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OSHA Recordkeeping

OSHA Maintaining Your Records

OSHA requires that employers of 11 or more employees keep records of occupational injuries and illnesses for each work establishment. An establishment is a single physical location in which business is conducted or in which services or industrial operations are performed. For mobile work sites (for example, construction and utility industries), the establishment is the location in which the workers are supervised or in which their activities are based. All occupational illnesses must be recorded regardless of severity. Occupational injuries must be recorded if they result in death, one or more lost workdays, restriction of work or motion, loss of consciousness, transfer to another job, or medical treatment. OSHA has developed the following forms for completing and maintaining records of injuries and illnesses:

OSHA Forms

The way to satisfy the two seemingly conflicting requirements is to introduce a Corrective Action Process; where corrective action may be issued based on the particular circumstance of the incident. This corrective action will not follow the standard of progressive discipline (verbal, written, suspension and discharge) but will be based on the seriousness of the incident and also the history of the employee.

  • OSHA Form 300, Injury and Illness Log - the log contains a brief description of each recordable injury and illness.
  • OSHA Form 300A, Summary of Work-Related Injuries and Illnesses - a list of injuries and illnesses that were recorded in the 300 Log during the previous calendar year, which must be posted in the workplace from February to April.
  • OSHA 301, Injury and Illness Incident Report - includes detailed information about each injury or illness incident.
  • Exception: Employers with 10 or fewer employees are generally exempt from keeping such records. Employers in retail trade, finance, insurance, real estate, and service industries, are generally exempt from record keeping.

OSHA Inspections

OSHA may inspect almost any place of business, in most cases without advance notification. Advance notice will be given only to enable an employer to correct an imminent danger quickly if inspection must be conducted after normal business hours, or to ensure the presence of employer or employee representatives. An unauthorized warning to an employer of a coming inspection is punishable by fine and a jail term.

Except in an emergency or if conditions are in plain sight, an OSHA inspector must obtain a search warrant if refused the right to enter.

Your OSHA 300 log is the first document OSHA will ask for in an inspection.


Failure to maintain the records can result in fines of up to $8,000 for each year of the violation. Employers could face penalties of $1,000 for each year they fail to properly maintain the new OSHA 300 form. In addition, a separate penalty may be issued for each OSHA 301 form that is not filled out accurately or correctly, with a maximum penalty of $7,000.

What incidents should be reported to OSHA directly?

Within eight (8) hours after the death of any employee from a work-related incident or the in-patient hospitalization of three or more employees as a result of a work-related incident, you must orally report the fatality/multiple hospitalization by telephone or in person to the Area Office of the Occupational Safety and Health Administration (OSHA), U.S. Department of Labor, that is nearest to the site of the incident. You may also use the OSHA toll-free central telephone number, 1-800-321-OSHA (1-800-321-6742).

Which work-related injuries and illnesses should you record?

Record those work-related injuries that result in:

  • Death
  • Loss of consciousness
  • Days away from work
  • Restricted work activity or job transfer, or
  • Medical treatment beyond first aid

You must also record any significant work-related injury or illness that is diagnosed by a physician or other licensed health care professional. You must record any work-related case involving cancer, chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum.

What are the additional criteria?

You must record the following conditions when they are work-related:

  • Any needle stick injury or cut from a sharp object that is contaminated with another person's blood or other infectious material
  • Any case requiring an employee to be medically removed under the requirements of an OSHA health standard
  • Tuberculosis infection as evidenced by a positive skin test or diagnosis by a physician or other licensed health care professional after exposure to a known case of active tuberculosis
  • An employee's hearing test (audiogram) reveals:

    1) That that the employee has experienced a Standard Threshold Shift (STS) in hearing in one or both ears (averaged at 2000, 3000, and 4000 Hz), and

    2) The employee's total hearing level is 25 decibels (dB) or more above audiometric zero (also averaged at 2000, 3000, and 4000 Hz) in the same ear(s) as the STS. top