The Three Forms
Federal OSHA and Cal/OSHA require employers with 11 or more employees to maintain three injury and illness recordkeeping forms. The OSHA 300 Log is a running log of all recordable injuries and illnesses throughout the year. The OSHA 300A Summary is an annual summary of the 300 Log that must be posted in the workplace. The OSHA 301 Incident Report provides detailed information about each individual incident.
What Must Be Recorded
An injury or illness is recordable if it results in death, days away from work, restricted work activity or job transfer, medical treatment beyond first aid, loss of consciousness, or a significant injury or illness diagnosed by a physician. First aid cases are not recordable. The distinction between first aid and medical treatment is critical and frequently misunderstood. First aid includes wound cleaning, bandaging, non-prescription medications, tetanus shots, and similar minor treatments.
Timeline Requirements
Injuries and illnesses must be recorded on the OSHA 300 Log within seven calendar days of learning about them. The annual 300A Summary must be posted in a conspicuous location in the workplace from February 1 through April 30 of the following year. It must be signed and certified by a company executive.
Electronic Submission
Establishments with 250 or more employees must electronically submit their 300 and 301 data annually through OSHA's Injury Tracking Application. Establishments with 20-249 employees in designated high-hazard industries must submit their 300A data. Submission deadlines are typically March 2 of the following year.
Cal/OSHA-Specific Requirements
California adds requirements beyond federal OSHA. Employers must report any serious injury, illness, or death to Cal/OSHA within 8 hours. The definition of serious injury in California is broader than the federal definition and includes any injury requiring hospitalization for more than 24 hours for purposes other than observation. Records must be maintained for a minimum of five years.
Common Errors
- Recording first aid cases that are not recordable
- Failing to record injuries because the employee did not miss work
- Not posting the 300A Summary or posting it late
- Having the summary signed by someone without authority
- Maintaining logs at a corporate office instead of the establishment where the injury occurred
- Failing to update entries when circumstances change, such as when an employee who returned to work later requires surgery