OSHA Recordkeeping Violations
Cost $16,550+ Each
Every employer with 11 or more employees must maintain OSHA 300, 300A, and 301 forms — and submit electronically by March 2 each year. Most violations aren't from negligence. They're from not knowing the rules.
Who Must Comply
Under 29 CFR 1904, OSHA recordkeeping is mandatory for most private-sector employers with 11 or more employees at any point during the prior calendar year — across virtually all industries.
Most Private Employers with 11+ Employees
Construction, manufacturing, warehousing, retail, healthcare, agriculture, transportation, utilities, and most service industries. If you had 11+ employees at any time last year, you're in.
Low-Hazard Industries (10 or fewer employees)
Employers in certain low-hazard industries (e.g., finance, insurance, legal, real estate) are exempt from routine recordkeeping — but ALL employers must report fatalities, amputations, and hospitalizations regardless of size.
Severe Injury Reporting — Everyone
Zero exceptions: every employer — regardless of size or industry — must report work-related fatalities within 8 hours and amputations, eye loss, or inpatient hospitalizations within 24 hours.
Check your exemption status: OSHA publishes a list of partially exempt industries by NAICS code. If you're unsure whether your industry qualifies, assume you're covered. The cost of a missed exemption is far less than a recordkeeping violation.
The Three Required Forms
OSHA recordkeeping revolves around three forms. Each serves a distinct purpose — and missing or misusing any one of them is a separate citable violation.
Log of Work-Related Injuries and Illnesses
The running log maintained throughout the year. Record each case within 7 calendar days of learning of a recordable injury or illness. Include case description, days away, job transfer/restriction, and injury type. Must be retained for 5 years.
Summary of Work-Related Injuries and Illnesses
Annual summary compiled from your 300 log. Must be posted in a conspicuous location accessible to employees from February 1 through April 30 each year. Must be certified by a company executive. Zero-injury years still require posting.
Injury and Illness Incident Report
A separate, detailed report for each recordable incident. Must be completed within 7 calendar days of the incident. Workers' compensation First Report of Injury forms may substitute if they contain the same information required by OSHA 301.
Annual Compliance Deadlines
OSHA recordkeeping has hard annual deadlines. Missing them is a violation even if your underlying records are perfect.
| Deadline | Requirement | Details |
|---|---|---|
| February 1 | Post OSHA 300A Summary | Must be posted through April 30 in a location employees can see. Certified by a company executive (owner, officer, or equivalent). |
| March 2 | Electronic Submission to OSHA | Establishments with 100+ employees in high-hazard industries submit 300A data electronically via OSHA's Injury Tracking Application (ITA). 20–99 employees in certain industries also required. |
| Within 7 Days | Record each incident on OSHA 300 & 301 | From the date you learn a work-related injury or illness occurred. Clock starts when you know about it, not when the incident happened. |
| 5 Years | Retain all OSHA 300/300A/301 records | Must be maintained at the establishment and produced upon OSHA request. Includes all prior years still within the retention window. |
Severe Injury Reporting Windows
Separate from routine recordkeeping, OSHA requires immediate phone reporting for the most serious incidents. These windows are tight — and they apply to every employer, regardless of size.
Report any work-related fatality to OSHA within 8 hours of learning of the death. Call OSHA directly, not just document it internally.
Any in-patient hospitalization, amputation, or loss of an eye must be reported within 24 hours — even if only one worker is affected.
How to report: Call the OSHA national hotline (1-800-321-OSHA), call your nearest Area Office, or report online at osha.gov. Failure to report within the window is a separate violation — on top of any underlying safety violations.
Top 5 Recordkeeping Mistakes
These are the mistakes OSHA compliance officers find most often during inspections. Each one is a citable violation — and they compound quickly.
Not every injury goes to the ER, but many still meet OSHA's recording threshold: days away from work, restricted duty, job transfer, medical treatment beyond first aid, or loss of consciousness. Employers often miss restricted duty cases — "light duty" still counts.
29 CFR 1904.7The annual summary must be posted from February 1 through April 30 — every year, even in years with zero recordable injuries. Many employers post it and forget to keep it up through April 30, or only post it on an HR bulletin board employees never see.
29 CFR 1904.32(b)(5)Since 2017, covered establishments must submit 300A data electronically via OSHA's ITA by March 2. Many employers don't know they're in a covered industry or size bracket — or they miss the submission window entirely. OSHA cross-references submitted data during inspections.
29 CFR 1904.41Vague case descriptions, missing check boxes (injury vs. illness type), incorrect employee information, or failing to update cases as they evolve (e.g., adding days away after they're known). OSHA inspectors review the entire log — not just recent entries.
29 CFR 1904.29Employers delay reporting hospitalizations or amputations because they're dealing with the incident itself, waiting for confirmation, or simply unaware of the 8/24-hour rules. OSHA treats late reporting as a separate violation — the clock starts when you know, not when your paperwork is ready.
29 CFR 1904.39Penalty Exposure
More OSHA Compliance Resources
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