OSHA 300 Log Requirements by Size and Industry

§1What employers mean by OSHA 300 log requirements

Search traffic for "osha 300 log requirements" usually wants a decision path, not a brochure. An HR lead needs to know whether this establishment must keep the injury log at all, which three forms that duty covers, when the annual summary has to hang on the wall, and whether electronic filing is also required. Those are separate rules inside 29 CFR part 1904, and collapsing them into one "yes we have a safety binder" answer is how small employers miss a posting window or an ITA deadline.

OSHA's own recordkeeping overview splits the work into three buckets: recording work-related injuries and illnesses on Forms 300, 300A, and 301 (or equivalent forms); reporting fatalities and severe injuries on a short clock; and annual electronic submission through the Injury Tracking Application for establishments that meet size and industry criteria [OSHA Recordkeeping, checked 2026-10-18]. This guide walks those buckets in the order a payroll or HR person usually meets them.

§2Step 1: size and industry decide whether you keep a routine log

Many employers with more than 10 employees must keep a record of recordable work-related injuries and illnesses. Employers with 10 or fewer employees are generally exempt from the routine recording duty, though not from fatality and severe-injury reporting [OSHA Recordkeeping]. Count carefully: the threshold is applied at the establishment level under part 1904, so a multi-site company can have one location over the line and another under it.

Industry can still remove an otherwise large office from routine recording. OSHA publishes a partially exempt industry list (Non-Mandatory Appendix A to Subpart B of 29 CFR 1904). If your NAICS code sits on that list, you may be excused from keeping the Forms 300/300A/301 log even with more than 10 employees. Confirm the current appendix rather than relying on a vendor blog's paraphrase, then document the NAICS you used and the date you checked.

A practical branch table for an HR file looks like this: (1) establishment employees ≤10 → no routine log, still report severe events; (2) employees >10 and NAICS on the partially exempt list → no routine log unless OSHA has told you otherwise; (3) employees >10 and not exempt → keep Forms 300, 300A, and 301 or equivalent forms for each recordable case.

§3Step 2: Forms 300, 300A, and 301 are three different jobs

Form 300 is the running log of work-related injuries and illnesses for the year. Form 301 (or an equivalent incident report) captures the detail of each case. Form 300A is the annual summary that totals the year's cases and must be certified by a company executive. Vendors sometimes sell a single "OSHA module"; your obligation is still to produce each of those three outputs when recording applies [OSHA Injury & Illness Recordkeeping Forms].

Recordable cases are a defined set under part 1904 (death, days away, restricted work or transfer, medical treatment beyond first aid, loss of consciousness, and certain diagnosed conditions). First-aid-only incidents generally stay off the log. When in doubt, read the regulation's first-aid list instead of guessing from a clinic invoice description.

Equivalent forms are allowed if they contain the same information. Spreadsheet templates are common in shops under 50 people. The risk is version drift: if three managers keep three sheets, you no longer have one establishment log. Assign a single recordkeeper and a single file location before the first case lands.

§4Step 3: posting the 300A and retaining the file

When recording applies, the completed Form 300A summary must be posted in a conspicuous place where notices to employees are customarily posted, from February 1 through April 30 of the year after the calendar year the records cover. Pulling the summary down on March 1 because "tax season is busy" is still a posting violation even if the numbers were correct.

Keep the log and related records for at least five years following the end of the calendar year to which they relate. That retention window matters when a former employee requests access or when an OSHA inspection asks for prior years. Pair the file with your broader HR calendar in the 2026 HR compliance checklist so posting and retention are not tribal knowledge.

§5Step 4: electronic submission is not the same as keeping the log

Establishments that meet certain size and industry criteria must submit injury and illness data electronically once per year through OSHA's Injury Tracking Application (ITA). The submission window runs from January 2 through March 2. Keeping a paper or spreadsheet log does not automatically make you an electronic filer, and missing the window does not erase the duty: OSHA's ITA pages state that establishments who miss the deadline must still submit [OSHA ITA, checked 2026-10-18].

Coverage turns on establishment size and industry appendices (including categories that require Form 300A only versus additional case-level data). Use OSHA's ITA Coverage Application for the establishment you are checking rather than copying a neighbor's conclusion. A 40-person manufacturer and a 40-person professional office can land on opposite sides of the electronic rule even when both keep a routine log.

After the March 2, 2026 timely-submission deadline, late filers were still told to submit. Treat that as a compliance cleanup task, not proof that the duty expired.

§6Step 5: severe-injury reporting still hits exempt employers

Every employer covered by the OSH Act must notify OSHA of a work-related fatality within 8 hours, and of a work-related in-patient hospitalization, amputation, or loss of an eye within 24 hours [OSHA Recordkeeping]. The 10-employee and partially exempt shortcuts for the routine log do not erase that clock.

Build the reporting path into the same incident playbook as workers' compensation first notice. Who dials OSHA, which phone number or online channel you use, and where the confirmation is filed should be written down before an emergency, next to your security and incident-response role descriptions if you staff a front desk or site security function.

§7How this differs from pages already ranking for the query

Law-firm and training-vendor pages in the current results explain pieces of part 1904 well, but most stop at a single angle: a 101 overview, a 300A explainer, or a posting tip sheet. The gap for an employer is the branch from headcount and NAICS to routine-log status, then from covered-establishment size to ITA forms and deadlines, with severe-event reporting kept on a separate track. That is the artifact this page is built to deliver.

If you already bought an HR suite with a safety module, still walk the branch table once. Software can store cases; it cannot decide whether your NAICS is partially exempt or whether this establishment owes an ITA file.

§8Frequently asked questions

Does a tiny shop still owe the injury register? The ongoing case register is usually optional below the double-digit headcount line. You still owe the same emergency notices when someone dies on the job or loses an eye, an arm, or needs overnight hospital care because of work (29 CFR part 1904 reporting rules).

If we already maintain Form 300, must we also upload to ITA? No. The upload rule is its own size-and-industry screen. Run the coverage checker for the specific site before you create an ITA account out of habit.

How long does the Form 300A stay on the wall? After year-end close, display the signed totals sheet for the full spring posting season the agency sets (starting February 1 and ending April 30) in the same spot as other required labor notices.

When do covered sites send their ITA file? Covered sites send data in the early-year filing season that closes on March 2. Sending late is better than skipping; the agency still expects the file.

Is a custom workbook acceptable instead of the PDF packet? A well-built sheet is fine when it stores every required field. Lock one workbook as the source of truth so the year-end totals cannot drift from the case rows.