OSHA Forms 300, 300A & 301: Recordkeeping Guide for Contractors

Why OSHA Recordkeeping Matters

OSHA requires most employers to maintain records of work-related injuries and illnesses using three standardized forms: Form 300 (the Log), Form 300A (the Annual Summary), and Form 301 (the Incident Report). These forms serve as the foundation of OSHA's injury and illness surveillance system and are among the first documents an inspector will request during a jobsite visit.

For construction contractors, recordkeeping is not optional paperwork — it is a regulatory obligation with real enforcement consequences. Failure to maintain accurate records, failure to post the annual summary, or failure to submit electronic data can each result in citations carrying penalties up to $16,550 per violation. More critically, incomplete or inaccurate recordkeeping signals to OSHA that your safety management system has gaps, which can trigger deeper inspection scrutiny.

The recordkeeping requirements are established under 29 CFR Part 1904 (Recording and Reporting Occupational Injuries and Illnesses). This guide walks through each form, who must comply, and the specific requirements that trip up contractors most often.

Who Must Keep OSHA Records

Not every employer is required to maintain OSHA injury and illness records. The obligation depends on two factors: the number of employees and your industry classification.

Employer Size Threshold

If you had 10 or fewer employees at all times during the previous calendar year, you are partially exempt from routine recordkeeping requirements under 29 CFR 1904.1. You do not need to maintain Forms 300, 300A, or 301 unless OSHA or the Bureau of Labor Statistics (BLS) specifically requests you to do so in writing.

However, all employers — regardless of size — must still report to OSHA:

• Any workplace fatality within 8 hours
• Any in-patient hospitalization within 24 hours
• Any amputation within 24 hours
• Any loss of an eye within 24 hours

These severe injury reporting requirements under 29 CFR 1904.39 apply to every employer in every industry, even if you are otherwise exempt from recordkeeping.

Partially Exempt Industries

Certain low-hazard industries listed in Appendix A to Subpart B of 29 CFR 1904 are partially exempt from routine recordkeeping. These are primarily retail, service, and finance industries with historically low injury rates. The exemption is based on your North American Industry Classification System (NAICS) code.

Construction is NOT a partially exempt industry. All construction employers with more than 10 employees must maintain OSHA 300, 300A, and 301 forms. This includes general contractors, specialty trade contractors, and heavy and civil engineering construction companies.

Construction Industry Requirements

Construction falls under NAICS codes 236 (Construction of Buildings), 237 (Heavy and Civil Engineering Construction), and 238 (Specialty Trade Contractors). All three categories are covered by the full recordkeeping requirements. If you are a construction employer with 11 or more employees at any point during the year, you must:

• Maintain OSHA Form 300 at each establishment
• Complete OSHA Form 301 (or equivalent) for each recordable incident
• Post the OSHA Form 300A annual summary from February 1 through April 30
• Retain all records for five years
• Submit data electronically if you meet the size threshold for your NAICS code

An “establishment” in construction typically means the company's fixed office location, not individual jobsites — unless employees report directly to jobsites and not to a fixed office. In that case, you must keep records at the location where employees report or maintain them at a central office with the ability to produce them within four business hours of a request. See OSHA Recordkeeping Requirements for Construction for detailed guidance on multi-site recordkeeping.

OSHA Form 300 — Log of Work-Related Injuries and Illnesses

Form 300 is the master log that tracks every recordable work-related injury and illness at your establishment throughout the calendar year. Each recordable event gets one line entry on the log, creating a running record of workplace incidents. OSHA uses this data to identify patterns, target inspections, and measure industry safety performance.

What It Is

The OSHA 300 Log is a spreadsheet-style form with columns for the case number, employee name, job title, date of injury, where the event occurred, a description of the injury or illness, how the injury was classified, and whether the case resulted in death, days away from work, restricted duty, or job transfer. You maintain one Form 300 per establishment per calendar year.

The form itself is available as a free download from osha.gov/recordkeeping/forms. You are not required to use the exact OSHA form — you can use any equivalent format (including digital systems) as long as it captures the same data fields in a readable format and can be produced upon request.

What to Record: Recordable Injury and Illness Criteria

Not every workplace injury requires a Form 300 entry. An injury or illness is recordable only if it is:

1. Work-related: The injury or illness resulted from an event or exposure in the work environment (29 CFR 1904.5)
2. A new case: The employee has not previously experienced a recorded injury or illness of the same type that affects the same body part (29 CFR 1904.6)
3. Meets one or more recording criteria under 29 CFR 1904.7

The recording criteria under 1904.7 include:

• Death
• Days away from work
• Restricted work activity or job transfer
• Medical treatment beyond first aid
• Loss of consciousness
• A significant injury or illness diagnosed by a physician or other licensed healthcare professional

The first aid distinction is critical. If an injury requires only first aid treatment, it is not recordable — even if a doctor administers it. First aid is defined in 29 CFR 1904.7(a) and includes: non-prescription medications at nonprescription strength, tetanus immunizations, wound cleaning and bandaging, butterfly bandages and Steri-Strips, hot or cold therapy, non-rigid splints, and drilling of a fingernail to relieve pressure. Anything beyond this list constitutes medical treatment and triggers recordability.

How to Fill Out Form 300

Each line on the Form 300 captures the following information:

• Case number: A sequential number you assign (e.g., 001, 002, 003 for the year)
• Employee name: Full legal name of the injured or ill employee
• Job title: The employee's regular job title at the time of injury
• Date of injury/illness: The date the injury occurred or the illness was diagnosed
• Where the event occurred: The specific location (e.g., “loading dock,” “3rd floor east wing,” “excavation trench at Oak Street site”)
• Description: A brief description of the injury, the body part affected, and the object or substance that caused it (e.g., “strained lower back lifting concrete block”)
• Classification: Check the appropriate column — death, days away from work, job transfer or restriction, or other recordable case
• Days away / Days restricted: The number of calendar days away from work or on restricted duty (cap at 180 days for counting purposes)
• Injury or illness type: Check the column indicating whether it is an injury, skin disorder, respiratory condition, poisoning, hearing loss, or all other illnesses

Common Mistakes on Form 300

These are the errors that OSHA compliance officers most frequently identify when reviewing Form 300 logs during inspections:

• Not recording cases promptly: Entries must be made within 7 calendar days of learning about a recordable injury. Backdating or batch-entering cases at year-end is a red flag.
• Misclassifying first aid as recordable (or vice versa): The first aid/medical treatment boundary is the most common source of recording errors. When in doubt, review the specific first aid definitions in 29 CFR 1904.7(a).
• Counting days incorrectly: Count calendar days, not work days. Do not count the day of injury. Begin counting the day after the injury.
• Failing to update the log: If a case initially classified as “other recordable” later results in days away from work, you must update the original entry.
• Using vague descriptions: “Hurt arm” is insufficient. The description should identify the body part, the nature of the injury, and the mechanism (e.g., “lacerated right forearm on exposed rebar”).
• Not maintaining a separate log per establishment: Multi-site employers must keep separate Form 300 logs for each establishment.

OSHA Form 300A — Summary of Work-Related Injuries and Illnesses

Form 300A is the annual summary of the data recorded on your Form 300 throughout the year. It aggregates your total case counts and days by category, includes your establishment's average number of employees and total hours worked, and must be signed by a company executive before posting.

Annual Summary Requirements

At the end of each calendar year, you must:

1. Review the Form 300 log to verify that all entries are complete and accurate
2. Calculate the annual totals for each column
3. Calculate the average number of employees who worked at the establishment during the year
4. Calculate the total hours worked by all employees during the year
5. Enter this information on the Form 300A
6. Have a company executive certify the form by signing and dating it

If you had zero recordable injuries or illnesses, you must still complete and post the 300A with zeros. An establishment with no incidents does not get an exemption from the posting requirement.

Posting Period: February 1 Through April 30

The certified Form 300A must be posted in a conspicuous place where notices to employees are customarily posted. The posting must remain in place from February 1 through April 30 of the year following the year covered by the form. For example, the 2025 annual summary must be posted from February 1, 2026 through April 30, 2026.

Failure to post the 300A is one of the most commonly cited recordkeeping violations. OSHA compliance officers routinely check for the posted summary during any inspection — it is a visible, easily verified requirement, and missing it demonstrates a basic gap in your recordkeeping program.

Who Must Sign and Certify

The Form 300A must be certified (signed) by a company executive. Under 29 CFR 1904.32(b)(3), the certifying official must be one of the following:

• An owner of the company (sole proprietor, partner, or corporate officer)
• An officer of the corporation
• The highest-ranking company official working at the establishment
• The immediate supervisor of the highest-ranking company official at the establishment

The certification states that the official has examined the OSHA 300 Log and reasonably believes, based on their knowledge of the process for recording information, that it is true, accurate, and complete. A safety manager or HR coordinator can prepare the form, but an executive-level official must sign it.

Electronic Submission Requirements (ITA)

Beyond posting, certain employers must also submit Form 300A data electronically to OSHA through the Injury Tracking Application (ITA). Construction establishments with 20 to 249 employees must submit Form 300A data annually. Establishments with 250 or more employees must submit data from all three forms (300, 300A, and 301). See the Electronic Recordkeeping section below for full details.

OSHA Form 301 — Injury and Illness Incident Report

Form 301 is the detailed incident report for a single work-related injury or illness. While Form 300 captures a one-line summary per case, Form 301 tells the full story: what the employee was doing, how the injury happened, what object or substance was involved, and what treatment was provided.

When to Complete It

You must complete a Form 301 — or an equivalent form — within 7 calendar days of receiving information that a recordable work-related injury or illness has occurred. This deadline is the same as the deadline for entering the case on Form 300.

In practice, many contractors complete the Form 301 and the Form 300 entry at the same time. The key is not to delay. OSHA views late entries as evidence of a recordkeeping system that is not functioning, which can escalate inspector scrutiny of your entire safety program.

What Information to Include

Form 301 captures detailed information in three sections:

Section A — About the employee:

• Full name, address, date of birth, gender
• Date of hire

Section B — About the case:

• Date and time of the event
• What the employee was doing just before the incident (the activity, the tools, materials, or equipment the employee was using)
• What happened (describe the event that directly caused the injury — e.g., “employee fell 8 feet from scaffold when guardrail gave way”)
• What was the injury or illness (identify the body part and the nature of the injury — e.g., “fractured left tibia”)
• What object or substance directly harmed the employee (e.g., “concrete floor,” “circular saw blade”)
• Date of injury or illness onset

Section C — About the treatment:

• Name and address of the treating physician or healthcare facility
• Was the employee treated in an emergency room?
• Was the employee hospitalized overnight as an in-patient?

Relationship to Workers' Compensation First Report of Injury

OSHA does not require you to use the exact Form 301 format. Under 29 CFR 1904.29(b)(4), you can use a workers' compensation first report of injury or an equivalent form as a substitute for Form 301, provided the substitute form contains the same information required by Form 301.

Most state workers' compensation first report of injury forms capture substantially the same data. Many contractors use the workers' comp report as their Form 301 equivalent to avoid duplicate paperwork. If your state's form does not capture all the required information, you must supplement it with the missing fields.

For a full list of documentation OSHA expects contractors to have on hand, see OSHA Required Documentation for Contractors.

Electronic Recordkeeping (ITA)

Since 2017, OSHA has required certain employers to submit injury and illness data electronically through the Injury Tracking Application (ITA). The electronic reporting rule was expanded in 2024, and the current requirements significantly impact construction employers.

Who Must Submit Electronically

The electronic submission requirements are tiered by establishment size:

The employee count is based on the peak employment at the establishment during the previous calendar year — not the current headcount. If you had 22 employees at any point during 2025, you must submit 300A data for 2025.

Submission Deadlines

The annual electronic submission deadline is March 2 of the year following the year covered by the forms. For calendar year 2025 data, the submission deadline is March 2, 2026. If March 2 falls on a weekend, the deadline shifts to the next business day.

Late submissions can result in citations. OSHA has increasingly enforced the electronic submission requirement, and the data submitted is used to target programmed inspections. Establishments with higher-than-average injury rates appearing in the ITA data are more likely to receive a planned inspection visit.

OSHA Injury Tracking Application

All electronic submissions are made through the ITA portal at injurytracking.osha.gov. To submit, you must:

1. Create an account using your establishment's legal name, address, and NAICS code
2. Enter your Employer Identification Number (EIN)
3. Enter your establishment's average annual employment and total hours worked
4. Enter the injury and illness summary data from your Form 300A (or from all three forms if you have 250+ employees)
5. Certify and submit the data

OSHA publishes the submitted data publicly. This means your establishment's injury and illness rates are visible to competitors, clients, general contractors, and insurers. Accurate recordkeeping is important not just for compliance but for how your company appears in the public dataset.

Common Recordkeeping Violations and Penalties

Recordkeeping violations are classified as other-than-serious in most cases, carrying penalties up to $16,550 per violation. However, OSHA can and does cite recordkeeping failures as willful violations when there is evidence of intentional under-recording — with penalties up to $165,514.

Failure to Maintain OSHA 300 Log

The most basic recordkeeping violation: not having a Form 300 log at all, or having a log with missing entries. OSHA typically identifies this during an inspection when the compliance officer requests the log and either cannot find it or finds obvious gaps. If a company has workers' compensation claims for recordable injuries that do not appear on the 300 Log, the discrepancy will generate a citation.

Failure to Post the 300A Summary

During any inspection, OSHA compliance officers routinely check whether the current year's Form 300A is posted. If the posting period is February 1 through April 30 and your 300A is not posted in a conspicuous location, you will receive a citation. This is one of the easiest violations to avoid — and one of the most common to receive.

Under-Recording Injuries and Illnesses

Under-recording is the most serious recordkeeping offense. It occurs when an employer fails to record injuries that meet the recording criteria, either through negligence or intentional suppression. OSHA has made under-recording a national enforcement priority and conducts targeted audits by comparing workers' compensation data, emergency room records, and employee interviews against Form 300 logs.

When OSHA finds evidence of intentional under-recording, the violation is classified as willful, with penalties of $11,524 to $165,514 per under-recorded case. A single audit can uncover multiple under-recorded cases, resulting in cumulative penalties that far exceed the penalties for the underlying safety violations.

Failure to Submit Electronic Data

As the ITA requirement has expanded, OSHA has begun citing employers who fail to submit their electronic data by the March 2 deadline. Because submission records are digital and easily auditable, OSHA can identify non-submitters programmatically and issue citations without conducting an on-site inspection.

Penalty Amounts for Recordkeeping Violations

For complete penalty amounts across all violation types, see OSHA Fines 2026: Current Penalty Amounts. To estimate your specific exposure, use the OSHA Penalty Calculator.

Key Recordkeeping Deadlines at a Glance

Frequently Asked Questions About OSHA Recordkeeping Forms

Related Resources

• OSHA Violations: Types, Penalties & How to Respond (2026)
• OSHA Fines 2026: Current Penalty Amounts & How to Reduce Them
• OSHA Recordkeeping Requirements for Construction
• OSHA Required Documentation for Contractors
• OSHA Penalty Calculator
• OSHA Inspection Defense Kit
• OSHA Citation Response System