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29 CFR 1904: OSHA Injury Recordkeeping

OSHA recordkeeping (29 CFR 1904) explained: who keeps OSHA 300, 300A and 301 forms, what's recordable, reporting deadlines and electronic submission.

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Regulatory citation: 29 CFR Part 1904, Recording and Reporting Occupational Injuries and Illnesses

What Is OSHA's Recordkeeping Rule?

29 CFR Part 1904 requires many employers to record work-related injuries and illnesses on OSHA forms, post an annual summary, report severe injuries to OSHA, and in some cases submit injury data electronically. The records help employers, workers and OSHA spot trends and target prevention.

Why Recordkeeping Matters

Accurate injury records are the foundation of injury rates like TRIR and DART, which customers, insurers and OSHA use to judge safety performance. Recordkeeping violations are also among the most commonly cited OSHA standards, and failing to report a severe injury can lead to penalties on its own.

Core Obligations

1. Keep the OSHA 300, 300A and 301 Forms

Covered employers must record each recordable injury and illness on the OSHA 300 Log and complete an OSHA 301 Incident Report (or equivalent) within seven calendar days of learning about it. Employers with 10 or fewer employees throughout the year, and establishments in certain low-hazard industries, are partially exempt from routine recordkeeping.

2. Record the Right Cases

A case is generally recordable if it is work-related, new, and results in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or a significant diagnosed injury or illness. Specific rules apply to needlesticks, hearing loss and other cases.

3. Post the Annual Summary

The OSHA 300A summary must be certified by a company executive and posted from February 1 to April 30 each year, even if no injuries were recorded.

4. Report Severe Injuries

Employers must report a work-related fatality to OSHA within 8 hours, and an in-patient hospitalization, amputation or loss of an eye within 24 hours.

5. Submit Data Electronically Where Required

Certain establishments must submit injury data to OSHA's Injury Tracking Application each year by March 2, based on establishment size and industry. Some high-hazard industries with 100 or more employees must also submit 300 and 301 case data.

6. Retain Records

Records must be kept for five years following the end of the calendar year they cover, and made available to employees, former employees and their representatives on request.

Common Compliance Approaches

Assign a Trained Recordkeeper

Name one person responsible for recordability decisions, and train them on OSHA's definitions of first aid, medical treatment and work-relatedness.

Capture Every Incident Promptly

Use a single incident reporting system so the seven-day recording window isn't missed and cases are classified consistently.

Audit the Log Before Year End

Review open cases, update days away and restricted days, and confirm the 300A totals before certification.

Example: Recordkeeping in Practice

A warehouse worker cuts a hand and needs stitches at an urgent care clinic. Because stitches are medical treatment beyond first aid, the case is recordable. The safety coordinator enters it on the OSHA 300 Log and completes a 301 form within seven days. Months later, another worker is admitted to hospital overnight after a fall, so the employer also reports the hospitalization to OSHA within 24 hours.

Related regulations: OSHA Emergency Action Plans, OSHA General Duty Clause, RIDDOR incident reporting (UK).

Note: This summary reflects federal OSHA requirements. States with OSHA-approved State Plans may have additional or different requirements. Always check the current regulation text and any state rules that apply to you.

Frequently Asked Questions

What makes an injury recordable to OSHA?

An injury or illness is generally recordable if it is work-related, is a new case, and results in death, days away from work, restricted work or transfer, medical treatment beyond first aid, loss of consciousness, or a significant diagnosed injury or illness such as a fracture. First aid cases, such as bandages or non-prescription medication at non-prescription strength, are not recordable.

Who is exempt from OSHA recordkeeping?

Employers with 10 or fewer employees throughout the previous calendar year, and establishments in certain low-hazard industries listed in the rule, are partially exempt from keeping OSHA injury logs. However, all employers must still report fatalities, in-patient hospitalizations, amputations and losses of an eye.

When must the OSHA 300A be posted?

The OSHA 300A annual summary must be posted in a visible location from February 1 to April 30 of the year following the year covered by the records. It must be certified by a company executive.

This guide is for general information only and is not legal advice. Always check the current text of the regulation with the relevant regulator.

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