Ten OSHA recordkeeping mistakes that trigger citations

Mistakes 1–3: timing

The deadlines are short and the clocks are unforgiving:

• 1. Recording late. Each recordable case belongs on the Form 300 within 7 calendar days of the employer learning about it. Cases batched quarterly, or reconstructed each January, are individually citable — and the gaps show.
• 2. Missing the severe-injury report clock. A fatality must be reported to OSHA within 8 hours, an in-patient hospitalization, amputation, or eye loss within 24. Recording a case on the log does not discharge the reporting duty — they are independent obligations.
• 3. Letting the log go stale during retention. Records are kept five years, and the Form 300 must be updated during that window as cases evolve — outcome reclassifications and day-count changes included.

Mistakes 4–6: classification

Where the judgment calls go wrong:

• 4. Calling medical treatment "first aid." The first-aid list in 1904.7(b)(5)(ii) is exclusive. Prescription medication, sutures, physical therapy — all medical treatment, all recordable, no matter how minor the injury looks or who provided the care.
• 5. Conflating recordability with compensability. The workers' comp claim decision and the OSHA recording decision use different criteria and different deciders. Waiting for a claim determination to record a case is how 7-day deadlines die.
• 6. Stopping the day counts. Days away and restricted-duty days keep accruing until the employee returns or the count hits the 180-day cap. Counts frozen at the first estimate understate severity and mismatch the medical file.

Mistakes 7–8: privacy and paperwork

The details inspectors check line by line:

• 7. Ignoring privacy cases. For privacy-concern cases (intimate-body-part injuries, sexual assault, mental illness, needlesticks, and similar), the name stays off the log — "privacy case" goes in the name column and the identity lives on a separate confidential list.
• 8. The wrong 300A signature. Certification belongs to a company executive who examined the log. A safety coordinator's signature, however diligent, does not satisfy 1904.32.

Mistakes 9–10: scope

Where multi-site employers slip:

• 9. One log for the whole company. Records are establishment-level. Each covered location keeps its own 300 and posts its own 300A; mobile and short-lived sites roll up to a supervising establishment by rule, not by convenience.
• 10. Skipping the March 2 electronic submission. Establishments covered by 1904.41 must also submit data through the Injury Tracking Application — a paper-perfect log with no ITA submission is still a violation for covered establishments.

The pattern behind all ten

Every one of these is a process failure, not a knowledge failure: facts trapped in inboxes, decisions made ad hoc, artifacts maintained annually instead of continuously. The durable fix is a single incident record feeding the log, the incident report, and the summary — with the recordability decision made once, on time, by someone accountable, and the evidence trail kept.

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