OSHA 300, 300A, and 301 Reconciliation: Find and Correct Discrepancies

An OSHA 300A can add up correctly and still be wrong. A missing case, duplicate entry, incorrect establishment, or misclassified illness can survive a simple column-total check. Reconciliation starts with the underlying cases and ends with the summary, rather than starting with the number the executive is expected to sign.

For an employer required to maintain these records, 1904.32(b)(1) requires year-end review of the Log as extensively as necessary to make it complete and correct. The procedure below turns that review into a case-to-form comparison. A separate reconciliation worksheet is a recommended control. OSHA doesn't prescribe a form for it.

Download the cross-form reconciliation worksheet (Word). It includes a case review record, rollup checks, correction trail, and the worked dataset below. This is an editable review document, not an Excel calculator or an official substitute for the OSHA forms.

Know which information should match

Under 1904.29(a), the Log, annual summary, and incident report perform different functions. Form 300 lists recordable cases and outcomes. Form 301 records the required incident information for each case, or an acceptable equivalent does. Form 300A summarizes the Log and adds establishment and employment information.

Do not expect every field to appear on every form. The objective is a consistent relationship, not three identical documents. A workers' compensation report may serve as an equivalent 301 only if it meets the applicable equivalency requirements; the existence of a claim file alone is insufficient.

Set the establishment, year, and review date

Identify the establishment and recording year before comparing cases. 1904.30 addresses separate establishment records and specified short-term establishment arrangements. 1904.31 addresses covered employees, including relevant day-to-day supervision questions. Company-wide totals do not automatically belong on a single establishment's summary.

Use the same review date for the documents being compared. A current Log may legitimately differ from a stored summary prepared earlier, because 1904.33 treats later updates differently. Preserve which version was reviewed instead of changing old records merely to make every historical total look identical.

Limit access to the information needed for the review. Forms 301 and confidential privacy-case lists contain information that should not be copied into a broadly distributed management spreadsheet or posted with the summary.

Reconcile cases before reconciling totals

Compare the recording determinations and incident information with the Log. Account for every recordable case and for any report still awaiting a supported determination. A report in an inbox is not proof that no case occurred. Apply 1904.4 and the relevant criteria rather than using a claims-payment decision as the recording test.

Match each case to its 301 or equivalent. Use a controlled case identifier, but investigate actual inconsistencies rather than assuming matching IDs prove everything. Look for missing reports, duplicate Log entries, one incident mistakenly counted twice, and separate cases incorrectly combined.

Under 1904.29(b)(3), the Log entry and incident report generally must be completed within seven calendar days after receiving information that a recordable injury or illness occurred. A year-end review is a check on that process, not permission to defer recording until year end.

For privacy-concern cases, apply the specified 1904.29(b)(6)–(9) provisions. Enter “privacy case” in place of the name where required and maintain the separate confidential identification list. An employee's request does not make every injury a privacy case; apply the rule's actual categories, including its provision for other illnesses when the employee independently and voluntarily requests that the name not be entered.

Check the outcome box and both day columns

The official OSHA forms and instructions distinguish the case's most serious outcome from its day counts. Select one outcome among Log columns G through J: death, days away, job transfer or restriction, or another recordable case.

A case can have both days away and restricted days. If days away is the most serious outcome, classify the case in H while retaining the appropriate counts in K and L. Do not count it once in H and again in I. Do not erase its restricted days merely because H is checked.

1904.7 supplies the counting rules. Begin after the incident day, apply the calendar-day provisions and relevant qualifications, and account for the combined 180-day cap where applicable. A payroll absence total is not automatically the OSHA count; the reviewer needs the relevant injury-related work-status information.

Keep occurrence-year allocation separate from the dates on which days accrue. A case that begins in one year and continues into the next is recorded once in the occurrence year's Log, with the appropriate days. If the worker is still away when the summary is prepared, paragraph (b)(3)(ix) directs an estimate of expected days and later Log updating when the actual count becomes known or reaches the cap.

Worked dataset: reconcile six cases across the forms

The following is a fictional training dataset, not actual employee or facility data. Assume that work-relatedness, new-case status, applicable recording criteria, establishment assignment, and source documentation have been properly determined. All six cases occurred in 2026. Counts shown are the supported totals used for the illustrative annual review.

The correct outcome totals are G = 0, H = 2, I = 2, J = 2. Their sum is 6 cases. The day totals are K = 14 and L = 19. Day totals are not case counts and are not supposed to equal six.

The injury/illness totals are M(1) injuries = 4, M(2) skin disorders = 1, M(3) respiratory conditions = 1, and M(4) poisoning, M(5) hearing loss, and M(6) other illnesses = 0. These type counts also total 6. A case belongs in one type category and one most-serious-outcome category; those are two classifications of the same cases, not twelve cases.

For an optional incident-rate calculation, use the correct numerator and verified hours for the same establishment and population. Do not include rates in the annual summary boxes that call for counts. The recordkeeping hub covers the wider program and related tools. The free OSHA 300 Log Excel template has the Form 300 columns and the 300A totals by formula.

What the reconciliation catches

If 2026-002 has a 301 but no Log entry, restore the missing case relationship and correct the affected H, K, L, and injury totals. Adding only one to the annual case count leaves the day and type fields wrong.

If 2026-003 appears twice on the Log, investigate whether the entries represent a duplicate or truly separate cases under the applicable criteria. A supported duplicate correction changes the rollup; it does not authorize deleting the underlying incident information to conceal the history.

If 2026-004 is placed in the injury type count instead of skin disorders, G through J and the day totals may still be right. The M category reconciliation detects the error. If a privacy designation applies, verify the Log treatment and confidential list separately.

For a cross-year illustration, suppose the nine days for 2026-006 run from December 29, 2026 through January 6, 2027. The nine days remain with the 2026 case. A second 2027 case entry for the same continuing injury would be an error.

Transfer the reviewed Log into Form 300A

Compare G, H, I, J, K, L, and all six M type totals with their corresponding summary fields. Check zeros as actual reviewed values. A missing field should not be filled with zero simply to complete the form.

Then verify the establishment identification, year, annual average number of employees, and total hours worked for the employees covered by the Log. Reconcile the source population and calculation method using the official instructions. A company-wide payroll export that includes other establishments does not establish the required figures for this summary (1904.32(b)(2)).

Under 1904.32(b)(3)–(4), the certifying executive must examine the Log and reasonably believe the summary is correct and complete based on knowledge of the recording process. The signer must qualify under one of the listed categories. A safety-manager title alone does not establish that eligibility. Use the executive review guide for the signer's review responsibilities.

For the 2026 summary, the current federal posting rule (1904.32(b)(6)) produces a February 1 through April 30, 2027 posting period. Electronic submission is a separate obligation with separate coverage. Post the required summary, not the employee-name Log or the 301 reports.

Classify discrepancies before correcting them

Keep the actual discovery and correction dates. Record the original field, corrected field, supporting information, reason, and person making the change. The audit-trail format is a recommendation. A company's internal approval process for corrections is its own procedure; Part 1904 doesn't prescribe one.

Apply the different update rules to a late-discovered case

Suppose the employer learns on March 3, 2027 of an additional recordable injury that occurred in 2026. For this fictional example, assume it is an injury-type case with medical treatment beyond first aid and no days away or restriction, and that no incident report was previously created.

Enter the newly discovered case on the 2026 stored Log under 1904.33(b)(1). Create the required initial 301 or equivalent within the applicable seven-calendar-day period under 1904.29(b)(3). The optional updating of an existing stored 301 does not excuse the initial incident report for a newly recorded case.

The revised Log now has 7 cases: G = 0, H = 2, I = 2, J = 3. K remains 14 and L remains 19. Injury types become 5 injuries, 1 skin disorder, and 1 respiratory condition. The correction changes the case and injury totals without adding days that did not occur.

During the five-year retention period, updating stored 300 Logs is required as specified by 1904.33(a) and (b)(1). Updating stored annual summaries and existing stored incident reports is optional under paragraphs (b)(2) and (b)(3). That distinction does not excuse preparing an inaccurate summary initially or knowingly omitting information available during the required annual review.

OSHA's ITA FAQ says that information already submitted need not be updated, although employers may update it through December 31 of the submission year. The current Log still needs the required update. The update rule for the stored Log does not automatically require amendment of an earlier ITA submission. Initial reporting must meet the applicable 1904.41(a) requirements.

Finish with exceptions resolved or clearly assigned

The review should identify the forms and versions checked, discrepancies found, evidence used, corrections made, remaining determinations, and the person responsible for resolving them. Do not certify an assumption as a reviewed fact or remove a case simply because a carrier denied payment.

Keep the worksheet within appropriate access controls. Record retention and employee or government access remain governed by Part 1904 and other applicable provisions; the reconciliation process should preserve those rights rather than creating a parallel file that hides the current records. The Log correction guide explains the detailed updating process.