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OSHA 300 Requirements: Seven Duties Behind One Log

By Job13 Editorial Team7 min read
A stack of paper OSHA 300 Log forms on a warehouse office desk

Photo by Joachim Schnürle on Pexels

The OSHA 300 requirements are the duties 29 CFR Part 1904 places on an employer who keeps the Form 300 log. Each recordable case goes on the log within seven calendar days of the employer learning it occurred. The log is kept for five years, the annual 300A summary is certified and posted from 1 February to 30 April, and employees and their representatives can ask for a copy and get it by the next business day. Those duties come from a short set of rules, and most compliance gaps sit in the handful of places where they meet real cases.

This post sets out the duties in order, works one year of cases through them, and flags where teams usually slip. The example is the same illustrative site used in the incident rate calculator walkthrough, so the figures match across both posts.

Who the requirement applies to

Part 1904 covers an employer with more than ten employees at any point in the year, unless the business sits in an industry on the partially exempt list. An exempt employer does not keep the log, but it still has to report a fatality or an in-patient hospitalisation to OSHA. The partially exempt industries trap covers that distinction and the Appendix A list.

Each physical establishment keeps its own log. A business with three sites keeps three logs, not one consolidated sheet, and an employee can ask for the log of any site where they worked.

The seven duties

The table sets out each duty, what the rule requires and where it sits in the regulation. Every row is a separate obligation, and a failure in any one of them is a failure of the log.

Duty What the rule requires Where it sits
Decide what counts Only recordable cases go on the log, so each event is checked for work-relatedness and then for a recording criterion first 1904.4, 1904.5, 1904.7
Enter it on time Enter each recordable injury or illness within seven calendar days of receiving information that it occurred 1904.29(b)(3)
Keep privacy cases private Certain sensitive cases are recorded as "Privacy Case" in place of the name 1904.29(b)(6) to (9)
Use electronic records if you wish A computer system is allowed if it can produce equivalent forms when they are needed 1904.29(b)(5)
Summarise and certify the 300A Review the log, complete the annual summary, and have a company executive certify it 1904.32
Post the 300A for three months Post it in a visible place from 1 February to 30 April of the following year 1904.32
Keep it and let people see it Keep the log for five years, and give copies to employees, former employees and representatives by the next business day 1904.33, 1904.35

The first duty comes before the log exists at all. The rest assume the case has already been decided.

A worked example: which cases reach the log

Take the seven events from the rate calculator example, all run through the same gates for a site that worked 124,000 hours in the year. Three of them reach the log, and four do not.

The cold reported at handover and the commute ankle twist are not work-related, so neither goes on the log. The finger cut closed with a butterfly bandage is first aid only, which also keeps it off. Those three are settled and need no further action beyond a short decision note.

The three that reach the log need different entries:

  • Laceration closed with sutures. This is medical treatment beyond first aid, so it goes on as an other recordable case with no days away.
  • Lifting strain under a five-day lifting limit. The restriction is a recording criterion in its own right, so it goes on under the job transfer or restriction column, and the restricted days count toward the total.
  • Shoulder flare-up after documented recovery. The case is new, caused by a workplace event, and treated with prescribed physiotherapy. It goes on as an other recordable case even though no shift was missed.

The seventh event, the hearing shift, is still open. It stays off the log until a baseline comparison settles it. Under 1904.29(b)(3) the seven days run from receiving information that a recordable case has occurred, so write down the date you received the audiogram result. If the comparison later confirms a shift, that date is the one that starts the clock. The standard threshold shift guide walks through the test.

The log therefore holds three entries and one pending decision. That is the number the 300A should total, and the one the rate calculation should use.

Where the requirements slip

Four failures come up again and again.

Counting events instead of cases. The log records determinations. A logged incident that fails a gate is not a log entry, and a log that holds every incident overstates the count in the summary and the rate. The recordable decision tree sets out the order of the gates.

Leaving the stored log unchanged. The stored log has to be updated for newly discovered cases and for changes in classification. If the description or outcome of an entry changes, the original is removed or lined through and the new information is entered. The annual summary and the 301 forms do not need the same updating. A log that was accurate in March and never touched again is the common finding in an audit.

Treating the 300A as the log. The 300A holds totals. It does not replace the entries behind them, and it does not prove the entries were made in time. Both have to be kept, and the 300A summary guide covers what the totals should match.

Refusing access because of names. Employees, former employees, personal representatives and authorised employee representatives can ask for the log and get it by the next business day. Names stay on the log for them. The only exception is the privacy concern cases, which are already recorded without the name.

Before the year closes

  • Check every recordable case against the three gates, and keep a short decision note on each borderline entry.
  • Confirm every recordable case was entered within seven calendar days of the date you received information about it.
  • Reconcile the log totals with the 300A, then certify the summary before posting it.
  • Keep the 300A posted from 1 February to 30 April, and put a reminder on the calendar for the removal date.
  • Set the five-year retention clock for the log, the privacy list and the 301 forms from the end of the calendar year they cover.

Electronic filing is a separate duty, due each year on a set date. The OSHA ITA electronic submission guide covers the upload itself.

Frequently asked questions

Does every employer need an OSHA 300 log?

No. The log applies to employers with more than ten employees at any point in the year, unless the business is in an industry on the partially exempt list. Partially exempt employers still report fatalities and in-patient hospitalisations.

How soon must a recordable injury go on the log?

Within seven calendar days of receiving information that a recordable injury or illness has occurred. The clock runs from when you learn of the case, not from when the paperwork is finished, so note the date you received the information.

How long do I keep the OSHA 300 log?

Five years after the end of the calendar year the log covers. The privacy concern list, the 300A and the 301 incident reports follow the same period, and the stored log has to be kept updated during that time.

Who can ask for a copy of the log?

Employees, former employees, personal representatives and authorised employee representatives can ask for it, and the employer must hand it over by the next business day. Names are shown, except for privacy concern cases, which are already recorded without them.

Sources

About the author

Job13 Editorial Team

Job13's editorial team writes about OSHA recordkeeping — 29 CFR Part 1904, the 300 Log and the determinations that feed it — and builds the recordability engine this site runs on.

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