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OSHA recordkeeping, in plain language
Most recordkeeping citations aren't for hiding something. They're for a form that wasn't filled in, a log that wasn't posted, or a record that couldn't be produced. Here's the short version. It's general guidance, not legal advice — check the current rules for your situation.
- What has to be recorded, and what doesn't
- The three OSHA forms and what each one is for
- Deadlines people miss every year
- What to keep beyond the OSHA logs
Is it recordable?
- Work-related, and a new case — not the continuation of an old one
- Death, days away from work, restricted duty, or transfer to another job
- Medical treatment beyond first aid — first aid alone is not recordable
- Loss of consciousness
- A significant injury or illness diagnosed by a physician or licensed health professional
- Specific cases with their own rules: needlesticks, tuberculosis, hearing loss, and medical removal
The three forms
- Form 300 — the running log of every recordable case for the year
- Form 301 — the detailed incident report behind each case, completed within 7 calendar days
- Form 300A — the year-end summary, certified by a company executive
Dates that catch people out
- Post the 300A from February 1 through April 30, where employees can see it
- Complete a 301 within 7 calendar days of learning about a recordable case
- Report a fatality to OSHA within 8 hours
- Report an inpatient hospitalization, amputation, or loss of an eye within 24 hours
- Keep the 300, 300A, and 301 for 5 years after the year they cover
- Update the 300 if a case changes — more days away, or a classification that turns out different
Keep these too, even though OSHA doesn't call them recordkeeping
- JHAs, signed and dated, for the work being done
- Toolbox talk and safety meeting sign-in sheets
- Equipment inspection records, especially cranes and lifts
- Training and certification records with expiration dates
- Corrective actions with who owned them and when they closed
- Near-miss reports — not required, but the best evidence of a real program
The one that catches everyone
The medical treatment line. First aid is not recordable, and OSHA lists exactly what counts as first aid — cleaning a wound, a non-prescription medication at non-prescription strength, a tetanus shot, a butterfly closure. Prescription medication, stitches, or immobilization crosses into medical treatment and the case becomes recordable. When people get this wrong, it's almost always in the direction of not recording something they should have.
How HazProof handles this
Your incident records generate the 300, 300A, and 301 rather than you retyping them, and when you're working through a case HazProof will give you an assessment of whether it looks recordable and explain its reasoning. That's a second opinion to help you think it through, not a determination — the call is yours, and it gets recorded as yours.
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