Share
An employee slips in the break room and sprains their wrist. Is it OSHA recordable? It depends on whether they sought medical treatment beyond first aid, whether it resulted in restricted work or days away from work, and whether the injury is work-related under OSHA’s definition. Getting the classification wrong — either missing a recordable or recording something that isn’t — creates liability in either direction.
OSHA recordkeeping requirements apply to most private-sector employers with 10 or more employees in industries that aren’t specifically exempt. This guide covers what counts as a recordable injury or illness, which forms you need, how long to retain them, and the electronic reporting requirements that have caught many employers off guard in recent years.
Who Must Keep OSHA Records
Employers with 10 or fewer employees are generally exempt from routine OSHA 300 Log recordkeeping. Employers in certain low-hazard industries — a list defined by OSHA based on NAICS codes — are also partially exempt, though they must still report fatalities and severe injuries. If you’re in manufacturing, construction, healthcare, food service, warehousing, or most other non-office industries with more than 10 employees, you almost certainly have full recordkeeping obligations.
A quick check: OSHA’s website maintains the current list of partially exempt industries with their NAICS codes. If your primary NAICS code appears on that list, you’re partially exempt from the 300 Log but still subject to reporting requirements for fatalities and hospitalizations. If you’re not sure of your NAICS code, it’s on your business registration documents and your workers’ compensation policy.
What Makes an Injury or Illness Recordable
An injury or illness is recordable if it’s work-related, is a new case, and meets one or more of the following criteria: it results in days away from work, restricted work activity, or job transfer; it requires medical treatment beyond first aid; it involves loss of consciousness; it involves a diagnosis of a significant injury or illness by a healthcare professional even if none of the other criteria are met.
The “beyond first aid” threshold is where most classification questions arise. First aid includes things like non-prescription medications at non-prescription strength, wound cleaning and bandaging, use of non-rigid means of support, hot or cold therapy, and single-visit professional care where no follow-up treatment is recommended. An employee who sees a doctor once, receives a prescription for ibuprofen (a prescription-strength medication, not the OTC dose), and is told to return in a week has received medical treatment beyond first aid — that’s a recordable case. An employee who goes to the urgent care, gets their wound cleaned and bandaged, and is told they don’t need to come back has received first aid — not recordable, assuming no days away and no restricted duty.
The OSHA Forms: 300, 300A, and 301
Three forms make up the OSHA recordkeeping system. The OSHA 300 Log is the running list of all recordable work-related injuries and illnesses during the calendar year. You record each case as it occurs, noting the employee name, job title, date, location, description, and case outcome (days away, restricted duty, job transfer, or other). The 300 Log is maintained throughout the year and updated as case outcomes change.
The OSHA 300A Summary is a one-page annual summary of the 300 Log totals. Employers must post the 300A Summary in a visible workplace location from February 1 through April 30 each year. It must be signed by a company executive certifying the information is accurate. The 301 Incident Report is a more detailed record for each individual case — capturing incident specifics that the 300 Log doesn’t have room for. Employers can use workers’ compensation First Report of Injury forms as a substitute for the 301 if they contain equivalent information.
Electronic Submission Requirements
OSHA’s electronic recordkeeping rule requires certain employers to submit their injury and illness data electronically through OSHA’s Injury Tracking Application (ITA). The requirements depend on employer size and industry.
Establishments with 250 or more employees must submit their 300 Log, 300A Summary, and 301 Incident Reports electronically each year. Establishments with 20 to 249 employees in designated high-hazard industries must submit their 300A Summary electronically. Smaller employers in non-designated industries are not subject to electronic submission requirements but still must maintain paper records. Submission deadlines are typically March 2 of the following year for the prior year’s data.
Retention Requirements
OSHA requires that the 300 Log, 300A Summary, and 301 Incident Reports be retained for five years following the end of the calendar year to which they relate. During that retention period, the records must be available for review by employees, former employees, their representatives, and OSHA inspectors. Employees have the right to access their own 301 Incident Reports and a copy of the 300 Log at no cost and within a reasonable timeframe — typically by the end of the next business day.
Netchex’s HR platform helps track workplace incidents, maintain documentation, and support the recordkeeping workflows that OSHA compliance requires. For employers managing safety documentation alongside HR and payroll records, centralizing that documentation reduces the risk of records being incomplete or inaccessible when needed. Talk to a Netchex consultant about incident tracking and HR compliance documentation for your workforce.
Frequently Asked Questions
Most private-sector employers with more than 10 employees must maintain OSHA 300 Logs unless they are in a partially exempt low-hazard industry as defined by OSHA’s NAICS code list. All employers, regardless of size or industry, must report fatalities within 8 hours and in-patient hospitalizations, amputations, or eye losses within 24 hours. Employers in partially exempt industries still have these reporting obligations even though they don’t maintain the 300 Log.
First aid includes specific treatments like wound cleaning and bandaging, non-prescription medications at OTC strength, and single-visit professional care with no recommended follow-up. Medical treatment beyond first aid — which makes a case recordable if other criteria are also met — includes prescription medications (even if the OTC equivalent exists), sutures, follow-up medical visits, and physical therapy. The classification depends on what treatment was actually provided, not where the employee went for care.
The 300A Summary must be posted in a conspicuous workplace location from February 1 through April 30 of the year following the recording year. It must be signed by a company executive — OSHA defines this as an owner, officer, director, or the highest-ranking company official at the establishment. An HR manager or safety officer cannot sign the 300A Summary unless they also hold one of the executive roles.
OSHA requires the 300 Log, 300A Summary, and 301 Incident Reports to be retained for five years following the end of the calendar year they cover. During the retention period, current and former employees and their representatives have the right to access the 300 Log and their individual 301 Incident Reports. OSHA inspectors may also request these records during inspections.
Keep Your OSHA Records Where Your HR Records Are
See how Netchex helps HR teams track workplace incidents, maintain compliance documentation, and keep everything accessible when you need it.
This guide reflects publicly available product information and independent reviewer data (G2, Capterra, Trustpilot, Yelp, Better Business Bureau, Reddit, Software Advice, GetApp) as of 2026. Feature availability and pricing may vary by plan. Contact each provider for current details.
Disclaimer: Any product roadmap or future plans provided herein are for informational purposes only. They do not represent a commitment to deliver any material, code, feature, or functionality. Plans may change without notification. The development, release and timing of any features or functionality described remain at the sole discretion of Netchex, its affiliates, and partners. Netchex does not give legal, tax, or accounting advice. You are responsible for ensuring your use of Netchex product meets your individual business and compliance requirements.
Related events
Top HR & Payroll Pain Points for School Districts and Private Schools
5 Best Payroll & HR Platforms for Revel Systems POS: 2026 Buyer’s Guide
Top 5 Payroll Software for Tray POS Users (2026)
