OSHA Recordkeeping: Forms 300, 300A & 301

Keeping records is an essential safety practice. Records help employers understand trends and monitor the effectiveness of their safety programs. When used as part of a complete safety program, recordkeeping is more than simply tracking events. By keeping track of injuries and incidents, recordkeeping can identify problems and help prevent future injuries.

What Incidents Must Be Recorded?

It is important to have a strong understanding of what events constitute recordable injuries and illnesses under OSHA’s standard 29 CFR 1904. For an injury or illness to be recordable, the following questions must be answered affirmatively:

• Did the employee experience an illness or injury?
• Is it a new case?

An injury or illness constitutes a new case if it occurs to an employee with no previously recorded injuries, or no previously reported injuries to the part of the body that is currently affected.

Injuries must also be designated as a new case if an employee receives an injury to the same body part as a previous injury that has completely healed.

• Is the case work-related?

A work-related case is defined as a case in which an exposure or event in the workplace caused or contributed to an injury or illness. The work environment includes all locations where employees are working or are present as a condition of employment. Tools and work-related materials are also considered part of the work environment.

• Does the case fit the recording criteria?

OSHA defines a recordable injury or illness as:

• Any work-related fatality.
• Any work-related injury or illness that results in loss of consciousness, days away from work, restricted work, or transfer to another job.
• Any work-related injury or illness requiring medical treatment beyond first aid.
• Any work-related diagnosed case of cancer, chronic irreversible disease, fractured or cracked bones or teeth, and punctured eardrums.
• Special recording criteria apply to work-related cases involving needlesticks and sharps injuries, medical removal, hearing loss, and tuberculosis.

Form 300

OSHA Form 300, Log of Work-Related Injuries and Illnesses (often referred to as the “OSHA log”), collects and classifies information about work-related injuries and illnesses. For each case, Form 300 records:

• The injured employee’s identification and job title
• The incident date
• A description of the injury (including the affected body part and the object that caused the injury)
• The location at the worksite where the injury occurred
• The severity of the case

Severity falls into one of four categories:

• Death
• Days away from work
• Job transfer or restriction
• All other recordable cases

You must also enter the number of days the injured or ill worker missed work entirely or was on restricted work activity. This includes all calendar days, whether the employee was scheduled to work or not, up to a maximum of 180 days. If new information becomes available, you may update the log by crossing out or correcting entries; you do not need to start a new form.

Form 301

Form 301 is the Injury and Illness Report. This form is completed for each individual case, whereas Form 300 is the overall log. Both forms must be updated as incidents occur. Form 301 must be filled out within 7 days of an injury or illness.

You can complete Form 301 by summarizing information entered on Form 300. If equivalent information already appears on insurance or other internal forms, you do not need to fill out Form 301 separately—provided that all information required by Form 301 is present in those documents.

Form 300A

Form 300A is the Summary of Work-Related Injuries and Illnesses. It summarizes all injury and illness incidents by transferring totals from Form 300. All incidents listed on Form 300 must be counted and listed as totals on Form 300A, even if the total is zero.

Form 300A must contain the signature of a company official verifying that the information has been reviewed and is correct. The company official must be the owner of the company, an officer of the corporation, the highest-ranking company official at the establishment, or that person’s supervisor.

Employee Involvement

For recordkeeping to achieve its intended purpose—identifying the scope of injuries and illnesses so preventive measures can be taken—employees must be involved. This includes training workers to accurately report all injuries and illnesses, no matter how slight, and assuring them that they can report without fear of retaliation.

OSHA’s recordkeeping standard contains provisions that encourage employees to report all relevant information. Employers are forbidden from retaliating against employees who report information to OSHA, whether through firing, demotion, or other means. Employees must be informed that they have this protection. OSHA “It’s the Law” worker protection posters should be posted throughout your facility so workers are aware of their rights.

Submitting Recordkeeping Data

The amount of data that must be submitted to OSHA depends on:

• The size of the company
• The type of industry

• Businesses with 250 or more employees in an industry covered by the recordkeeping regulation must electronically submit information from Forms 300, 300A, and 301.
• Businesses with 20–249 employees in industries with historically high rates of occupational injuries and illnesses must electronically submit information from Form 300A. The complete list of higher-risk industries can be found on OSHA’s website: NAICS codes for electronic submission.
• Businesses that maintain fewer than 20 employees throughout the year do not have to routinely submit information electronically to OSHA, unless OSHA makes a written request.

Data for injuries and illnesses that occurred in 2017 had to be submitted to OSHA by July 1, 2018. Beginning in 2019, data from the previous year must be submitted by March 2 of the current year.

Keeping and Storing Records

Records must be kept for 5 years and posted in a visible location from February 1st to April 30th following the year covered by the summary. Any employee or employee representative has the right to limited access to injury and illness records in a timely manner. This information must be provided by the end of the next business day following the request.

Conclusion

Recordkeeping is an integral part of any workplace safety program. Diligent recordkeeping allows employers to identify potential problem areas and implement necessary safety changes.