OSHA Recordkeeping: How to Fill Out the 300 Log and What Must Be Recorded (2026)

Two questions come up on almost every OSHA audit: what happened, and whether the case is recordable. Those are different questions. A lot of safety managers mix them up, and that confusion leads to bad log entries, missed citations, and sometimes the opposite problem, recording cases that didn’t need to be there.

The OSHA recordkeeping standard sits at 29 CFR 1904. It’s one of the more detailed parts of the OSHA regulations, and it’s the first thing a compliance officer asks for when they walk in the door.

The Three Forms and What Each One Does

OSHA’s recordkeeping system uses three forms. They work together, but they serve different purposes.

Form 300 is the log. You use it to record every work-related injury and illness that meets the recording criteria during the calendar year. Each entry gets a case number, employee name (or a description if privacy applies), job title, date, where the event happened, and what happened. You also mark the outcome: days away, job transfer or restriction, or other recordable.

Form 301 is the incident report. For every case that goes on the 300 log, you fill out a 301 too. It captures more detail about the employee, the treatment, and exactly how the injury happened. OSHA allows you to substitute an equivalent state workers’ compensation first-report form if it captures all the same information. But you still need one per recordable case.

Form 300A is the annual summary. At the end of each year, you tally the 300 log entries and post the 300A. It covers total injury and illness counts by type, along with the hours worked and average employment figure needed to calculate your incidence rate.

None of these forms get sent to OSHA as a matter of routine. They are internal documents. Reporting to OSHA, when it’s required, is a separate process entirely.

The Recordability Decision

Every case follows the same three-part test from 29 CFR 1904.

First: Is it work-related? OSHA presumes that any injury or illness that occurs in the work environment is work-related. The work environment includes anywhere the employee is present as a condition of employment. That presumption can be rebutted, but you have to make that call consciously and document your reasoning.

Second: Is it a new case? This matters for recurring conditions. If an employee had a prior injury and it flares up again, you need to determine whether this is a new event or a continuation of the old one.

Third: Does it meet any of the general recording criteria?

Work-relatedness is where most disputes happen. OSHA lists specific exceptions in 1904.5(b)(2). An injury isn’t work-related if it resulted from a personal task unrelated to employment. It isn’t work-related if it resulted from voluntary participation in a wellness program or personal grooming. The common cold or flu, mental illness without a formal diagnosis, and injuries from car accidents in a parking lot that the employer doesn’t control are also excluded.

Where it gets harder is in the gray areas. An employee slips on ice in the company parking lot. Work-related? Under OSHA’s rule, injuries in employer-controlled parking lots on the way to or from work are generally not work-related. But if the employee was traveling between worksites, it’s different. Read the exceptions carefully before you make the call, and document your reasoning either way.

What First Aid Actually Means

OSHA’s definition of first aid isn’t the layperson’s definition. It’s a specific list in 29 CFR 1904.7(a), and only the items on that list count as first aid for recordability purposes.

The list includes: non-prescription medication at non-prescription strength, tetanus immunizations, one-time cleaning of a wound, draining a blister, use of bandages and eye patches, use of non-rigid supports like elastic bandages, removal of foreign bodies from the eye with irrigation or a cotton swab, simple removal of splinters, use of a finger guard, and use of a breathing device as a precaution.

If the treatment is on that list, and it’s the only treatment the employee received, the case is not recordable on that basis alone. It may still be recordable if the employee lost consciousness or had days away, but the treatment itself doesn’t trigger recording.

What crosses the line: any prescription medication at any dose, sutures, physical therapy, specialist referrals, x-rays used diagnostically (x-rays to rule out fracture when fracture isn’t found are first aid, but that’s a narrow exception), and any custom-fabricated orthotic device.

This is the most common place to get it wrong. A supervisor takes an injured worker to urgent care. The provider prescribes a short course of a prescription anti-inflammatory. That’s medical treatment beyond first aid, and the case is recordable even if the employee returned to full duty the next day. The severity of the injury doesn’t determine recordability. The type of treatment does.

What Always Gets Recorded

Six outcomes make a case automatically recordable under 29 CFR 1904.7(a):

Days away from work. Any case where the employee misses a full shift or more after the day of the injury.

Restricted work or job transfer. If the employee came back but couldn’t do their normal job, or was moved to a different assignment because of the injury, it’s recordable.

Medical treatment beyond first aid. Covered above.

Loss of consciousness. Even briefly. Even if the employee felt fine afterward.

Diagnosis of a significant injury or illness by a licensed healthcare professional. This one catches occupational illnesses that might not have an obvious acute event: occupational asthma, occupational hearing loss meeting the threshold criteria, repetitive strain conditions.

Death. Always recordable. Always reported to OSHA separately.

A few conditions have their own criteria. Hearing loss gets recorded when the employee has an annual audiogram that shows a 10-decibel age-corrected shift and the total threshold in either ear is 25 decibels or more above audiometric zero. Needlestick injuries involving contaminated sharps get recorded even without symptoms. Tuberculosis diagnosed after a known occupational exposure is recordable.

The 300A Posting Requirement and Electronic Submission

Every year, you total up your 300 log entries and complete the 300A. A company executive must certify it. “Company executive” means an owner, officer of the corporation, the highest-ranking official at the establishment, or that person’s supervisor.

The 300A goes up on February 1 and stays posted through April 30. It posts at each establishment, in a place where employees can see it. You do this even if you had zero recordables. The form still gets posted, with zeros.

Certain employers also have to submit their 300A data electronically to OSHA through the Injury Tracking Application (ITA) at injurytracking.osha.gov. The submission requirement applies to establishments with 250 or more employees that are covered by OSHA recordkeeping, and to establishments with 20 to 249 employees that fall in specific high-hazard industries. OSHA periodically updates those industry lists, so check the current requirements rather than relying on what applied two or three years ago. Submission is due by March 2 each year for the prior year’s data.

If you’re covered and you don’t submit, that’s a separate recordkeeping citation risk. OSHA has used ITA data to identify employers for targeted enforcement, so the submission requirement has teeth.

Reporting vs. Recordkeeping

These two obligations get mixed up constantly, even by experienced safety managers. They are separate requirements with different deadlines and different purposes.

Recordkeeping is the log. It’s internal documentation. You maintain it. Inspectors can request it. You don’t file it with OSHA unless you’re submitting electronically under the ITA requirement.

Reporting is what happens when something serious occurs. Under 29 CFR 1904.39, you must report to OSHA directly:

Fatalities within 8 hours of learning of the death. The 8 hours starts when you, as the employer, find out, not when the incident happened.

In-patient hospitalizations, amputations, or loss of an eye within 24 hours of learning of the event.

You report by calling OSHA at 1-800-321-OSHA or by using OSHA’s online reporting system. You can also call the nearest OSHA area office directly.

Not every hospitalization triggers the 24-hour report. Only inpatient hospitalization counts. If an employee goes to the emergency room and is discharged, that’s not a reportable hospitalization even though it may well be a recordable case.

Amputations include the loss of any part of a digit, not just a full finger. Eye loss is enucleation or evisceration. These definitions matter.

Common Mistakes

Pressure on supervisors to keep cases off the log is real in a lot of workplaces. The supervisor wants to protect the department’s numbers. The worker wants to keep their record clean. The result is cases classified as first-aid-only when they weren’t, or injury dates that don’t match treatment records.

OSHA knows this. They look at the 300 log against your workers’ compensation records, DART rates against industry averages, and whether your recordable rates have suspiciously sharp drops in specific years or departments. Deliberate under-recording is a serious violation. OSHA can cite you for failing to record, failing to record accurately, or for retaliation that discourages reporting.

Occupational illnesses are under-recorded across most industries. Hearing loss, skin conditions, respiratory conditions, and repetitive strain disorders often don’t make it to the log because they don’t have a single identifiable incident date. But they’re recordable when diagnosed. If your 300 log shows only acute injuries and zero illnesses, that’s a flag.

Both the 300 log and the 301 incident reports are required. Some employers keep good logs but forget the 301s. Others have 301s and incomplete 300 entries. OSHA checks both.

Record retention is five years from the end of the calendar year that the records cover. If someone files a workers’ comp claim after they leave the company, you still need to produce the records if the incident fell within the retention window.

Supervisors who want to do this right should get proper training. The OSHA 30 General Industry course covers recordkeeping at a level that helps supervisors make accurate first-call determinations in the field. Combined with a clear employer safety training program that defines who makes recordability determinations and how to escalate, it reduces the margin for both honest mistakes and deliberate misclassification.

The 300 log isn’t just a regulatory checkbox. Your DART rate (days away, restricted duty, or transfer) and TRIR (total recordable incident rate) are the numbers that tell you whether your safety program is actually working, or just looking good on paper. They’re also what an OSHA inspector asks for first.

Sources: OSHA Recordkeeping Rule, 29 CFR Part 1904 (osha.gov/recordkeeping). Penalty amounts adjust annually under Federal Civil Penalties Inflation Adjustment Act.