OSHA Recordkeeping Requirements: A Complete Guide for Small Businesses

The forklift operator who strained his back last week-is that recordable? The office worker who needed stitches after cutting her hand-does that go on the log? OSHA recordkeeping can feel like navigating a maze of rules and exceptions. But here's the truth: these records aren't just bureaucratic requirements. They're your defense against citations, your data for preventing future injuries, and sometimes, your evidence that you're running a responsible business.

Who's Required to Keep Records?

The basic rule is straightforward: if your company has 11 or more employees at any time during the calendar year, you must maintain OSHA injury and illness records. Count everyone-full-time, part-time, temporary, seasonal. If you hit 11 employees even for just one day, you're covered for the entire calendar year.

However, certain low-hazard industries get a partial exemption. Retail stores (except those selling building materials), banks, insurance companies, real estate offices, and certain service businesses don't have to keep routine records. But-and this is crucial-even exempt employers must still report severe injuries to OSHA within required timeframes and must provide records if OSHA, the Bureau of Labor Statistics, or state agencies specifically request them.

The Three Forms That Matter

OSHA Form 300 is your captain's log-a running record of every work-related injury and illness throughout the year. Think of it as your safety diary where you document what happened, to whom, when, and what the outcome was. You have seven calendar days from learning about a recordable case to enter it here. This isn't a detailed narrative; it's a line-item entry with basic facts that helps you spot patterns and problem areas.

OSHA Form 301 tells the full story of each incident. While Form 300 gives you the headline, Form 301 provides the complete article. You'll document exactly how the injury occurred, what the employee was doing, what tools or equipment were involved, and what specific injury or illness resulted. This detailed account becomes invaluable for preventing similar incidents and defending against claims. Workers' compensation forms with equivalent information can substitute for Form 301.

OSHA Form 300A is your annual report card-a summary of the year's injuries and illnesses that must be certified by a company executive and posted where all employees can see it from February 1 through April 30. This public posting serves two purposes: it demonstrates transparency about workplace safety and allows employees to understand their workplace's safety performance compared to previous years.

Decoding What's Recordable

The recordability decision tree starts with a fundamental question: Is the injury or illness work-related? This doesn't mean work must be the sole cause, just that work activities or the work environment caused or contributed to the condition. An employee who aggravates a pre-existing back condition while lifting boxes at work? That's work-related. Someone who has a heart attack at their desk with no work connection? Generally not work-related.

Next, determine if it's a new case or a continuation of something previously recorded. Then comes the critical test: Does it meet general recording criteria? The case must involve death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or diagnosis of a significant injury or illness by a healthcare professional.

The distinction between first aid and medical treatment trips up many employers. First aid keeps it off the books-think band-aids, ice packs, non-prescription medications, or simple wound cleaning.Medical treatment triggers recording-stitches, prescription medications, physical therapy, or anything requiring professional medical skill. That tetanus shot? First aid. Those butterfly bandages? First aid. But surgical glue to close a wound? That's medical treatment and makes it recordable.

Privacy Cases: Handling Sensitive Information

Some injuries and illnesses require special privacy protection. Instead of recording the employee's name on Form 300, you'll enter "Privacy Case" and maintain a separate, confidential list. This applies to injuries to intimate body parts, sexual assaults, mental illnesses, HIV infection, hepatitis, tuberculosis, and needlestick injuries contaminated with blood.

Employees can also request privacy case handling for other illnesses if they provide adequate reason. Balance transparency with dignity-your records should inform safety improvements without embarrassing individuals. Remember, even privacy cases must be fully documented on Form 301, just with extra attention to confidentiality.

Electronic Submission: Going Digital

Large establishments with 250 or more employees must electronically submit their injury and illness data to OSHA annually. Smaller establishments (20-249 employees) in certain high-hazard industries must submit Form 300A data. This information goes into OSHA's public database, making your safety record visible to potential customers, employees, and competitors.

Submission happens through OSHA's Injury Tracking Application (ITA) by March 2nd each year. The system is straightforward but unforgiving of errors. Double-check your data before submission-once it's public, corrections become complicated. Consider this submission an opportunity to review your safety performance and identify improvement areas before the data goes public.

Common Mistakes That Trigger Citations

Misclassifying days away from work happens when employers don't understand that "days away" means calendar days, not just scheduled work days. If an employee injured on Friday can't return until Wednesday, that's five days away (Saturday through Wednesday), not three work days. The only day you don't count is the day of injury itself.

Recording injuries just because they happened at work misunderstands the work-relatedness requirement. An employee who breaks their ankle playing basketball during lunch on company property? Probably not recordable-personal activities during breaks generally aren't work-related. But if playing was part of a company-sponsored team-building event? Now it's likely recordable.

Failing to update records when circumstances change costs many employers. An employee who returns to work after an injury but later needs surgery and additional time off? You must update your records to reflect the additional lost days. Records are living documents until the year ends.

Improper storage creates compliance nightmares. Those forms from three years ago that you tossed during spring cleaning? OSHA requires keeping Forms 300, 301, and 300A for five years following the year they cover. Electronic storage is fine, but ensure you can produce readable copies on demand.

Turning Records into Safety Improvements

Smart employers don't just file these forms-they mine them for insights. Monthly analysis might reveal that most injuries happen during overtime hours, suggesting fatigue issues. You might discover that new employees account for a disproportionate share of injuries, indicating training gaps. Or perhaps certain departments consistently report more incidents, pointing to equipment or procedure problems.

Calculate your DART rate (Days Away, Restricted, or Transferred) and compare it to industry averages. If you're above average, dig deeper. Are you actually less safe, or are you better at identifying and recording cases? Both scenarios require action-either improving safety or ensuring consistent recording practices.

Share sanitized data with employees. When workers see that hand injuries decreased after new gloves were introduced, or that back injuries dropped following ergonomic improvements, they understand that safety initiatives produce real results. This transparency builds trust and encourages reporting of hazards before they cause injuries.

Best Practices for Bulletproof Recordkeeping

Centralize your recordkeeping under one knowledgeable person, but ensure backup coverage. This consistency prevents different interpretations of recordability and ensures timely recording. Train supervisors to recognize potentially recordable cases and report them immediately-the seven-day clock starts when any management representative learns of the case, not when the safety manager finds out.

Investigate incidents immediately while memories are fresh and evidence is available. Document everything, even if you ultimately determine the case isn't recordable. That documentation protects you if questions arise later and provides valuable near-miss data for safety improvement.

Consider digital recordkeeping systems that can generate required forms, calculate rates, and flag recording deadlines. These systems reduce errors and make analysis easier. But maintain paper backup capability-computer crashes during an OSHA inspection won't excuse missing records.

The Bigger Picture

OSHA recordkeeping isn't just about avoiding citations-it's about understanding your workplace's safety story. These records reveal whether your safety programs work, where to focus limited resources, and how to protect employees more effectively. They're evidence of due diligence in legal proceedings and demonstrations of social responsibility to stakeholders.

Most importantly, accurate records honor the experiences of injured employees. Each entry represents someone's pain, lost wages, and family stress. By recording accurately, analyzing thoroughly, and acting on findings, you transform bureaucratic requirements into genuine safety improvements. That's when recordkeeping stops being a burden and becomes a tool for building a workplace where everyone goes home healthy.