What the standard requires
29 CFR Part 1904 requires covered employers to record work-related injuries and illnesses on three forms and to report fatalities and severe injuries directly to OSHA within tight timeframes. Recordkeeping isn't just paperwork — the records drive OSHA inspection targeting, industry benchmarking, and internal safety analysis.
Who must keep records
All employers must report fatalities and severe injuries regardless of size or industry (see below). The recordkeeping requirement (the 300 log) is narrower. Employers are partially exempt from routine recordkeeping if either:
- They had 10 or fewer employees at all times during the previous calendar year, OR
- Their establishment is in a partially exempt industry (specific NAICS codes with historically low injury rates — see 1904 Appendix A).
Partially exempt employers must still report fatalities and severe injuries, and must still respond to OSHA and BLS survey requests.
The three forms
OSHA Form 300 — Log of Work-Related Injuries and Illnesses
One line per recordable case. Includes case number, employee name, job title, date of injury, where the event occurred, description, and classification (death, days away, restricted work, other recordable). Update within seven calendar days of receiving information that a recordable case occurred. Employee names may be omitted on "privacy concern" cases.
OSHA Form 301 — Injury and Illness Incident Report
One form per case with detailed information about the incident: what the employee was doing before the incident, what happened, what the injury or illness was, and what object or substance directly harmed the employee. Must be completed within seven calendar days.
OSHA Form 300A — Summary of Work-Related Injuries and Illnesses
Annual summary of the 300 log. Must be reviewed and certified by a company executive (owner, officer, highest-ranking company official at the site, or immediate supervisor of that official). Posted in a visible location from February 1 through April 30 of the following year, even if there were zero recordable cases.
What counts as recordable
A case is recordable if it is work-related, is a new case, and results in one of the general recording criteria:
- 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.
Additional recording criteria apply to needlestick and sharps injuries, tuberculosis cases, hearing loss meeting specific thresholds, and standard-threshold-shift-related cases.
First aid vs medical treatment
OSHA maintains a specific list of what counts as first aid (not recordable) versus medical treatment (recordable). First aid includes non-prescription medications at non-prescription strength, tetanus immunizations, cleaning/flushing surface wounds, wound coverings, hot/cold therapy, non-rigid supports, temporary immobilization for transport, drilling of a fingernail/toenail to relieve pressure, eye patches, removal of foreign bodies from the eye by irrigation, removal of splinters/foreign material other than in the eye by irrigation/tweezers/cotton swabs/simple means, finger guards, massages, and drinking fluids for relief of heat stress. Anything beyond this list is medical treatment.
Fatality and severe-injury reporting
Every employer — regardless of size or industry — must report:
- Fatality: within 8 hours of the death (or knowledge of a work-related death).
- Inpatient hospitalization, amputation, or loss of an eye: within 24 hoursof the event.
Report by calling the nearest OSHA area office, calling the 24-hour OSHA hotline (1-800-321-OSHA), or using OSHA's online reporting form.
Electronic submission (ITA)
Establishments meeting certain size and industry criteria must electronically submit injury and illness data through OSHA's Injury Tracking Application (ITA) by March 2 each year. As of the 2024 rule update:
- Establishments with 250+ employees in industries covered by routine recordkeeping — submit Form 300A.
- Establishments with 20–249 employees in certain high-hazard industries — submit Form 300A.
- Establishments with 100+ employees in specifically listed high-hazard industries — submit Forms 300, 301, and 300A (case-level detail with employee names).
Check current ITA requirements each year — the list of covered industries has been expanded multiple times.
Retention
Keep the 300 log, 300A summary, and 301 forms for 5 years following the end of the calendar year that the records cover. Update the 300 log during the retention period as newly discovered information about a case becomes available.
Common citations
- 1904.29(b)(3) — failure to enter recordable case within 7 days.
- 1904.32(a) — 300A not certified by company executive.
- 1904.32(b)(6) — 300A not posted February 1 – April 30.
- 1904.39(a) — failure to report fatality/hospitalization within required timeframe.
- 1904.7 — misclassification of recordable cases as first aid.
Documentation checklist
- Current OSHA 300 log for each establishment.
- OSHA 301 (or equivalent) for each recordable case.
- Certified and posted 300A summary (Feb 1 – Apr 30).
- Prior 5 years of 300 / 300A / 301 records.
- Fatality and severe-injury reporting log.
- ITA electronic submission confirmation for covered establishments.
- Written incident investigation records supporting recordability decisions.
Common mistakes we see
- Misclassifying medical treatment as first aid. Prescription-strength medication given even once = medical treatment.
- Not counting restricted-duty days correctly. Counted from the day after the injury; capped at 180 days per case.
- Missing the 8-hour fatality reporting window. The clock starts when you learn of the fatality, not the incident date.
- Executive certification signed by HR or Safety. Must be a company executive as defined in 1904.32(b)(4).
- Forgetting to submit through ITA when the establishment crosses a size or industry threshold.
How CSPC helps
Our Compliance Compass program handles end-of-year 300A preparation, executive certification review, ITA submission support, and recordability determinations for ambiguous cases. During Baseline Blueprint, we audit prior-year logs for classification errors before OSHA does.