OSHA Injury and Illness Recordkeeping is the federal rule that requires many employers to record work-related injuries and illnesses on standard forms, summarize them each year and keep the records available. It protects workers by producing an accurate picture of where and how people get hurt, so employers, employees and OSHA can spot hazards and fix them.
Even employers exempt from keeping the forms must still report fatalities and severe injuries to OSHA, and recordkeeping data feeds the injury rates that customers, insurers and regulators use to judge safety performance.
What Is OSHA Injury and Illness Recordkeeping?
The recordkeeping rule is found at 29 CFR Part 1904, Recording and Reporting Occupational Injuries and Illnesses. Its legal basis is Section 8(c)(2) of the Occupational Safety and Health Act, which directs the Secretary of Labor to require accurate records of work-related deaths, injuries and illnesses other than minor injuries needing only first aid.
Part 1904 covers scope and exemptions, recording criteria, forms, retention, employee access and reporting to the government. The core building blocks are:
- OSHA Form 300, the Log of Work-Related Injuries and Illnesses, a running list of every recordable case at an establishment.
- OSHA Form 300A, the annual Summary of Work-Related Injuries and Illnesses, which totals the log and is posted for employees.
- OSHA Form 301, the Injury and Illness Incident Report, a detailed record of each case.
Employers may use equivalent forms that capture the same information. Records are kept by establishment, meaning a single physical location where business is conducted.
Who Must Comply?
Most private sector employers with more than 10 employees must keep OSHA injury and illness records. There are two partial exemptions:
- Size exemption (1904.1). If your company had 10 or fewer employees at all times during the last calendar year, you do not need to keep the forms. Size is measured by peak employment across the whole company, not per site.
- Industry exemption (1904.2). Establishments classified in certain low-hazard industries listed in Appendix A to Subpart B, such as many offices, retail and professional services, do not routinely keep the forms.
Partially exempt employers must still keep records if OSHA or the Bureau of Labor Statistics asks them in writing to participate in a survey, and every employer must report fatalities, in-patient hospitalizations, amputations and losses of an eye under 1904.39.
Under 1904.31, you record injuries to employees on your payroll and to temporary or leased workers you supervise day to day. OSHA has explained that only one employer provides day-to-day supervision, the one directing the details, means and methods of the work. State Plan states run their own programs and may have additional or different requirements, so check your state plan if you operate in one.
Key Requirements
Deciding whether a case is recordable
Section 1904.4 requires you to record each injury or illness that is work-related, is a new case and meets one or more of the general recording criteria. Work-relatedness is presumed for events or exposures in the work environment, unless one of the nine exceptions in 1904.5(b)(2) applies, such as a commuting crash in the company parking lot, a common cold or flu, or an injury from voluntary participation in a wellness program.
Under 1904.7, a case is a recordable injury or illness if 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, such as cancer, a chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum
First aid vs. medical treatment
The first aid list in 1904.7(b)(5)(ii) is complete: 14 items, including non-prescription medication at non-prescription strength, tetanus shots, cleaning wounds, bandages and butterfly closures, hot or cold therapy, non-rigid supports, finger guards, eye patches and drinking fluids for heat stress. Anything not on the list, such as sutures, prescription medication or rigid splints, counts as medical treatment.
Specific recording criteria
Sections 1904.8 through 1904.12 add rules for particular cases. Contaminated needlestick and sharps injuries are recordable. Hearing loss is recorded when an employee has a Standard Threshold Shift, an average change of 10 dB or more at 2000, 3000 and 4000 Hz, and the total hearing level in the same ear is 25 dB or more above audiometric zero.
Counting days
Count calendar days, not workdays, starting the day after the injury or illness began. You may stop counting days away or restricted days once the total reaches 180 days.
Privacy cases
For privacy concern cases listed in 1904.29(b)(7), such as injuries to intimate body parts, sexual assault, mental illness, HIV, hepatitis or tuberculosis, and contaminated needlesticks, write "privacy case" instead of the employee's name and keep a separate confidential list of names and case numbers.
Timing, Posting and Retention
- Record within 7 calendar days. Enter each recordable case on the 300 Log and complete a 301 within seven calendar days of receiving information that the case occurred (1904.29(b)(3)).
- Review and certify the annual summary. At the end of each year, review the log for accuracy, total it on Form 300A and have a company executive certify it. The certifier must be an owner of a sole proprietorship or partnership, a corporate officer, the highest-ranking company official at the establishment, or that official's immediate supervisor (1904.32(b)(4)).
- Post from February 1 to April 30. Post the certified 300A where employee notices are usually posted, even if you had no recordable cases. Enter zeros in that case.
- Keep records for five years. Retain the 300 Log, privacy case list, 300A and 301 forms for five years following the end of the calendar year they cover. Update the stored 300 Logs when you learn of new cases or changes in outcome during that period (1904.33).
- Give employees access. Employees, former employees and their representatives can request copies of the log, which you must provide by the end of the next business day (1904.35(b)(2)).
- Give OSHA access within four business hours. When an authorized government representative asks for your Part 1904 records, you must provide copies within four business hours (1904.40).
- Submit electronically if covered. Some establishments must also submit their data to OSHA each year by March 2. See OSHA Electronic Injury and Illness Reporting.
Common Violations and Penalties
Frequent recordkeeping problems include:
- Under-recording. Treating prescription medication, physical therapy or work restrictions as first aid.
- Late entries. Logging cases weeks or months after the fact instead of within seven calendar days.
- Missing or uncertified 300A. Forgetting to post the summary, posting it without an executive signature, or taking it down before April 30.
- Not updating day counts. Leaving days away or restricted days unchanged after the employee's situation changes.
- Policies that discourage reporting. Reporting rules that are unreasonable or punitive can be cited under the anti-retaliation provisions.
OSHA's civil penalties are adjusted for inflation. According to OSHA's 2026 penalty memo, there was no inflation increase for 2026, so the maximum for a serious or other-than-serious violation remains $16,550 and the maximum for a willful or repeated violation remains $165,514. Check the current figures on the OSHA penalties page before relying on them.
How to Comply: Step by Step
- Confirm your status. Check your peak company headcount for the prior year and your establishment's NAICS code against the partial exemption list.
- Assign ownership. Name and train a recordkeeper for each establishment.
- Set up a reporting procedure. Tell every employee how to report a work-related injury or illness and that they will not face retaliation for doing so.
- Capture every incident. Collect details on each incident promptly, including treatment, restrictions and time away.
- Make the recordability decision. Apply the work-relatedness, new case and general criteria tests and document your reasoning.
- Record within seven days. Enter the case on the OSHA 300 Log and complete a 301 or equivalent.
- Track case outcomes. Update day counts and case classification as the employee's status changes, up to the 180-day cap.
- Close out the year. Review the log, complete the 300A, get executive certification and post it by February 1.
- Submit and retain. Submit electronically if your establishment is covered and keep all records for five years.
How SMS360 Helps
SMS360's Incident Management module gives teams one place to report incidents from the field, capture injury details and track each case to closure. Mobile access helps employees report promptly, assigned corrective actions keep follow-up on track, and centralized records and dashboards make it easier to review your log, monitor open cases and pull information for annual summaries, audits and OSHA requests.
Frequently Asked Questions
Do small businesses have to keep OSHA injury logs?
Companies with 10 or fewer employees at all times during the previous calendar year are partially exempt and do not need to keep the OSHA 300, 300A and 301 forms. The count is based on total company employment, not each location. They must still report fatalities and severe injuries to OSHA and keep records if OSHA or BLS asks in writing.
How long do I have to record an injury on the OSHA 300 Log?
You must record a case within seven calendar days of receiving information that a recordable injury or illness occurred. If you later learn more, such as additional days away, update the entry. Waiting until the end of the year to record cases is a common violation.
How long must OSHA injury records be kept?
Keep the 300 Log, the privacy case list, the 300A summary and the 301 incident reports for five years following the end of the calendar year they cover. During that time you must update stored logs for newly discovered cases and changes in outcome. You do not have to update the 300A or 301 forms, though you may.
Is a recordable injury the same as a workers' compensation claim?
No. OSHA recordability is based on the Part 1904 criteria, while workers' compensation eligibility is set by state law. A case can be recordable without a compensation claim, or compensable without being recordable.
