The OSHA 300 log is one of the most commonly misunderstood recordkeeping requirements in construction. Employers get cited for failing to record incidents that should have been recorded, for missing the annual posting deadline, and for not retaining records long enough — all avoidable mistakes that lead to real penalties.
This guide covers what you actually need to know: who has to keep the log, what goes in it, the deadlines that matter, and the mistakes that generate citations.
What Is the OSHA 300 Log?
The OSHA Recordkeeping Rule (29 CFR Part 1904) requires covered employers to track and record certain work-related injuries and illnesses. The system uses three forms:
- OSHA Form 300 — Log of Work-Related Injuries and Illnesses. The running log where you record each case during the year — one line per incident.
- OSHA Form 300A — Annual Summary of Work-Related Injuries and Illnesses. A one-page totals summary from your Form 300. This is the form posted in the workplace every February.
- OSHA Form 301 — Injury and Illness Incident Report. A detailed report for each individual case logged on Form 300 — more detail than the 300, less than a full investigation report.
These three forms together make up your recordkeeping file for each calendar year.
Who Must Keep the OSHA 300 Log?
Employers with 10 or fewer employees at all times during the previous calendar year are generally exempt from routine recordkeeping. You still must report severe injuries (hospitalizations, amputations, loss of an eye) directly to OSHA within 24 hours — but you don't need to maintain the 300 log.
Partially exempt industries — Employers in certain low-hazard NAICS codes are also exempt regardless of size. These exemptions cover sectors like retail, finance, insurance, and certain services.
Construction is not exempt. Every construction employer with more than 10 employees must maintain OSHA 300 records. If you're a general contractor, specialty subcontractor, or any contractor with more than 10 people on payroll at any point in the year, these records are required.
Note that the 10-employee threshold is based on your company-wide headcount across the entire previous calendar year — not per project or per site. A contractor who thinks they "hover around 10" but actually had 11 or more on payroll at any point is not exempt.
What Must Be Recorded?
A work-related injury or illness must be recorded on the OSHA 300 log if it results in any of the following:
- Days away from work (beyond the day of the incident itself)
- Restricted work or job transfer — any modification to normal duties or hours as a result of the injury
- Medical treatment beyond first aid (see below)
- Loss of consciousness — even briefly
- Significant injury or illness diagnosed by a healthcare professional — including fractures, punctured eardrums, chronic irreversible disease, or cancer
- Death
The First Aid Exception
This is where most employers make mistakes. If an injury requires only first aid treatment, it is not recordable — regardless of whether a doctor or medical professional provided the treatment.
OSHA defines first aid as a specific list of treatments:
- Non-prescription medications at non-prescription strength
- Wound cleaning and covering with bandages
- Hot or cold therapy
- Non-rigid means of support (splints, slings)
- Drilling a fingernail or toenail to relieve pressure
- Draining fluid from blisters
- Eye patches
- Removing splinters from areas other than the eye
If a worker gets 2 stitches, that is medical treatment beyond first aid — recordable. If a worker gets a cut cleaned and bandaged with no stitches, that is first aid — not recordable.
Work-Relatedness
An injury is work-related if an event or exposure in the work environment caused or contributed to it, or significantly aggravated a pre-existing condition. The work environment includes your facilities, your equipment, and any location where your employees are working at the time of injury.
Certain situations are explicitly not work-related under OSHA's rule: injuries that occur when the employee is present as a member of the public, personal tasks performed outside normal work hours, symptoms solely caused by a non-work event, and voluntary participation in wellness programs or recreational activities.
Privacy Cases
For certain sensitive injuries and illnesses, you must protect the worker's identity by entering "Privacy Case" in the name column instead of the employee's name. Privacy cases include:
- Injuries to intimate body parts or reproductive systems
- Sexual assaults
- HIV infection, hepatitis, or tuberculosis
- Needlestick injuries and cuts from objects potentially contaminated with blood or infectious material
- Mental illness
Maintain a separate confidential list of privacy case names for your own records — but don't put the name on the 300 log itself.
The Deadlines You Cannot Miss
Recording deadline: Each recordable case must be entered on the Form 300 within 7 calendar days of learning that the case is recordable. The clock starts when you know about the case — not when you finish the investigation.
Annual Summary (Form 300A): At the end of each calendar year, complete the Form 300A using totals from your Form 300. A company executive must certify the form. Then:
- Post the Form 300A no later than February 1
- Keep it posted in the workplace until April 30
- This requirement applies even if you had zero recordable incidents — you still post the summary showing zeroes
Records retention: Keep completed Forms 300, 300A, and 301 for 5 years following the end of the calendar year they cover. During that period, make them available to current and former employees and their representatives upon request.
Electronic Submission Requirements
Beyond maintaining paper records, many employers must submit data electronically to OSHA through the Injury Tracking Application (ITA) at osha.gov:
- 250 or more employees: Must electronically submit 300, 300A, and 301 data annually
- 20–249 employees in designated high-hazard industries: Must submit Form 300A data only
Construction is a designated high-hazard industry. If your construction company had 20–249 employees in the prior year, you must submit your 300A summary data electronically by March 2 of the following year.
This is one of the most commonly missed requirements. Failure to submit electronically is a separate citable violation from failure to maintain the log.
The Mistakes That Generate Citations
1. Not recording cases that meet the criteria. The most common violation. Employers decide a case is minor, the worker says they're fine, or they don't want it on their record — so they don't record it. OSHA's criteria are objective: if the case meets them, it must be recorded.
2. Missing the 7-day recording deadline. Treatment gets arranged, the injury gets managed, and two weeks later no one entered it on the log. Build a system that flags cases for review and recording within 7 days of notification.
3. Not posting the Form 300A by February 1. This violation has nothing to do with having incidents. Employers with zero recordable injuries still get cited for not posting. Set a calendar reminder every year.
4. Missing the electronic submission deadline. Largely unknown until the citation arrives. Check whether your employee count and NAICS code require electronic submission.
5. Incomplete log entries. OSHA requires specific columns to be filled in: the case description, the injury type, the number of days away or restricted, and the case type checkboxes. Missing information is citable.
6. Incorrect assumption of exemption. The 10-employee and industry exemptions are specific. If you think you're exempt but aren't, you've been accumulating a citable gap in records.
7. Not retaining records for 5 years. Most contractors purge records after a year or two. When OSHA arrives and asks for 3 years of 300 logs, the absence of records is its own violation.
What OSHA Does With These Records During an Inspection
OSHA compliance officers can request your 300 logs and 301 forms during any inspection — whether triggered by a serious injury, an employee complaint, or a programmed inspection in your NAICS code. They review records going back as far as 5 years.
Recordkeeping violations are typically classified as "other than serious" but carry penalties up to $16,131 per violation under current penalty tables. Willful failure to record — where OSHA determines you intentionally chose not to record a case you knew was recordable — can reach $161,323 per violation.
The bigger risk isn't the citation. Inaccurate or missing records give OSHA a roadmap to unreported incidents — incidents that may have involved other, more serious violations worth investigating.
The Connection to Your TRIR and Bid Eligibility
When general contractors ask for your TRIR (Total Recordable Incident Rate) for prequalification, they're calculating it from your OSHA 300 data — typically a 3-year rolling average. Contractors who haven't maintained accurate 300 logs routinely get caught flat-footed in the prequalification process: they either can't produce the numbers, produce numbers that don't match what OSHA has on record, or discover their TRIR is higher than they thought.
If you want to know where you stand, use our free TRIR calculator to calculate your rate and compare it against BLS industry averages.
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If maintaining OSHA 300 recordkeeping compliance is taking time away from running projects, Greenberg Safety handles it for clients as part of our ongoing safety program work. Schedule a call or reach us at (512) 585-7070.