The True ROI of Proactive First-Aid
Our CEO, William Waite, breaks down the impact on business safety and efficiency.
Read Article
OSHA Documentation & Record Keeping Requirements
Complete guide to maintaining compliant workplace safety records and reducing OSHA recordable incidents
Understanding OSHA Record Keeping Requirements
Federal OSHA regulations require most employers with more than 10 employees to maintain records of serious work-related injuries and illnesses.
Proper documentation and record keeping form the foundation of OSHA compliance. These requirements aren't just bureaucratic paperwork—they provide critical data for identifying workplace hazards, tracking trends, and implementing effective safety improvements that protect your employees.
Who Must Keep OSHA Records?
Most employers with 11 or more employees at any time during the previous calendar year must maintain OSHA injury and illness records. However, there are important exceptions:
Required Industries
Construction, manufacturing, transportation, healthcare, food service, and most other industries must maintain records.
Partially Exempt
Certain low-hazard industries (retail, finance, real estate) are partially exempt but must still report fatalities and severe injuries.
Small Employers
Employers with 10 or fewer employees are generally exempt from routine record keeping requirements.
State Requirements
State-plan states like California may have additional or more stringent record keeping requirements beyond federal OSHA.
Important: Even if your company is exempt from routine record keeping, you must still report any workplace fatality within 8 hours and any work-related inpatient hospitalization, amputation, or loss of an eye within 24 hours to OSHA.
What Incidents Must Be Recorded?
You must record work-related injuries and illnesses that result in:
- Death
- Days away from work
- Restricted work or job transfer
- Medical treatment beyond first aid
- Loss of consciousness
- Significant injury or illness diagnosed by a physician or licensed healthcare professional
First Aid vs. Medical Treatment
Understanding the difference between first aid and medical treatment is crucial for accurate record keeping. OSHA defines first aid as:
- Use of non-prescription medications at non-prescription strength
- Cleaning, flushing, or soaking wounds on the surface of the skin
- Using wound coverings such as bandages, gauze pads, or butterfly bandages
- Using hot or cold therapy
- Using non-rigid means of support (elastic bandages, wraps, non-rigid back belts)
- Using temporary immobilization devices while transporting an accident victim
- Drilling a fingernail or toenail to relieve pressure
- Draining fluid from a blister
- Using eye patches
- Removing foreign bodies from the eye using irrigation or cotton swab
- Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs, or other simple means
Anything beyond these treatments is considered medical treatment and typically must be recorded.
OSHA Required Forms
OSHA requires employers to use three specific forms for recording work-related injuries and illnesses.
OSHA Form 300: Log of Work-Related Injuries and Illnesses
The Form 300 is the cornerstone of OSHA record keeping. It's a running log where you record each recordable injury or illness that occurs at your workplace.
What to Include:
- Case number
- Employee name (or "privacy case" if applicable)
- Job title
- Date of injury or onset of illness
- Location where event occurred
- Description of injury or illness, parts of body affected
- Classification of case (days away, job transfer/restriction, other recordable cases)
- Number of days away from work or on restricted duty
Deadline: Within 7 calendar days of learning that a recordable injury or illness has occurred.
OSHA Form 300A: Summary of Work-Related Injuries and Illnesses
Form 300A is an annual summary of all injuries and illnesses recorded on the Form 300 log.
Key Requirements:
- Calculate totals from your Form 300 log
- Include average number of employees and total hours worked
- Calculate injury and illness incidence rates
- Must be signed by a company executive
- Post in a visible location from February 1 to April 30
- Even if no injuries occurred, must post with zeros
Annual Deadline: Must be completed by February 1st and posted until April 30th each year.
OSHA Form 301: Injury and Illness Incident Report
Form 301 provides detailed information about each specific incident. It's essentially an incident investigation report.
Information Required:
- Detailed employee information
- Physician or healthcare professional information
- Exact location and time of incident
- What the employee was doing when injured
- How the injury occurred
- Object or substance that directly harmed the employee
- Date of death (if applicable)
Note: You can use an equivalent form (such as a workers' compensation report) as long as it contains all required information.
Electronic Submission Requirement: Certain employers must electronically submit injury and illness data to OSHA annually. As of 2024, establishments with 250 or more employees must submit Forms 300A, 300, and 301 data. Establishments with 20-249 employees in designated high-hazard industries must submit Form 300A data.
Record Retention Requirements
OSHA requires employers to retain injury and illness records for specific periods, and these records must be readily available for inspection.
Standard Retention Periods
5 Years
Forms 300 and 301: Must retain for 5 years following the end of the calendar year covered by the records.
Annual Updates
During the 5-year retention period, you must update the OSHA 300 Log to include newly discovered recordable injuries or illnesses and show changes that occurred to already recorded cases.
30 Years
Medical Records: Employee medical records and exposure records for toxic substances must be retained for at least 30 years after employment ends.
Training Records
Safety training documentation should be retained for the duration of employment plus 3 years, though some states require longer retention.
Providing Records to Employees and OSHA
You must provide copies of records when requested:
Employee Access Rights
- Current employees: Have the right to review the OSHA 300 Log for their establishment
- Former employees: Have the right to review their own records (Form 301 or equivalent)
- Employee representatives: Authorized employee representatives can access certain records on behalf of employees
- Timeframe: Must provide access by the end of the next business day
Privacy Protection: OSHA regulations require privacy protections for certain injuries and illnesses, including:
- Cases involving intimate body parts or reproductive system
- Sexual assault cases
- Mental illness cases
- HIV, hepatitis, or tuberculosis cases
- Needlestick injuries or cuts from sharp contaminated objects
For these cases, enter "privacy case" instead of the employee's name on the Form 300 Log.
Best Practices for OSHA Record Keeping
Implementing systematic record keeping procedures ensures compliance and provides valuable data for improving workplace safety.
1. Establish Clear Reporting Procedures
Create and communicate a clear process for employees to report injuries and illnesses immediately. Every employee should know:
- Who to report to: Designate specific personnel to receive injury reports
- When to report: Require immediate reporting of all injuries, no matter how minor
- How to report: Provide multiple reporting methods (in-person, phone, online form)
- No retaliation: Clearly communicate that reporting injuries will not result in discipline
Anti-Retaliation Requirements: OSHA strictly prohibits retaliating against employees for reporting injuries or illnesses. This includes not implementing post-incident drug testing policies that discourage reporting, or using safety incentive programs that penalize employees for getting hurt.
2. Conduct Thorough Incident Investigations
Every recordable incident should trigger a formal investigation to determine root causes and prevent future occurrences:
Immediate Investigation
Investigate as soon as possible while facts are fresh and physical evidence is available.
Interview Witnesses
Speak with injured employee and any witnesses separately to get complete, unbiased accounts.
Document Evidence
Take photos, preserve equipment, and collect any physical evidence related to the incident.
Root Cause Analysis
Look beyond immediate causes to identify systemic issues that contributed to the incident.
3. Implement Digital Record Keeping Systems
Modern digital systems offer significant advantages over paper-based record keeping:
87%
Reduction in documentation errors
62%
Less time on admin tasks
100%
Audit-ready at all times
4. Regular Audits and Reviews
Schedule periodic reviews of your injury and illness records to:
- Verify accuracy and completeness of all entries
- Identify trends and patterns in workplace injuries
- Assess effectiveness of implemented corrective actions
- Prepare for potential OSHA inspections
- Update safety programs based on incident data
Monthly Review Checklist
- Verify all injuries/illnesses from the previous month are properly recorded
- Confirm Form 301 details match Form 300 entries
- Update any cases where employee status has changed (returned to work, restricted duty lifted, etc.)
- Review incident investigations and corrective action implementation
- Analyze trends in injury types, affected body parts, and departments
- Ensure privacy cases are properly handled
5. Training and Communication
Ensure all relevant personnel understand record keeping requirements:
- Supervisors and managers: Train on what constitutes a recordable injury, first aid vs. medical treatment, and how to properly investigate incidents
- HR and safety staff: Provide detailed training on completing OSHA forms accurately and maintaining records
- All employees: Communicate reporting procedures and emphasize the importance of immediate reporting
- Annual refreshers: Review procedures annually to maintain knowledge and incorporate any regulatory changes
Common Record Keeping Mistakes to Avoid
Understanding common errors helps you maintain accurate records and avoid OSHA citations.
Top Record Keeping Violations
Failing to Record
Not recording incidents that meet OSHA's recording criteria, particularly when medical treatment is provided beyond first aid.
Late Recording
Recording incidents after the 7-day deadline or failing to update the log when obtaining additional information about a case.
Days Away Errors
Incorrectly calculating days away from work or days of restricted duty, including miscounting consecutive days.
Incomplete Forms
Leaving required fields blank or providing vague descriptions that don't adequately describe the injury or how it occurred.
Privacy Violations
Failing to protect employee privacy for sensitive cases or improperly redacting employee names.
Posting Failures
Not posting the Form 300A summary during the required February 1 - April 30 timeframe or posting in an inaccessible location.
Work-Relatedness Determination Errors
One of the most common sources of confusion is determining whether an injury or illness is work-related. An injury or illness is work-related if an event or exposure in the work environment either caused or contributed to the condition or significantly aggravated a pre-existing condition.
Work-Relatedness: Key Scenarios
Generally Work-Related:
- Injuries occurring in the workplace during work hours
- Injuries during breaks if on company premises
- Injuries while traveling for work-related purposes
- Injuries at company-sponsored events
- Aggravation of pre-existing conditions due to work activities
Generally NOT Work-Related:
- Injuries from horseplay or fighting (unless part of job duties)
- Self-inflicted injuries
- Injuries from personal tasks during work hours
- Common colds and flu (unless special circumstances apply)
- Injuries during voluntary participation in wellness programs
First Aid Classification Errors
Misclassifying medical treatment as first aid is a frequent error. Remember:
These are considered medical treatment (not first aid):
- Prescription medications (at prescription strength)
- Stitches (sutures)
- Physical therapy or chiropractic treatment
- Treatment of second-degree or third-degree burns
- Application of rigid means of support (splints, casts)
- Any treatment specifically recommended by a physician
How QuickCare Simplifies OSHA Record Keeping
Our integrated safety services and digital tools help you maintain accurate records while reducing administrative burden and improving workplace safety.
Comprehensive Record Keeping Support
On-Site First-Aid Response
Our on-site paramedics provide immediate care for workplace injuries and handle critical documentation decisions in real-time.
How We Help:
- Accurate determination of first aid vs. medical treatment
- Real-time documentation of injury details
- Proper triage reduces unnecessary ER visits
- Expert witness for work-relatedness decisions
- Immediate digital reporting to your safety team
- Reduction in OSHA recordable incidents through proper first aid
Digital Documentation System
Our cloud-based platform streamlines the entire record keeping process with automated workflows and intelligent reminders.
Features Include:
- Auto-populated OSHA Forms 300, 300A, and 301
- Automated deadline tracking and reminders
- Secure, cloud-based storage accessible anywhere
- Digital signature capture for Form 300A certification
- Automated electronic submission to OSHA
- Real-time dashboards and analytics
- Mobile access for supervisors and safety staff
Incident Investigation Support
We provide expert guidance and tools for conducting thorough incident investigations that meet OSHA standards.
Our Services:
- Structured investigation templates and checklists
- Root cause analysis methodology training
- Digital evidence collection and storage
- Corrective action tracking and verification
- Expert consultation for complex cases
Training and Compliance Education
We provide comprehensive training to ensure your team understands and properly implements OSHA record keeping requirements.
Training Programs:
- OSHA record keeping fundamentals for safety staff
- Supervisor training on injury reporting procedures
- Work-relatedness determination workshops
- First aid vs. medical treatment certification
- Digital system training and support
- Annual refresher courses
Real Results from QuickCare Clients
47%
Average reduction in OSHA recordable incidents
73%
Decrease in workers' comp costs
92%
Documentation accuracy rate
5.2hrs
Saved per week on administrative tasks
Before QuickCare, our OSHA record keeping was a constant source of stress. We were never sure if we were classifying injuries correctly or if our forms were accurate. Now, with QuickCare's on-site paramedics making real-time first aid vs. medical treatment determinations and their automated documentation system, we've cut our recordable incidents by 52% and our compliance audits are effortless. It's been transformational for our safety program.
Get Expert OSHA Record Keeping Support
Don't let record keeping challenges put your business at risk. Contact QuickCare Solutions today to learn how our comprehensive safety services and digital tools can simplify your OSHA compliance while reducing workplace injuries.