OSHA Recordkeeping Requirements for Construction (2026 Guide)

OSHA recordkeeping requirements for construction are governed by 29 CFR Part 1904. Construction employers with more than 10 employees must maintain three core forms: the Log of Work-Related Injuries and Illnesses (Form 300), the Annual Summary (Form 300A), and the Injury and Illness Incident Report (Form 301). These records must be retained for five years and, in many cases, submitted electronically to OSHA annually.

Recordkeeping violations are among the most common — and most preventable — citations in construction. OSHA issued over 1,300 recordkeeping citations in the most recent fiscal year, with penalties averaging $4,000-$8,000 per violation. The difference between a citation and a clean inspection often comes down to whether records exist, are accurate, and are accessible.

Who Must Keep OSHA Records

All construction employers are subject to OSHA recordkeeping requirements unless they qualify for a specific exemption. There are two partial exemptions:

Size Exemption (29 CFR 1904.1)

Employers with 10 or fewer employees at all times during the previous calendar year are exempt from routine recordkeeping. However, this exemption does not apply to:

• Fatality/severe injury reporting obligations (8-hour and 24-hour rules)
• Specific OSHA standards that require their own records (e.g., hearing conservation, respiratory protection)
• Bureau of Labor Statistics (BLS) survey participation when selected

Key detail: the 10-employee threshold applies to your peak employment at any point during the year. If you had 11 employees for even one pay period, you are required to maintain records for the entire year.

Industry Exemption (29 CFR 1904.2)

Certain low-hazard industries are partially exempt from routine recordkeeping. Construction (NAICS codes 23xxxx) is not on the exempt list. Construction employers with more than 10 employees must maintain OSHA records — no exceptions.

The Three Required OSHA Recordkeeping Forms

Form 300: Log of Work-Related Injuries and Illnesses

Form 300 is your running log of every recordable work-related injury and illness during the calendar year. For each recordable case, you must document:

• Employee name and job title
• Date and location of the injury/illness
• Description of what happened (include the object or substance involved)
• Classification: death, days away from work, restricted work, transfer, or other recordable
• Number of days away or restricted (if applicable)

Timing: Each recordable injury must be logged within 7 calendar days of learning about it. Do not wait until the end of the month or quarter.

Form 300A: Summary of Work-Related Injuries and Illnesses

Form 300A is the annual summary of your Form 300 data. It must be:

• Completed by February 1 of the year following the records
• Certified (signed) by a company executive
• Posted in a visible workplace location from February 1 through April 30

Missing the posting window is one of the most common recordkeeping violations — and one of the easiest to avoid. Set a calendar reminder for February 1.

Form 301: Injury and Illness Incident Report

Form 301 is a detailed report for each individual recordable case. It captures more specific information than Form 300, including how the injury occurred, what the employee was doing at the time, and what object or substance was involved. Workers' compensation first reports of injury can substitute for Form 301 if they contain equivalent information.

What Counts as a Recordable Injury or Illness

Not every workplace injury requires recording. OSHA uses specific criteria defined in 29 CFR 1904.7. An injury or illness is recordable if it results in any of the following:

• Death
• Days away from work — any time off beyond the day of injury
• Restricted work or job transfer
• Medical treatment beyond first aid — this is the most commonly misunderstood criteria
• Loss of consciousness
• Significant injury or illness diagnosed by a physician or licensed healthcare professional

First Aid vs. Medical Treatment

The line between first aid and medical treatment determines recordability. OSHA defines first aid as a specific list of treatments (29 CFR 1904.7(a)):

• Wound cleaning, flushing, or soaking
• Bandages, butterfly closures, or Steri-Strips
• Non-prescription medications at nonprescription strength
• Tetanus shots (as preventive, not treatment)
• Drilling fingernails/toenails to relieve pressure
• Eye patches, rigid finger guards, non-rigid wraps
• Hot or cold therapy, elastic bandages
• Drinking fluids for heat stress relief

Anything not on this list is medical treatment, making the case recordable. Sutures, prescription medications, and physical therapy are not first aid under OSHA's definition.

Electronic Submission: OSHA ITA Requirements

OSHA's Injury Tracking Application (ITA) requires certain employers to electronically submit recordkeeping data annually. For construction, the requirements are:

• 20-249 employees in high-hazard industries (construction is included): Submit Form 300A data annually
• 100+ employees in high-hazard industries: Submit Form 300, Form 300A, and Form 301 data annually
• Deadline: Typically March 2 of the following year

Submissions are made through OSHA's ITA portal at injurytracking.dol.gov. Failure to submit or late submission can result in penalties up to $16,550 per violation.

Record Retention Requirements

OSHA recordkeeping forms must be retained for five years following the end of the calendar year they cover. During this five-year window, employers must:

• Update Form 300 to reflect reclassification of cases (e.g., a restricted-duty case that later requires days away)
• Make records available to current and former employees, their representatives, and OSHA upon request
• Provide copies of Form 300, 300A, and 301 within specified timeframes when requested

Multi-site contractors: If you operate multiple construction sites, you must maintain a separate Form 300 log for each establishment where employees report to work. Temporary worksites lasting less than one year can be linked to the employee's home office for recordkeeping.

Fatality and Severe Injury Reporting (Separate from Recordkeeping)

In addition to recordkeeping, all employers — regardless of size or exemption status — must report:

• Fatalities: Within 8 hours of learning about the death
• In-patient hospitalizations: Within 24 hours
• Amputations: Within 24 hours
• Loss of an eye: Within 24 hours

Reports can be made by calling the nearest OSHA Area Office, calling 1-800-321-OSHA (6742), or using OSHA's online reporting portal. Late reporting — or failure to report — is treated as a serious violation with penalties up to $16,550.

Most Common OSHA Recordkeeping Violations in Construction

Based on OSHA enforcement data, the most frequently cited recordkeeping problems in construction are:

1. Not recording recordable injuries — Misclassifying medical treatment as first aid, or simply failing to log recordable cases. This is the #1 recordkeeping citation.
2. Not posting Form 300A — Failing to post the annual summary from February 1 through April 30, or posting it without executive certification.
3. Incomplete Form 300 entries — Missing descriptions, incomplete job titles, or failing to update case outcomes when they change.
4. Late reporting of severe injuries — Exceeding the 8-hour (fatality) or 24-hour (hospitalization, amputation, eye loss) reporting windows.
5. Failure to retain records — Discarding forms before the five-year retention period expires, or being unable to produce them when requested.

Each of these violations is individually citable. A single inspection can result in multiple recordkeeping citations if the inspector identifies several deficiencies.

Recordkeeping Best Practices for Construction Contractors

• Designate a recordkeeper. Assign one person responsibility for maintaining OSHA logs. Unclear ownership is the root cause of most recordkeeping failures.
• Log injuries within 24 hours. OSHA gives you 7 days, but recording immediately improves accuracy and prevents backlogs.
• Use the first aid checklist. Post OSHA's first aid list where supervisors can reference it. When in doubt, record the case.
• Calendar your annual obligations. Set reminders for Form 300A completion (Feb 1), posting period (Feb 1 - Apr 30), and electronic submission deadline (Mar 2).
• Store records securely for 5 years. Use a consistent filing system — digital or physical — that allows retrieval within minutes during an inspection.
• Review records quarterly. Check for incomplete entries, cases that need updating, and overall accuracy.