Every year, employers across the country get tripped up by one of OSHA’s most deceptively simple obligations: keeping accurate injury and illness records. It sounds like paperwork. In practice, it’s one of the most heavily enforced areas of compliance, and errors here routinely lead to citations even at workplaces with genuinely strong safety cultures.

OSHA’s recordkeeping requirements are laid out in 29 CFR Part 1904 and summarized on the agency’s Recordkeeping overview page. Understanding exactly what triggers a record, how long you have to make it, and who’s exempt is the first step toward staying off OSHA’s radar for the wrong reasons.

Who Has to Keep Records

Most employers with more than 10 employees at any time during the prior calendar year must keep OSHA injury and illness records, unless they fall into a specific low-hazard industry classified as “partially exempt” under 1904.2. Retail, service, finance, insurance, and real estate industries make up most of the exempt list, but the exemption is based on NAICS industry codes, not company size alone, so it’s worth checking your specific classification rather than assuming.

Even exempt employers aren’t fully off the hook. Every employer covered by OSHA, exempt or not, must report any work-related fatality within 8 hours and any work-related inpatient hospitalization, amputation, or loss of an eye within 24 hours, using OSHA’s Injury Tracking Application or by phone.

The Three Core Forms

Covered employers use three linked forms:

• OSHA Form 300 (Log of Work-Related Injuries and Illnesses) — the running log of every recordable case during the year.
• OSHA Form 301 (Injury and Illness Incident Report) — the detailed report completed for each individual case.
• OSHA Form 300A (Summary) — the annual summary, which must be posted in a visible location at each establishment from February 1 to April 30 of the following year, even at locations with zero recordable cases.

What Actually Counts as “Recordable”

This is where most errors happen. A case is recordable if it’s work-related and results in death, days away from work, restricted work or job transfer, loss of consciousness, medical treatment beyond first aid, or a significant diagnosed injury or illness (such as a cancer, fractured bone, or punctured eardrum) even without those other outcomes. OSHA maintains a detailed first aid vs. medical treatment distinction that trips up even experienced safety managers — an ice pack and an over-the-counter pain reliever are first aid; a prescription-strength dose of the same medication is medical treatment, and that single distinction can change whether an incident belongs on the log.

Electronic Submission Requirements

Under the current electronic recordkeeping rule, establishments with 20-249 employees in designated high-hazard industries must submit Form 300A data electronically each year, while establishments with 250 or more employees in industries required to keep records must submit Form 300A, 300, and 301 data. Deadlines fall on March 2 annually, and OSHA has stated it publishes portions of this data, which means recordkeeping accuracy is increasingly a public reputational issue, not just a compliance one.

Building a Recordkeeping System That Holds Up to an Audit

A defensible recordkeeping program isn’t just about filling out forms correctly after an incident. It requires:

1. A designated, trained recordkeeper who understands the work-relatedness and recordability criteria in 1904.5 and 1904.7.
2. A consistent intake process so supervisors report incidents immediately rather than after the fact.
3. Retention of all records for five years following the end of the calendar year they cover, per 1904.33.
4. An annual review process before the February posting deadline to catch errors before they become citations.

The Bottom Line

Recordkeeping citations are avoidable, but only with a system that treats the requirement as an ongoing discipline rather than an annual scramble. Employers who build recordkeeping into their regular safety cadence, rather than reconstructing it every February, consistently fare better in both OSHA inspections and their own injury-trend analysis.

Sources & Further Reading

• OSHA, Recordkeeping Overview
• OSHA, 29 CFR Part 1904 — Recording and Reporting Occupational Injuries and Illnesses
• OSHA, Injury Tracking Application (ITA) and Electronic Reporting
• eCFR, Title 29, Part 1904