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.
References and further reading
Check the current source and your worksite’s requirements before acting.
Frequently asked questions
Make all ten structurally impossible
One incident record, a walked recordability decision with a human in charge, live day counts, privacy-case handling, and per-establishment artifacts — maintained continuously, not each January.