Recordkeeping under OSHA requirements takes many forms, including records of training, written programs, equipment inspection documentation, injury and illness records, air and noise monitoring data, and medical and exposure records.
Scope
Most recordkeeping requirements apply to all employers who have employees exposed to the particular hazard requiring the activity or exposure that is to be documented. For injury and illness records, employers with fewer than 11 employees are exempt, as well as employers in certain industries (as listed in Appendix A of Part 1904 Subpart B).
Key definitions
- Exposure record: A record required by OSHA pertaining to exposure to hazardous chemicals.
- Form 300: The form or log that OSHA requires to be used to record injuries/illnesses meeting the specified criteria.
- Form 300A: The form employers must make, certify, and post to summarize information on the Form 300 for each year.
- Form 301: The form that is used to record detailed information about an injury/illness from the Form 300.
- Injury/Illness record: A record made to satisfy OSHA’s requirements for injuries/illnesses that meet certain criteria (i.e., are work-related and result in medical treatment beyond first aid, lost-time, loss of consciousness, or other specified criteria).
- Medical record: A record required to be kept by OSHA regarding employees’ medical records, including examinations and surveillance for exposure to a chemical.
- Written program/plan: A document required by several OSHA standards, such as Hazard Communication and Respiratory Protection, explaining how employers will comply with various aspects.
Summary of requirements
- Keep injury/illness records. Covered employers must keep injury and illness records using the OSHA Form 300 Log, the Form 300A Summary, and the Form 301 Incident Reports, or equivalent forms.
- Certify and post the annual summary of injuries/illnesses. This must be posted from February 1 through April 30.
- Submit injury and illness data electronically to OSHA or OSHA’s designee, if required, by March 2 every year. Under a rule published in July 21, 2023 and effective January 1, 2024, many establishments with 20 or more employees must submit certain injury and illness data to OSHA. Exact requirements depend on the number of employees at each establishment and the North American Industry Classification System (NAICS) code for each establishment:
- Establishments with 250 or more employees that are required to maintain an OSHA 300 Log (or equivalent) must submit data from the 300A Annual Summary.
- Establishments with 20 to 249 employees whose NAICS codes are listed in Appendix A to Subpart E of 29 CFR 1904 must submit data from the 300A Annual Summary.
- Establishments with 100 or more employees whose NAICS codes are listed in Appendix B to Subpart E of 29 CFR 1904 must submit data from the 300 Log, 301 Incident Report Forms, and 300A Annual summary.
- If you are NOT in a routine electronic submission category above, then submit 29 CFR 1904 records electronically ONLY upon notification. Upon notification by mail from OSHA, you must electronically submit the requested information from your Part 1904 records to OSHA or OSHA’s designee as part of an individual data collection.
- Keep exposure/medical records for at least 30 years. Employers with employees exposed to hazardous chemicals or harmful physical agents must keep exposure records and in some cases medical surveillance records. Exposure records must be kept for 30 years. Medical records must be kept for the duration of employment plus 30 years.
- Report to OSHA. All employers, even those who may be exempt from other recordkeeping requirements, must promptly report to OSHA all work-related:
- Fatalities
- In-patient hospitalizations
- Amputations
- Losses of an eye
- Document training. Many OSHA standards require training to be documented, but not all.
- Develop written programs. Many OSHA standards, such as Hazard Communication, Respiratory Protection, and Bloodborne Pathogens, require employers to maintain a written program or plan.
- Maintain inspection records. Several OSHA standards require documentation of maintenance and/or inspection records.
