OSHA Recordkeeping Requirements: 300 Log, 301, & 300A Complete Guide

The Foundation of Workplace Safety: Understanding 29 CFR 1904

Few duties carry as much liability for as little attention as OSHA recordkeeping. While HazCom programs often take center stage in safety discussions, the injury and illness records required by 29 CFR 1904 are among the first documents an inspector can ask for, and 1904.40(a) gives you four business hours to produce them.

The Occupational Safety and Health Administration (OSHA) requires most employers with more than 10 employees to keep a standardized set of records documenting serious work-related injuries and illnesses. These records serve three primary purposes. First, they allow employers to analyze their own operations to find and fix hazards. Second, they provide OSHA with data to target inspections and resources. Third, they ensure workers have access to information about the hazards they face.

An inaccurate or missing log is a citable violation. The maximum is $16,550 per serious or other-than-serious violation and $165,514 per willful or repeated violation (29 CFR 1903.15(d), amounts in effect since January 15, 2025). Where the violations are willful, OSHA's egregious policy (CPL 02-00-080, October 21, 1990) can treat each instance as a separate violation with its own penalty. Our Fine Calculator estimates a penalty with the Field Operations Manual method.

This guide covers Forms 300, 301, and 300A, the recordability criteria, and the posting and submission dates, with the paragraph of 29 CFR 1904 behind each rule. Under 29 CFR 1904, a company that had more than 10 employees at any time in the last calendar year, outside the partially exempt industries, enters each new work-related case that meets a general recording criterion on the 300 Log and a 301 within seven calendar days, posts the 300A summary from February 1 to April 30, and keeps these records for five years.

1. Who Must Keep Records: Size and Industry Exemptions

Not every company is required to maintain the 300 Log. OSHA provides exemptions based on two criteria: company size and industry classification.

The "Small Employer" Exemption

Under 29 CFR 1904.1, if your company had 10 or fewer employees at all times during the last calendar year, you do not need to keep OSHA injury and illness records unless specifically asked to do so in writing by OSHA or the Bureau of Labor Statistics (BLS). The count is your company-wide peak employment during the last calendar year, not an average (1904.1(b)(1) and (b)(2)).

The Partial Industry Exemption

Under 29 CFR 1904.2, certain low-hazard industries are partially exempt. This list includes specific retail, service, finance, and real estate sectors. The construction industry (NAICS 23) is not on that list. Regardless of your safety record, if you had more than 10 employees at any time last year, you must maintain these records (1904.1(a)(2)).

Even if you are exempt from routine recordkeeping, you are never exempt from the "Fatalities and Severe Injuries" reporting rule. You must report any work-related fatality within 8 hours and any inpatient hospitalization, amputation, or loss of an eye within 24 hours. A late or missing report is its own violation of 29 CFR 1904.39, cited apart from the hazard that caused the event; see OSHA penalties for construction for the amounts.

2. Defining "Recordable": The OSHA Decision Tree

Under 29 CFR 1904.4(a), you record a case that is work-related, is a new case, and meets a general recording criterion of 1904.7, which means it results in any of the following:

• Death
• Days away from work
• Restricted work or transfer to another job
• Medical treatment beyond first aid
• Loss of consciousness
• A significant injury or illness diagnosed by a physician or other licensed health care professional (PLHCP)

The Work-Relatedness Test

The central question is: Did an event or exposure in the work environment either cause or contribute to the resulting condition, or significantly aggravate a pre-existing condition?

The "Work Environment" is defined as the establishment and other locations where one or more employees are working or are present as a condition of their employment. This includes work-related travel and work performed at home, provided the injury is directly related to the performance of work rather than the general home environment.

Determining Recordability Checklist

• Did the employee experience an injury or illness?
• Is the injury or illness work-related?
• Is the injury or illness a new case?
• Does the injury or illness meet one or more of the "General Recording Criteria" (Medical treatment, lost time, etc.)?

If you are unsure of the exposure risks on your site, use our HazCom Compliance Scorer to evaluate your current hazard communication and safety posture before an incident occurs.

3. First Aid vs. Medical Treatment: The Line in the Sand

Many borderline cases turn on the line between first aid and medical treatment. OSHA provides an exhaustive, "exclusive" list of what counts as First Aid under 29 CFR 1904.7(b)(5)(ii). If a treatment is on this list, it is first aid and not recordable (unless it also involves lost time or restricted duty). If it is not on this list, it is medical treatment.

The First Aid List

• Using non-prescription medication at non-prescription strength.
• Administering tetanus immunizations.
• Cleaning, flushing, or soaking wounds on the surface of the skin.
• Using wound coverings such as bandages, Band-Aids, gauze pads, or butterfly bandages.
• Using hot or cold therapy.
• Using any non-rigid means of support, such as elastic bandages, wraps, or non-rigid back belts.
• Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards).
• Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister.
• Using eye patches.
• Removing foreign bodies from the eye using only irrigation or a cotton swab.
• Removing fragments from areas other than the eye by irrigation, tweezers, cotton swabs, or other simple means.
• Using finger guards.
• Using massages.
• Drinking fluids for relief of heat stress.

Anything else is medical treatment, except visits solely for observation or counseling and diagnostic procedures such as X-rays and blood tests (1904.7(b)(5)(i)). That includes stitches, a prescription the employee never fills (1904.7(b)(5)(v) makes you record a recommended treatment the employee does not follow), and physical therapy. Our Recordability Decision Tree walks a case through these questions.

Special Recording Criteria (1904.8–1904.11)

A handful of case types carry their own recording rules on top of the general 1904.7 criteria. These are the ones most often missed:

• Needlesticks and sharps (1904.8). Record every work-related needlestick or cut from a sharp object contaminated with another person's blood or other potentially infectious material — no days-away or treatment threshold applies. Enter it as a privacy case (no name on the log; see Section 8).
• Medical removal (1904.9). If an employee is medically removed under the medical-surveillance provisions of an OSHA health standard (lead, cadmium, benzene, and others), record it as a days-away or restricted case. If a chemical exposure prompted the removal, also check the poisoning column.
• Occupational hearing loss (1904.10). Record a work-related hearing-loss case when the audiogram shows both: a Standard Threshold Shift (STS) — an average change of 10 dB or more at 2000, 3000, and 4000 Hz in either ear from baseline — and a total hearing level of 25 dB or more above audiometric zero (averaged at those same frequencies) in that ear. You may age-adjust when checking the STS, but not when checking the 25-dB level.
• Tuberculosis (1904.11). If an employee is occupationally exposed to a person with a known case of active TB and then develops a TB infection (a positive skin-test conversion or a physician's diagnosis), record it in the respiratory column. A pre-employment positive test is not recordable — no workplace exposure had occurred yet.
• Musculoskeletal disorders (MSDs). There is no separate MSD column on the 300 Log — OSHA rescinded that requirement (former §1904.12 was deleted). Record an MSD like any other case: if it meets a 1904.7 criterion (days away, restriction, or treatment beyond first aid), it goes on the log.

4. Form 300: The Log of Work-Related Injuries and Illnesses

The OSHA 300 Log is your master list of all recordable incidents for the year. Each entry must be made within seven (7) calendar days of receiving information that a recordable case has occurred (1904.29(b)(3)).

Column-by-Column Guidance

• Column A (Case Number): Use a unique identifier (e.g., 2026-001).
• Column B (Employee Name): Except in privacy cases (see Section 8).
• Column C (Job Title): Be specific (e.g., "Journeyman Electrician" not just "Worker").
• Column D (Date of Injury): The date the incident occurred or the illness was first recognized.
• Column E (Location): Where exactly on the site did it happen? (e.g., "North Loading Dock").
• Column F (Description): Describe the injury, body part affected, and the object/substance that directly injured the person. (Example: "Laceration to left index finger from circular saw").

Classifying Outcomes (Columns G through J)

You must check only one of these boxes based on the most serious outcome of the case:

• G (Death)
• H (Days away from work)
• I (Job transfer or restriction)
• J (Other recordable cases) - Use this for medical treatment beyond first aid where the employee returned to full duty immediately.

Tracking Days (Columns K and L)

When counting days away or days restricted, you count calendar days, including weekends, holidays, and vacation days. The count begins the day after the injury occurred (1904.7(b)(3)(i)). There is a cap of 180 days (1904.7(b)(3)(vii)) — once a case reaches 180 days away, restricted, or transferred in any combination, you may stop counting and enter 180.

What if the employee leaves the company while you're still counting?

The count doesn't automatically run to 180. The rule is asymmetric, and it turns on why the employee left:

• They left for a reason unrelated to the injury — retirement, a plant closing, taking another job. Then you may stop counting on the day they leave. That is 1904.7(b)(3)(viii), verbatim: "if the employee leaves your company for some reason unrelated to the injury or illness, such as retirement, a plant closing, or to take another job, you may stop counting days away from work or days of restriction/job transfer."
• They left because of the injury or illness. Then you do not stop: 1904.7(b)(3)(viii) says "you must estimate the total number of days away or days of restriction/job transfer and enter the day count on the 300 Log," and OSHA's FAQ 7-21 frames that estimate as the count "expected for the particular type of case."

The arithmetic trap. Even in a shortened window, the day of the injury never counts (1904.7(b)(3)(i) — the count begins the day after). Worked example: injured March 1, quits (unrelated) effective March 10. The count starts the day after the injury and stops at the departure, so count March 2 through March 9 — 8 days, not 9, and not "whatever was typed in the form." If your software or spreadsheet counts the injury day inside that truncated window, every terminated-employee case on your 300 Log is off by one.

One more edge worth checking in whatever tool you use: a termination date earlier than the injury date is impossible data. It should be rejected loudly — not silently accepted while the days-away count quietly keeps running. (Our free OSHA 300A auto-filler totals the log columns for you — and the day-count arithmetic above is exactly what it expects to find in columns K and L.)

HazComFast does this count on the server: the day of injury never enters the total, an unrelated departure stops the clock on the departure date, and a termination date earlier than the injury is refused outright instead of quietly skewing every case on your log. Use the free toolsLog in.

Column M: Injury or Illness Type

After you classify the outcome in columns G–J, you check one box in Column M for the case type: (M1) injury, or one of five illness categories — (M2) skin disorder, (M3) respiratory condition, (M4) poisoning, (M5) hearing loss, or (M6) all other illnesses. Most construction cases are injuries (M1); the illness boxes matter for exposure cases like dermatitis, silica-related respiratory disease, lead poisoning, or a recordable hearing-loss shift.

5. Form 301: Injury and Illness Incident Report

While the 300 Log is a summary list, Form 301 is the detailed deep-dive for each individual case. Under 29 CFR 1904.29, you must complete a 301 for every recordable entry on your 300 Log, or an equivalent form such as an insurance first report of injury that carries the same information (1904.29(b)(4)).

Key Data Requirements

Form 301 asks for details that go beyond the log:

• What was the employee doing just before the incident?
• What happened?
• What was the injury or illness?
• What object or substance directly harmed the employee?

A 301 for a fall or an eye injury is a good moment to update your Fall Protection Plan Builder or revisit your PPE Selector choices. You must keep 301 forms on file for five years following the end of the calendar year that these records cover (1904.33(a)).

6. Form 300A: The Annual Summary

The 300A is the "Summary" page that totals all the data from your 300 Log. Even if you had zero injuries for the year, you must still fill out and post the 300A, entering zeros in each column total (1904.32(b)(2)(i)).

Mandatory Posting Requirements

• Dates: The 300A must be posted from February 1 to April 30 of the following year (1904.32(b)(6)).
• Location: It must be posted in a conspicuous place where notices to employees are customarily posted (e.g., breakroom, safety board), and not altered, defaced, or covered (1904.32(b)(5)).
• Certification: A company executive must certify the 300A (1904.32(b)(3)): an owner (sole proprietorship or partnership only), an officer of the corporation, the highest-ranking company official working at the establishment, or that official's immediate supervisor (1904.32(b)(4)).

To check the rest of your site before an unannounced visit, review how to prepare for an OSHA HazCom inspection.

Turning the 300A Into an Incident Rate (TRIR & DART)

The 300A totals also give you two incidence rates. Both use the same formula, (cases × 200,000) ÷ total hours worked, with the hours taken from the 300A (1904.32(b)(2)(ii)), where 200,000 is the hours 100 full-time employees work in a year (the standard base):

• TRIR (total recordable incident rate) counts every recordable case — 300 columns G + H + I + J.
• DART (days away, restricted, or transferred) counts only the more serious cases in columns H + I.

For worked examples, where to find "hours worked," the under-100-employee myth, and how to benchmark against your industry, see the full guide: How to Calculate TRIR & DART from the 300 Log.

7. Electronic Submission (ITA Portal)

29 CFR 1904.41 sets who must submit records electronically to OSHA’s Injury Tracking Application (ITA).

Who Must Submit?

1. Establishments with 100+ employees in an industry on Appendix B to Subpart E submit their 300 and 301 data (1904.41(a)(2)). From construction, only NAICS 2381 (foundation, structure, and building exterior contractors) is on that list.
2. Establishments with 20-249 employees in an industry on Appendix A to Subpart E, which lists all of construction (NAICS 23), submit their 300A data (1904.41(a)(1)(i)).
3. Establishments with 250+ employees that must keep records submit their 300A data (1904.41(a)(1)(ii)).

The deadline for electronic submission is March 2 each year for the previous year’s data (1904.41(c)). If you are struggling with the data entry, our OSHA 300A Auto-Filler can help streamline the process.

8. Privacy Cases and Restricted Entries

Under 29 CFR 1904.29(b)(6) through (10), certain cases are designated "privacy concern cases." For these, you do not enter the employee's name on the 300 Log. Instead, enter "Privacy Case" in the name field.

What Qualifies as a Privacy Case? (1904.29(b)(7))

• An injury or illness to an intimate body part or the reproductive system.
• An injury or illness resulting from a sexual assault.
• Mental illnesses.
• HIV infection, hepatitis, or tuberculosis.
• Needle-stick injuries and cuts from sharp objects that are contaminated with another person's blood or other potentially infectious material.
• Other illnesses, if the employee voluntarily requests that their name not be entered on the log (only for illnesses, not injuries).

You must maintain a separate, confidential list of the case numbers and employee names for privacy concern cases so that they can be identified if necessary (1904.29(b)(6)).

9. Multi-Employer Worksites: Who Records the Injury?

In construction, worksites often have a General Contractor (GC), several subcontractors, and temporary labor agencies. This creates confusion regarding who is responsible for recording an injury.

The "Day-to-Day Supervision" Standard

Under 29 CFR 1904.31, the employer who provides day-to-day supervision records the injury or illness: you record cases for temporary or leased workers you supervise day to day (1904.31(b)(2)), and a contractor whose crew works under its own day-to-day supervision records that crew's cases (1904.31(b)(3)).

• Scenario A: A subcontractor's employee is injured while working under the direct supervision of the subcontractor’s foreman. The subcontractor records the injury.
• Scenario B: A temporary staffing agency sends a worker to a GC, and the GC’s site superintendent tells the worker what to do and how to do it. The GC records the injury, as they are providing day-to-day supervision.

10. Recordkeeping Errors to Fix Before an Inspector Finds Them

Under-recording and misclassification are the two families of error. Five to check:

1. Failure to record within 7 days (1904.29(b)(3)): it shows up when medical bills or workers' comp claims are compared with the 300 Log.
2. Counting workdays instead of calendar days (1904.7(b)(3)(iv)): scheduled workdays undercount lost time.
3. Missing executive certification (1904.32(b)(3)): a safety manager who is not one of the four company executives of 1904.32(b)(4) cannot certify the 300A.
4. "First Aid" Misclassification: Recording an injury as first aid when a prescription was issued.
5. Inaccurate NAICS Codes: Using a corporate office NAICS for a high-risk field site to avoid electronic submission requirements.

Each violation can cost up to $16,550 (29 CFR 1903.15(d)(4)), and a willful one up to $165,514 (1903.15(d)(1)); under the egregious policy of CPL 02-00-080, each willful instance can carry its own penalty. The Safety Pays Calculator estimates what the injury itself costs the business.

11. State Plan Variations

While Federal OSHA sets the standard, 21 states plus Puerto Rico (California, Washington, and Michigan among them) run their own State Plans under section 18 of the OSH Act, covering private employers. For recordkeeping the bar is higher than "at least as effective": a State Plan's rules must be substantially identical to Part 1904 (29 CFR 1904.37(a)), with the same rules for which cases are recordable and how they are recorded (1904.37(b)(1)). Other provisions, such as severe-event reporting and record retention, may be more stringent (1904.37(b)(2)).

California is the clearest example: an employer reports any serious injury or illness, or a death, to Cal/OSHA immediately, which means no later than 8 hours after it knows or with diligent inquiry would have known (8 CCR 342(a)), and "serious injury or illness" follows the state definition in 8 CCR 330(h), not the federal 1904.39 list. If you operate in a State Plan state, check its reporting windows before you rely on the federal 8- and 24-hour rules.

12. Digital Solutions and Recordkeeping Best Practices

Paper logs are legally compliant, and OSHA does not mandate software: 1904.29(b)(5) allows a computer system as long as it can produce equivalent forms when they are needed. A digital log adds time stamps and search, and it makes the four-business-hour deadline of 1904.40(a) easier to meet when an inspector asks for five years of records.

Best Practices for Recordkeeping Excellence

• Weekly walk-throughs: ask crews about injuries that never reached the office.
• Chemical exposure cases: name the product on the 301 and pull its SDS, which 1910.1200(g)(8) requires you to keep readily accessible; an SDS QR code on the container links straight to it.
• Monthly Reconciliation: Compare your Workers' Comp "First Report of Injury" list with your OSHA 300 Log to ensure they match.
• Training for foremen: 1904.35(b)(1) requires a reporting procedure that every employee knows about; a Toolbox Talk Generator session on how to report an injury helps you deliver it.

Recordkeeping Maintenance Roadmap

• Yearly: Train all supervisors on the difference between first aid and medical treatment.
• Monthly: Review the 300 Log for completeness and accuracy.
• February 1: Post the 300A Summary.
• March 2: Electronically submit data to the ITA.
• April 30: Remove the 300A Summary from the posting area.
• Ongoing: Keep records for at least five (5) years.

13. The Integration of HazCom and Recordkeeping

Recordkeeping and Hazard Communication (29 CFR 1910.1200) meet on every chemical case. If an employee is injured by a chemical splash, the 301 asks what object or substance directly harmed the employee, so it names the chemical, and your HazCom program must have its SDS (1910.1200(g)(8)).

When an inspector reviews a chemical injury, expect requests for:

1. The 300 Log entry for the injury.
2. The label on the container, including any workplace container label under 1910.1200(f)(6) (secondary container labels: OSHA rules).
3. Evidence that the employee received HazCom training (29 CFR 1910.1200(h)(1)).
4. The SDS for that specific chemical.

Using the GHS Label Generator ensures that your site chemicals are properly labeled, reducing the chance of accidental exposure that leads to a recordable illness.

Conclusion: Reducing Risk Through Rigorous Documentation

An accurate 300 Log is also a diagnostic tool for your business. An accurate 300 Log reveals trends—perhaps your drywall crew has a high rate of eye injuries, suggesting a need for better safety glasses, or your electricians are suffering from heat exhaustion, requiring a revamped hydration plan.

However, the administrative burden is real. Between tracking calendar days, managing privacy cases, and handling electronic submissions, safety managers can easily become overwhelmed.

HazComFast is designed to take the guesswork out of compliance. Whether you need to generate a compliant GHS label, build a complete Hazard Communication plan, or calculate the potential costs of an OSHA fine, our suite of tools is built for the rugged realities of the construction site.

Ready to simplify your compliance?

• Generate your 2026 HazCom Program: HazCom Program Generator
• Audit your HazCom program: HazCom Audit Checklist
• Check your exposure risk: Silica Exposure Calculator

Don't wait for an OSHA inspector to knock on your trailer door: a log that is complete, on time, and certified is the one you can hand over within the four business hours that 1904.40(a) allows.

The hub & related reading: OSHA recordkeeping — 300, 300A & 301 · When is an injury recordable? · The 9 work-relatedness exceptions · Who can see the 300 Log and the 301s · How long to keep each OSHA record

Sources & verification (read on the eCFR, October 5, 2026): recordkeeping duties per 29 CFR 1904.1, 1904.2, 1904.4, 1904.5, 1904.7, 1904.29, 1904.31, 1904.32, 1904.33, 1904.35, 1904.37, 1904.40 and 1904.41 and its appendices; the first-aid list per 1904.7(b)(5)(ii); severe-event reporting per 1904.39; penalty maximums per 29 CFR 1903.15(d); 29 U.S.C. 666(g); OSHA Instruction CPL 02-00-080 (October 21, 1990); California reporting per 8 CCR 342(a). General guidance, not legal advice.