OSHA Recordkeeping and Reporting Guidance for Employers, Part I: Foundations of OSHA Injury and Illness Recordkeeping

Employers first determine whether they must keep Occupational Safety and Health Administration (OSHA) injury and illness records and, if so, which forms apply. Most employers must maintain the OSHA Form 300 Log (“Log” or “300”), prepare an OSHA Form 301 Incident Report (301) for each recordable case, and prepare and post the OSHA Form 300A Annual Summary (300A).

Employers with ten or fewer employees in the prior year and those in industries listed in OSHA’s partial-exemption appendix are generally exempt from routine recordkeeping duties but must still report severe events and respond to government data requests, such as those from the Bureau of Labor Statistics (BLS).

Each recordable case must be entered on the Log and documented on a 301 within seven calendar days of receiving information that the case is recordable. Employers must post the 300A from February 1 through April 30 and retain the 300, 300A, and 301 for five years, updating the 300 during that period if new information comes to the employer that suggests an entry was erroneous.

Quick Hits

• Employers must determine if they need to keep OSHA injury and illness records, which include the OSHA Form 300 Log, the OSHA Form 301 Incident Report for each recordable case, and the OSHA Form 300A Annual Summary, which has to be posted from February 1 through April 30.
• Determining whether a case is recordable involves confirming an injury or illness, assessing work-relatedness, identifying if it is a new case, and applying general recording criteria such as death, days away from work, or medical treatment beyond first aid.
• Employers must ensure accurate recordkeeping, involve employees in the process, and provide access to records while maintaining privacy and data integrity, especially for special recordkeeping categories like hearing loss, needlestick injuries, and privacy concern cases.

Determining Whether a Case Is Recordable and Work-Related

Determining whether a case is recordable follows a structured sequence that begins with confirming that an injury or illness has occurred. OSHA defines “injury or illness” broadly as an “abnormal condition or disorder,” acute or chronic, that reflects an adverse change of some significance; normal end‑of‑day fatigue or mood changes are not injuries or illnesses.

Employers next determine work-relatedness under OSHA’s geographic presumption that events or exposures in the work environment are work-related unless a specific regulatory exception applies. Exceptions include symptoms arising at work that result solely from a nonwork event, voluntary wellness or recreational activities, personal tasks outside working hours, personal food consumption, self‑medication for a nonwork condition, and common colds or influenza. Work performed at home is recordable only when the injury or illness occurs while the employee is performing paid work and is directly related to the performance of that work rather than the home environment. OSHA’s website includes many answers to “frequently asked questions” and standard interpretations that help employers determine whether a work-related injury or illness occurred.

New Cases vs. Continuations of Previously Recorded Conditions

If the case is work-related, employers determine whether it is a new case rather than a continuation of a previously recorded condition. A new case exists when the employee has not previously experienced an injury or illness of the same type affecting the same body part, or when the employee had fully recovered, and a new workplace event or exposure caused the condition to recur. Chronic diseases that persist regardless of new workplace exposure are recorded once, while sensitization conditions that flare with new exposures are recorded when those exposures occur. If the case is new and work-related, employers apply the general recording criteria: death; one or more calendar days away from work; restricted work or job transfer; medical treatment beyond first aid; loss of consciousness; or a significant diagnosed injury or illness such as a punctured eardrum, a fractured rib, or a broken toe.

Medical Treatment vs. First Aid

Distinguishing medical treatment from first aid is central to consistent and compliant recordability.

Medical treatment includes the management and care of a patient to combat disease or disorder and excludes diagnostic procedures and observation-only visits. OSHA provides an exclusive list of first aid measures that are never medical treatment, regardless of who provides them.

First aid includes nonprescription medicines at nonprescription strength, cleaning and bandaging wounds, butterfly bandages and Steri‑Strips, hot or cold therapy, non‑rigid supports, temporary immobilization for transport, draining a blister, removing superficial splinters, finger guards, massage as a standalone measure, and drinking fluids for heat stress. Treatments not on the first‑aid list, such as sutures, tissue adhesives, prescription medications, physical therapy, or any wound‑closure device other than butterfly bandages or Steri‑Strips, are medical treatment. The definition of what constitutes first aid tends to shift and narrow over time, so employers are encouraged to review OSHA’s website to ensure that the current definition meets their understanding of the definition.

Counting Days Away and Days of Restriction or Transfer

Counting days away and days of restriction or transfer requires careful application of OSHA’s rules. Employers record calendar days, including weekends, holidays, and vacation days, beginning the day after the incident. If a licensed healthcare professional recommends days away or restricted duty, the employer records the recommended days even if the employee works; if the employee stays out longer than recommended, the employer records only the recommended days. The combined total of days away and days restricted or transferred is capped at 180 for each case. Where providers disagree, employers resolve the difference by selecting the most authoritative recommendation and documenting the basis for that choice. If a recordable injury happens after July 1 of any given calendar year, the count of days away, restricted, or transferred ends at the end of that calendar year.

Special Recordkeeping Categories

Special recordkeeping categories require tailored treatment. Recordable work‑related hearing loss requires both a standard threshold shift under the noise standard and an average hearing level of 25 decibels or more at 2,000, 3,000, and 4,000 hertz in the affected ear. Needlestick injuries or cuts from sharps contaminated with another person’s blood or other potentially infectious materials are recordable as injuries regardless of other criteria, and employers must update the Log if a related infection is later diagnosed. Medical removals required by specific substance standards are recorded as days away or restricted work, as applicable. Privacy-concern cases—including injuries to intimate body parts, sexual assaults, mental illnesses, HIV, hepatitis, tuberculosis, and contaminated sharps injuries—must omit the employee’s name on the Log, with a confidential list maintained to cross‑reference case numbers to names.

Employee Involvement and Access

Employers must also ensure employee involvement and access. Employers must inform employees how to report injuries and illnesses, provide access to recordkeeping forms within specified timeframes, and ensure that reporting procedures are reasonable and nonretaliatory. Employees and their personal representatives may access the Form 301 for that employee’s case, while authorized employee representatives may access the narrative “how the incident happened” portion for cases at the establishment with personal identifiers redacted. Employers must provide records to OSHA and other authorized government representatives promptly upon request.

Key Takeaways

With the definition, work‑relatedness, new‑case status, and recording criteria resolved, employers must translate those decisions into accurate entries on Forms 301, 300, and 300A.

Part II of this series walks through each form, step by step, using information commonly at hand, and explains how to maintain objectivity, privacy, and data integrity as case outcomes evolve.

Ogletree Deakins’ Workplace Safety and Health Practice Group will provide updates on the Workplace Safety and Health blog

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