OSHA Recordkeeping and Reporting Guidance for Employers, Part II: Completing OSHA Forms 301, 300, and 300A

The OSHA Form 301 Incident Report captures the who, what, where, when, and how for each recordable case. Employers typically assemble the required information from supervisor reports, employee statements, timekeeping records, medical work‑status notes, workers’ compensation first reports of injury, equipment logs, and job descriptions.

Quick Hits

• The OSHA Form 301 Incident Report requires detailed documentation of each recordable case, including the sequence and mechanism of injury or illness, and must be updated if the case outcome changes.
• Employers must maintain the OSHA Form 300 Log with unique case numbers, detailed descriptions, and accurate day counts, ensuring privacy for sensitive cases and maintaining separate logs for each establishment.
• The OSHA Form 300A Annual Summary must be reviewed, certified by a company executive, posted from February 1 through April 30, and retained for five years, with electronic submission requirements varying by employer size and industry.

Narrative Description

Employers may want to ensure that the narrative objectively describes the sequence and mechanism of injury or illness without speculating about fault, such as noting that the employee slipped on a wet floor in the packaging area after mopping, fell onto the left wrist, and was diagnosed with a non‑displaced distal radius fracture at an urgent care clinic. Employers may also want to identify the treating provider and facility when known and classify the case according to the most severe outcome known at the time, updating if later developments, such as surgery or extended restrictions, change the outcome category or day counts. Where a workers’ compensation first report captures all required fields, it may serve as an equivalent to Form 301 if completed using OSHA’s instructions.

OSHA Form 300

The OSHA Form 300 memorializes each recordable case and relates to the corresponding 301. Each Form 300 should have a unique case number, and include the employee’s name unless it is a privacy concern case, specify the employee’s job title and department, and the date of the incident. The brief case description should mirror the objective tone of the 301 narrative and identify the location, event, and nature of the injury or illness. Employers may want to note that OSHA periodically cites employers for entries that are too vague.

Employers check only the most severe outcome column known at the time—death; days away; job transfer or restriction; or other recordable case—and enter day counts beginning the day after the incident, using calendar days and capping totals at 180 per case. If a provider recommends days away and the employee works anyway, the Log reflects the recommended days; if an employee stays out longer than medically indicated, the Log reflects only the recommended period. For multi‑establishment employers, each establishment keeps its own Log, and cases are recorded on the Log for the establishment where the employee normally works, with special attention to traveling or temporary assignments. The caveat to this guidance is that geographically close operations can be included on a single Log.

Privacy concern cases require heightened care on the Log. Employers must omit the employee’s name and enter “privacy case” in the name field, ensure the case description conveys cause and severity without disclosing identity, and maintain a separate confidential list that ties case numbers to employee names. Employers must also maintain a sharps injury log if required under the Bloodborne Pathogens Standard, 29 C.F.R. § 1910.1030, which can be satisfied by the OSHA Form 300, provided that the type and brand of device are recorded and records are maintained in a way that segregates sharps cases.

OSHA Form 300A Annual Summary

The OSHA Form 300A Annual Summary aggregates totals and must be reviewed, certified, posted, and, in many instances, electronically submitted. Employers may want to verify each Log entry is complete and accurate, total each column, and calculate the average number of employees and the total hours worked for the year using payroll and HRIS data. A company executive—an owner, a corporate officer, the highest‑ranking official at the establishment, or that official’s direct supervisor—must certify the 300A. Employers must post the certified 300A in a conspicuous location from February 1 through April 30, and they must retain all three forms for five years. During that retention period, the Log must be updated if case outcomes change; the 301 and 300A do not require updating after year‑end.

Electronic submission obligations encompass three regimes that are size‑ and industry‑specific and must be checked annually. Employers with 250 or more employees that are required to keep records must submit 300A data annually by March 2. Employers with 20 to 249 employees in designated industries must also submit 300A data annually by March 2. Beginning with 2023 data due March 2, 2024, and continuing thereafter, certain establishments in designated high‑hazard industries with one hundred or more employees must submit case‑level data from Forms 300 and 301 annually in addition to the 300A. OSHA’s coverage is set by NAICS‑based lists and may be updated over time. As a practical matter, employers may want to confirm their establishments’ NAICS codes and status each January, especially after acquisitions, divestitures, or significant changes in operations.

Employers strengthen reliability and defensibility by building a disciplined internal process around the seven‑day recording window and periodic reconciliations. A practical approach includes a standard intake checklist, immediate retrieval of provider work‑status notes, monthly reconciliation of recommended restrictions and days away with the Log, and a January close process that resolves ambiguous cases before 300A certification. Employers may want to document rationales for work‑relatedness and new‑case determinations, particularly for home‑office injuries, preexisting conditions, and exception scenarios, and retain the basis for resolving conflicting medical opinions.

Key Takeaways

Recordkeeping and reporting are related but distinct obligations. A case may require rapid reporting to OSHA even before all facts are known, and reporting never replaces the duty to evaluate recordability and update the Log and 301.

Part III of this series explains what triggers reporting, how the clock runs, how to report, and where state‑plan rules may differ.

Ogletree Deakins’ Workplace Safety and Health Practice Group will continue this series with a final installment and will provide updates on the Workplace Safety and Health blog as additional information becomes available.

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