OSHA recordkeeping uses three forms: Form 301 is the incident report you fill out for each recordable case, Form 300 is the running log of all recordable injuries and illnesses, and Form 300A is the annual summary you must post in the workplace from February 1 through April 30.
That is the whole system in one sentence. The hard part is everything around it: whether your plant must keep records at all, which cases are recordable, the 7-day entry clock, and the electronic submission rules that now cover many manufacturers. Each section below links the actual regulation, 29 CFR Part 1904.
Which employers have to keep OSHA injury records?
Most employers with more than 10 employees must keep OSHA injury and illness records. There are two partial exemptions. Under 29 CFR 1904.1 a company that had 10 or fewer employees at all times during the last calendar year is exempt from routine recordkeeping. Under 1904.2 establishments in certain low-hazard industries listed in Appendix A to Subpart B are also exempt. The exemption list is by NAICS code; most manufacturing codes are not on it, so if you run a plant, assume you keep records.
Both exemptions are partial: every employer covered by the OSH Act, however small, must still report severe incidents to OSHA (below), and OSHA or the BLS can notify any employer in writing that it must keep records for a survey year.
Recordable vs. reportable vs. first aid: what's the difference?
These three words carry the whole regulation, and plants mix them up constantly.
Recordable means the case goes on your forms. Under 1904.7 a work-related injury or illness is recordable if it results in death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness, or if a physician or other licensed health care professional diagnoses a significant injury or illness such as a fractured bone or punctured eardrum.
Reportable means you must contact OSHA directly, and the clock is short. Under 1904.39 a work-related fatality must be reported within 8 hours. An in-patient hospitalization, an amputation, or a loss of an eye must be reported within 24 hours. This applies to every employer, including those exempt from the log.
First aid is a specific, closed list in 1904.7(b)(5)(ii): cleaning wounds, simple bandages and butterfly closures, non-prescription medication at non-prescription strength, hot or cold therapy, finger guards, and similar items. On the list: not recordable on that basis. Not on the list: it's medical treatment, and the case goes on the log. There is no judgment call; the list is exhaustive by design.
A near miss, the pallet that almost fell, the guard that was missing but nobody got hurt, is none of the above. It never touches the OSHA forms, which is exactly why plants that only track recordables are blind to most of their risk. That is a near-miss reporting problem, not a recordkeeping problem.
What goes on each form?
Form 301 (Injury and Illness Incident Report) is the detail record: one per case, completed within 7 calendar days of learning about a recordable injury, per 1904.29 who was hurt, doing what, with what object or substance. An equivalent form (a state workers' comp report with the same fields) is acceptable.
Form 300 (Log of Work-Related Injuries and Illnesses) is the year's running log: one line per case, classified by severity (death, days away, job transfer or restriction, other recordable) with day counts. Days away and restricted days are counted in calendar days, capped at 180.
Form 300A (Summary) is the annual roll-up of the 300 log: total cases, total days, injury types, plus average employment and total hours worked. A company executive must certify it, and under 1904.32 it must be posted where notices to employees are usually posted, from February 1 to April 30 of the following year. You must post a 300A even if you had zero recordables. All three forms are kept for five years.
What to do when someone gets hurt: the sequence
When an incident happens, run this order of operations. It keeps the fast clocks from getting lost behind the slow ones.
- Get the person treated. Nothing about paperwork comes before care.
- Check the 1904.39 reporting triggers immediately. Fatality: call OSHA within 8 hours. In-patient hospitalization, amputation, or loss of an eye: report within 24 hours (1-800-321-OSHA or the online form).
- Decide recordability using the decision tree above: work-related, new case, meets a 1904.7 criterion.
- Complete Form 301 and enter the case on Form 300 within 7 calendar days of learning about it.
- Track day counts as they accumulate calendar days away or restricted, updated as the case develops, capped at 180.
- Investigate the cause a recordable is also a failed control. Feed it into your job safety analysis for that task and brief the crew at the next toolbox talk.
- Roll the year into the 300A certify it, post it February 1, submit electronically by March 2 if you're covered, and keep everything five years.
Who must submit records electronically?
Electronic submission runs through OSHA's Injury Tracking Application (ITA) and the rules were expanded by a final rule effective January 1, 2024. Under 1904.41 there are now three tiers:
- Establishments with 250 or more employees that are required to keep records must submit their 300A data annually.
- Establishments with 20–249 employees in designated higher-hazard industries must submit their 300A data annually.
- Establishments with 100 or more employees in the high-hazard industries listed in Appendix B to Subpart E, which includes much of manufacturing, must also submit case-level data from their Form 300 and Form 301 along with their legal company name and EIN.
The deadline is March 2 each year, covering the prior calendar year. Counts are per establishment, not per company, and the rules apply in State Plan states too. For covered plants, case-level injury detail now reaches OSHA annually, and OSHA uses it to target enforcement.
What do the national numbers look like?
The records you keep feed the national picture. The most recent federal data:
- Private industry employers reported about 2.5 million nonfatal workplace injuries and illnesses in 2024, down 3.1 percent from 2023 (BLS, Employer-Reported Workplace Injuries and Illnesses).
- The total recordable case rate was 2.3 per 100 full-time-equivalent workers the lowest in the series; manufacturing has run above that all-industry average in recent years (BLS industry tables).
- Those rates are computed from the same 200,000-hour formula your 300A feeds, see how to calculate TRIR for the math and its blind spots.
Where plants get recordkeeping wrong
The same failures show up in citations and audits: recording first-aid-only cases (inflating your rates) or quietly skipping real ones; missing the 7-day window because the report sat in a clipboard over a long weekend; posting the 300A late, or having HR sign what requires a company executive's certification; counting workdays instead of calendar days. And treating the log as the whole safety program, the 300 log only sees incidents that already happened, which is why it pairs with near-miss reporting and lockout/tagout discipline rather than replacing them.
Getting the data off clipboards
Most recordkeeping failures are really data-capture failures: the incident happened at 2 a.m. and the paper form reached the safety manager on Thursday. Plants that move incident and inspection capture to tablets at the station, the first phase of any connected worker rollout, get timestamps, complete fields, and a log that's current instead of reconstructed every January. That's how Harmony starts on the floor: digitize the paper, so the record exists the moment the event does (see how it works).