and illnesses. This is not optional, and it is not complicated — but many small business owners either don't know it applies to them, aren't sure what they need to record, or are recording things incorrectly.

This guide explains OSHA's injury and illness recordkeeping requirements in plain language — what the three forms are, what triggers a recordable, and how a proper incident investigation makes the whole process significantly easier and more accurate.

Who Needs to Keep OSHA Records

OSHA's recordkeeping rule (29 CFR Part 1904) applies to most private sector employers with 10 or more employees. However, there are important exemptions:

• Employers with 10 or fewer employees at all times during the previous calendar year are partially exempt from routine recordkeeping — though they must still report severe injuries to OSHA
• Employers in certain low-hazard industries are also partially exempt — OSHA maintains a list of partially exempt industries based on NAICS codes

Partial exemption means you don't have to maintain the OSHA 300 Log routinely — but it does not mean you are exempt from OSHA's severe injury reporting requirements. If a worker is killed, hospitalised, loses an eye, or has an amputation, you must report to OSHA regardless of your size or industry.

If you are unsure whether your business is required to maintain OSHA records, check OSHA's recordkeeping guidance directly or consult a qualified safety professional. The exemptions have specific criteria that a general article cannot cover completely.

The Three OSHA Recordkeeping Forms

OSHA Form 300 — Log of Work-Related Injuries and Illnesses

The 300 Log is a running record of every recordable work-related injury or illness during the calendar year. For each case, you record: the worker's name (or job title if privacy case applies), job title, date of injury or illness onset, where the event occurred, a description of the injury or illness, and the case classification — days away from work, restricted work, job transfer, other recordable case, or illness.

OSHA Form 301 — Injury and Illness Incident Report

For each entry on the 300 Log, you must also complete an OSHA 301 form (or an equivalent workers compensation first report of injury). The 301 is a detailed record of the individual incident — what the worker was doing, how the injury occurred, the object or substance involved, and the nature of the injury. This is where a thorough incident investigation directly contributes: the 301 requires exactly the information a structured investigation generates.

OSHA Form 300A — Summary of Work-Related Injuries and Illnesses

The 300A is an annual summary of the totals from your 300 Log. It must be posted in your workplace from February 1 to April 30 each year, even if there were zero recordable cases. It must be certified by a company executive.

What Makes a Case Recordable

Not every workplace injury is OSHA recordable. A case is recordable if it is work-related, is a new case, and meets one of the following general recording criteria:

• Results in days away from work
• Results in restricted work activity or job transfer
• Requires medical treatment beyond first aid
• Results in loss of consciousness
• Results in diagnosis of a significant injury or illness by a healthcare professional

First aid treatment — defined by OSHA as a specific list of treatments including non-prescription medication, wound cleaning, bandaging, and similar — does not make a case recordable on its own. The distinction between first aid and medical treatment is one of the most common sources of recordkeeping confusion for small businesses.

Work-relatedness is also a specific determination under OSHA's rules — not everything that happens at work is automatically work-related for recordkeeping purposes. OSHA's guidance on work-relatedness covers a range of scenarios including pre-existing conditions, personal tasks, and travel. When in doubt, consult the OSHA recordkeeping rule or a qualified safety professional.

How a Proper Incident Investigation Makes Recordkeeping Accurate

The OSHA 301 form requires information that a structured incident investigation generates as a matter of course:

• What was the employee doing just before the incident? — your incident timeline
• What happened? — your factual incident account
• What was the injury or illness? — your evidence documentation
• What object or substance directly harmed the employee? — your PEEPO evidence analysis

Businesses that investigate well complete their OSHA records accurately and quickly. Businesses that don't investigate — or investigate weeks after the fact — end up with 301 forms that are incomplete, inconsistent with other records, or based on reconstructed accounts that don't match witness statements.

An inconsistent or incomplete OSHA record is a problem if OSHA conducts a programmed or unprogrammed inspection. It is also a problem if the incident results in a workers compensation claim — because the OSHA records become part of the claim documentation.

"Your OSHA 301 and your workers compensation first report of injury are often compared directly. If they tell different stories, someone asks why."

Electronic Submission Requirements

OSHA's Injury Tracking Application (ITA) requires certain employers to electronically submit their recordkeeping data annually. The submission requirements depend on establishment size and industry:

• Establishments with 250 or more employees in industries covered by recordkeeping rules must submit 300A summary data annually
• Establishments with 20–249 employees in certain high-hazard industries must also submit 300A summary data annually
• Establishments with 100 or more employees in certain high-hazard industries must submit 300 Log and 301 form data

Electronic submission requirements have been updated in recent years. Check OSHA's current ITA guidance for the applicable requirements for your establishment size and NAICS code.

Retention Requirements

OSHA requires you to retain your injury and illness records for five years following the end of the calendar year they cover. During that period, you must make them available to current and former employees, their representatives, and OSHA upon request.

Note: This article provides a general overview of OSHA recordkeeping requirements. It does not constitute legal advice. Recordkeeping obligations are specific to establishment size, industry, and individual case circumstances. Consult OSHA's recordkeeping guidance at osha.gov or a qualified safety professional for your specific situation.