OSHA 300 log requirements

Who has to keep one

Two exemptions, and they work on different units. 1904.1: if your company had more than ten employees at any time during the last calendar year, you must keep OSHA injury and illness records unless the establishment is classified in a partially exempt industry under 1904.2.

1904.2 exempts establishments in the industry groups listed in Appendix A to Subpart B. Construction is not among them. And the size exemption is a company test while the industry exemption is an establishment test — a company with several establishments in different classes of business may have to keep records at some and not others.

What makes a case recordable

A work-related injury or illness goes on the log if it results in any one of six things. 1904.7(a), quoted:

The sixth is the one people miss. It stands alone: a significant diagnosis is recordable even if it does not result in death, days away, restricted work, medical treatment beyond first aid or loss of consciousness.

The columns, and the one that decides the rate

Restricted work is where logs go wrong, and it has a precise test. Restriction is recordable only if it affects one or more of the employee’s routine job functions — if it keeps them from performing a routine function, or from working the full workday they would otherwise have worked. Producing less while performing every routine function is not restricted work.

Two corollaries from the standard, both counter-intuitive:

• A restriction or transfer that applies only to the day of the injury is not recordable as restricted work.
• If a physician recommends a restriction and the employee performs every routine function anyway, you must still record it as a restricted work case — and you should make sure the employee complies with the restriction.

Vague advice like “light duty” or “take it easy” gets clarified by asking the professional two questions: can they do all routine job functions, and can they work the full shift. Two yeses mean no restriction. If you cannot get an answer, record it as restricted work.

These columns are what the TRIR calculator reads, and the DART half of that number comes entirely from days-away and restricted-work rows.

Privacy cases and access

Some cases are entered on the log without the employee’s name — a privacy case carries “privacy case” in the name column and the name is held on a separate confidential list. The category exists for a short defined set of case types, and a contractor who applies it liberally to keep names off a log a GC will read is misusing it.

Employees, former employees, their personal representatives and their authorised employee representatives have a right of access to the records. So do OSHA and, in a State Plan, the state agency. A log kept “privately” is not a category the standard recognises.

How long you hold it

You keep the 300 log, the privacy case list, the 300A summary and the 301 incident reports for five years following the end of the calendar year those records cover, and during that period you must update the 300 log to include newly discovered recordable injuries and illnesses.

The summary has its own clock: 1904.32 requires it posted no later than February 1 of the following year and kept in place until April 30, certified by a company executive. That window, and the electronic submission that sits beside it, is covered in OSHA 300A posting requirements.

A fillable version of the log itself is on the OSHA 300 log template.

Retain