OSHA Recordkeeping and Posting Requirements

The Occupational Safety and Health Act of 1970 requires employers to keep track of serious work-related injuries and illnesses.  The information aids employers, workers, and OSHA to:

• evaluate the safety of a workplace,
• understand industry hazards, and
• implement worker protections to reduce and eliminate hazards in preventing future workplace injuries and illnesses.

The Occupational Safety and Health Administration (OSHA) covers most private sector employers and their workers in all 50 states, the District of Columbia, and other U.S. jurisdictions either directly through federal OSHA, or through an OSHA-approved state program. Those not covered by OSHA include: self-employed workers, immediate family members of farm employers, and workers whose hazards are regulated by another federal agency.

Currently, employers with more than ten employees are required to keep a record of serious work-related injuries and illnesses. Records should be kept on Occupational Safety and Health Administration (OSHA) forms to include:

• Form 300 – Log of Work-Related Injuries and Illnesses,
• Form 301 – Injury and Illness Incident Report, and
• Form 300A – Summary of Work-Related Injuries and Illnesses.

Employers with ten or fewer employees (at all times) during the last calendar year are exempt from keeping Occupational Safety and Health Administration (OSHA) records unless OSHA, the Bureau of Labor Statistics (BLS), or their state safety agency informs the employer in writing that they must keep these records.  Additionally, some lower-hazardous industries, such as schools and many stores, are also exempt from the recordkeeping requirements.

Employers may determine if they are exempt by first determining their North American Industry Classification System (NAICS) code at www.census.gov/eos/www/naics. In the search box for the most recent NAICS codes, enter a keyword that describes the business. Choose the primary business activity that most closely corresponds to the business, or refine the search to obtain choices.  Once viewing the most recent NAICS tables on the U.S. Census Bureau NAICS main webpage, select the two-digit sector code and choose a six-digit industry code to interpret its definition. Once the employer has their NAICS codes, they may use the table on the Occupational Safety and Health Administration (OSHA) website to determine if their industry is either a low-hazard industry https://www.osha.gov/memos/2024-11-14/2024-low-hazard-industries-table, or completely exempt.  An employer may also contact their nearest Occupational Health and Safety Administration (OSHA) office, or state agency for assistance in determining if they are exempt from reporting and recordkeeping requirements.

All recordable injuries and illnesses must be recorded on the appropriate forms, as stated above, within seven-days of the employer learning of the occurrence. An Injury or illness is defined as an abnormal condition, not an exposure, unless it results in signs or symptoms.  Severity criteria that may prompt a recording include:

• death,
• loss of consciousness,
• days away from work,
• restricted work activity or job transfer, and
• medical treatment beyond first aid.

Other recording criteria may include:

• hearing loss,
• tuberculosis,
• medical removal,
• needle stick and sharps injuries, and
• significant diagnosis of an injury or illness.

Simple first aid or minor injuries do not need to be recorded. First aid is typically administered immediately after the injury, often at the incident’s location. However, it may also include one-time, short-term treatment requiring little technology or training.  Medical treatment beyond minimal first aid may require the case to become recordable. All fatalities must be reported to the Occupational Safety and Health Administration (OSHA) within eight-hours and any amputation, loss of an eye, or hospitalization of a worker must be reported within 24-hours.

From February 1^st through April 30^th of each year, employers must post in an area where all employees may review it, the Form 300A – Summary of Work-Related Injuries and Illnesses, which were recorded during the previous calendar year.  The report should be removed after the expiration date, or employers may face fines for having the document posted outside of the designated timeframe.  All records should be maintained at the worksite for at least five-years.  If requested, employers must provide copies of the records to current and former employees, or their designated representatives.

In addition to maintenance and posting requirements, many employers must also electronically submit information from their previous year’s OSHA 300 records directly to the Occupational Safety and Health Administration (OSHA) each year. This information must be submitted using OSHA’s online Injury Tracking Application (ITA) by March 2^nd of each year. Organizations with:

• 20-249 employees in certain industries must submit the 300A Summary Form information,
• 100 or more employees in designated industries must submit some information from the OSHA 300 Log and the 301 form, or
• 250 or more employees in all industries, unless exempt from recordkeeping requirements, must submit 300A Summary Form information.

There is a helpful tool for employers on the OSHA website on how to use the ITA system for reporting titled, An Injury Tracking Application (ITA) User Guide: Instructions for Using OSHA’s ITA to Electronically Submit Injury and Illness Data  www.osha.gov/sites/default/files/ita_user_guide.pdf.

For additional information relating to the Occupational Safety and Health Administration (OSHA), visit OSHA’s website at www.osha.gov, or to read the full OSHA Recordkeeping regulation 29 CFR 1904 follow the link www.osha.gov/laws-regs/regulations/standardnumber/1904/. In addition, for information on OSHA recordkeeping requirements, please contact us at www.newfocushr.com.

Written by:

• Kristen Deutsch, M.B.A., CCP
  President
  02/06/2026

Source:

• Occupational Safety and Health Administration (OSHA) website at www.osha.gov.