OSHA recordkeeping is frequently confused with workers’ compensation and internal incident reporting. They are not the same system. Part 1904 defines which work-related injuries and illnesses are recordable and which employers must maintain OSHA forms.
Employers also need to distinguish recording from reporting. A company may be partially exempt from routine OSHA logs and still have to report certain severe events to OSHA.
Who is partially exempt because of size?
If the company had 10 or fewer employees at all times during the previous calendar year, it generally does not have to keep OSHA injury and illness records unless OSHA or BLS tells it in writing to do so. The size test is based on the entire company’s peak employment during the prior year.
If the company had more than 10 employees at any time during the previous year, recordkeeping generally applies unless the establishment is in a partially exempt industry.
What are Forms 300, 300A and 301?
The running log of recordable work-related injury and illness cases.
Provides additional information about each recordable case, or an equivalent form may be used if it contains the required information.
Year-end summary that covered employers complete, certify and post from February 1 through April 30.
How long are the records kept?
Covered employers must retain the OSHA 300 Log, privacy case list if one exists, 300A Annual Summary and 301 Incident Reports for five years following the end of the calendar year those records cover.
Electronic submission is a separate question
Some establishments must electronically submit injury and illness information to OSHA’s Injury Tracking Application. The thresholds depend on establishment size and industry. Do not assume that keeping an OSHA 300 Log automatically means the same establishment has the same electronic-submission obligation.
Partial exemption does not erase severe-event reporting
OSHA’s small-employer and low-risk-industry partial exemptions do not eliminate the requirement for covered employers to report specified severe events, including work-related fatalities, in-patient hospitalizations, amputations and losses of an eye, under the timing and criteria in 1904.39.
Primary sources
Use the current regulation and agency guidance for decisions about your workplace. These links were reviewed when this resource was published.
Important boundary
This resource is general educational information, not a legal determination that a particular OSHA, state-plan, DOT or other requirement applies to your company. Applicability depends on industry, jurisdiction, tasks, exposures, equipment, employee duties and other facts.