Who must keep OSHA injury and illness records
Federal OSHA's recordkeeping rule, 29 CFR Part 1904, requires covered employers to record work-related injuries and illnesses that meet one or more recording criteria. Coverage is the first question every employer should settle, because the two exemptions are narrower than most people assume.
The size exemption (29 CFR 1904.1) applies only if the company had 10 or fewer employees at all times during the previous calendar year — counting all employees company-wide, including temporary, seasonal, and part-time workers across every establishment. Crossing to 11 at any point in the year ends the exemption for the following year.
The industry exemption (29 CFR 1904.2) applies to establishments whose primary activity falls in a low-hazard industry listed by NAICS code in appendix A to subpart B. It is establishment-specific: a company can have one exempt establishment and one covered establishment at the same time.
What the exemptions do not cover
Both exemptions are partial. Every employer covered by the OSH Act — regardless of size or industry — must still report severe outcomes to OSHA under 29 CFR 1904.39: a work-related fatality within 8 hours, and an in-patient hospitalization, amputation, or loss of an eye within 24 hours.
Exempt employers must also keep records if OSHA or the Bureau of Labor Statistics asks them to in writing, for example as part of an annual survey.
The three records covered employers maintain
Covered employers keep three related records for each establishment, and each has its own job:
- OSHA Form 300 — the Log of Work-Related Injuries and Illnesses. A running log with one line per recordable case, updated within 7 calendar days of learning about a case.
- OSHA Form 301 — the Injury and Illness Incident Report, one per recordable case, capturing how the incident happened. An equivalent form with the same data fields is acceptable.
- OSHA Form 300A — the annual Summary of Work-Related Injuries and Illnesses, totaled from the log, certified by a company executive, and posted in the workplace from February 1 to April 30.
The recordkeeping calendar
The deadlines repeat every year, which makes them easy to systematize and easy to miss without a system:
- Within 7 calendar days of learning about a recordable case: enter it on the Form 300 log and complete the Form 301 incident report.
- February 1 – April 30: post the certified Form 300A summary for the previous calendar year where notices to employees are customarily posted.
- March 2: establishments covered by the electronic reporting rule (29 CFR 1904.41) submit their data to OSHA's Injury Tracking Application.
- Five years: retain the 300, 300A, and 301 records following the end of the calendar year they cover, and keep the 300 log updated during that period.
Why recordkeeping accuracy compounds
The log is not paperwork for its own sake. Recordkeeping data drives OSHA's programmed inspection targeting, feeds the rates (TRIR, DART) that general contractors and insurers use to prequalify companies, and is often the first document an inspector asks for in an opening conference.
A log maintained continuously — with recordability decided case by case as incidents happen — is also the only reliable way to make the February posting and March submission deadlines without reconstructing a year of history from memory.
Frequently asked questions
Keep the log current without the year-end scramble
SafeGora captures incident facts once, walks the recordability decision with a human in charge, and keeps 300 / 300A / 301 artifacts organized and export-ready all year.