January 10, 2024

Commonly asked questions about OSHA’s recordkeeping and electronic reporting requirements

With OSHA recordkeeping and electronic reporting deadlines fast approaching, it’s time for businesses across the country to compile their 2023 injury and illness data. Starting this year, certain establishments with 100 or more employees in high-hazard industries must also submit more detailed information about each recordable event. To help you prepare and understand the additional requirement, Texas Mutual’s safety services team has compiled responses to frequently asked questions we receive during OSHA recordkeeping season.

Q: What is the purpose of OSHA’s recordkeeping and reporting requirements?
A: Recordkeeping and reporting requirements:

• Support OSHA’s mission of ensuring safe and healthy work conditions.
• Provide transparency to your employees on the company’s injury and illness record.
• Help the agency track trends and determine methods of inspection and outreach.

Recordkeeping requirements

Q: Am I required to keep records?
A: Employers with more than 10 employees, who are not listed as an exempt industry, are required to keep records of injuries and illnesses using OSHA’s forms or equivalent forms.

You are also required to keep records if OSHA or the Bureau of Labor Statistics has asked you to do so in writing. We recommend that you keep records even if you’re not required to.

Q: What types of injuries and illnesses do I need to include on our log?
A: In general, you should record work-related injuries and illnesses that resulted in death, loss of consciousness, days away from work, restricted work duties, job transfer or medical treatment beyond first aid. To view additional criteria and more detailed information, download OSHA’s forms and instructions.

Q: Can I use the loss runs my workers’ compensation carrier provides to complete the summary?
A: No, your loss runs may not match the information you are required to include on your OSHA 300 log. This is because not all recordable injuries are filed as workers’ comp claims (and vice versa) and the days away from work are tracked differently for the claims process.

Q: If an employee misses a partial day of work, how do I record that on the log?
A: The day the injury occurred is not counted. Any partial days after the date of injury are recorded as a day of job transfer or restriction for recordkeeping purposes.

Q: What if an injured employee’s lost time started in 2023 and carried over into 2024? Do I have to record the injury on my 2023 log and my 2024 log?

A: No, you only record the injury on one log. All lost time for an injury that occurred in 2023 should be recorded on the 2023 log. If the injured employee is still out on February 1, 2024, estimate the total number of days you expect them to be out and record that number on your 2023 log. You can amend the record later, if needed, once the employee returns to work. For recordkeeping purposes, OSHA places a 180-day maximum on lost workdays.

Q: How can I calculate my incidence rate?
A: You can calculate your incidence rate by using this formula:

Total number of injuries and illnesses X 200,000 / Number of hours worked by all employees = Total recordable case rate

The Bureau of Labor Statistics website offers more information about calculating incidence rates, as well as an incidence rate calculator tool.

Q: If we have multiple office locations, does each location fill out the OSHA 300 log and post the summary?
A: You must keep a separate OSHA 300 log for each physical location that is expected to be in operation for one year or longer.

Q: We have temporary locations. Do they fill out the OSHA 300 log, or is it just the main location that fills it out?
A: You must keep a separate OSHA 300 log for each physical location that is expected to be in operation for one year or longer. If you have locations that will be in operation for less than one year, you do not have to keep separate OSHA 300 logs. You may keep one log that covers all of your short-term establishments or choose to group them on separate logs based on company divisions or geographic regions.

Q: Our agency provides temporary workers. If an employee got injured at a host employer job site, who is responsible for recording the injuries?
A: OSHA requires the employer who provides day-to-day supervision to record temporary worker injuries. That typically means the host employer is required to record the injury.

Q: Do we need to record all COVID-19 cases?
A: You must record cases of COVID-19 if the case is confirmed as defined by the Centers for Disease Control and Prevention (CDC), work-related and involves one or more of the general recording criteria. OSHA expects employers to make a good faith effort to determine work-relatedness based on reasonably available information. Refer to OSHA's updated interim enforcement guidance for more information on handling COVID-19.

Q: What actions do I need to take after I’ve completed the forms?
A: You should file all completed OSHA forms in a secure location and must maintain them for at least five years. You must also post the previous year’s OSHA Form 300A in your workplace from February 1 to April 30. For example, you must have the OSHA Form 300A covering calendar year 2023 posted in your workplace from February 1, 2024 through April 30, 2024. OSHA requires employers to post the form in a common area where notices to employees are usually kept.

Q: What should I include on the form if we’ve had zero recordable injuries or illnesses?
A: You must fill out and post the OSHA Form 300A even if your business had no recordable events during the calendar year. In this case, you should include a “0” for each entry in the number of cases, number of days and injury and illness types sections.

Electronic reporting requirements

Q: Do we need to submit the Form 300A electronically to OSHA?
A: The electronic reporting rule is based on the size of the establishment (a single physical location) rather than the size of the entire company. Establishments with 20 to 249 employees, that are listed on the required industry list, must electronically report injury and illness data from the 300A summary form. Establishments with 250 or more employees, who are currently required to keep records must also electronically report this information.

Q: Do we also need to submit Form 300 and Form 301 electronically to OSHA?
A: As part of a new requirement this year, establishments with 100 or more employees, that are listed on the required industry list must also report more detailed information about each recordable injury and illness from the OSHA Form 300 log and the OSHA Form 301 incident report. Alternatively, you can use this tool to determine if you are required to submit this additional information.

Q: Where do I submit my required data to OSHA?
A: As of October 2022, the OSHA Injury Tracking Application has transitioned to using Login.gov. The deadline for submitting information from the 2023 Form 300A, 300 and/or 301 is March 2, 2024. Visit OSHA’s Injury Tracking Application page for more information.

More questions?
For more information about recordkeeping requirements, visit OSHA’s website. The site includes a searchable database of FAQs.

You can also watch a recording our OSHA recordkeeping and reporting webinar from January 24, 2023.

Note: Texas Mutual Insurance Company offers this information as general guidance. The company does not represent OSHA, nor do its employees speak on OSHA’s behalf. This guidance does not constitute legal advice. Texas Mutual encourages you to review the governmental regulations and, for specific guidance, contact your local OSHA field office or consult with legal counsel.