OSHA Recordkeeping Requirements 2026: Complete Guide

Safety managers have a lot on their plate, and keeping up with OSHA’s recordkeeping requirements is crucial for compliance. Accurate injury and illness records not only help avoid fines but also improve workplace safety by highlighting hazards. OSHA is prioritizing enforcement, data accuracy, and electronic reporting in 2026, so now is the time to ensure your recordkeeping practices are up to par. This complete guide breaks down who needs to keep OSHA records, what incidents to record, which forms to use, and how training courses and checklists can simplify compliance.

OSHA Recordkeeping Overview and Purpose

OSHA’s recordkeeping rules (29 CFR Part 1904) require certain employers to document work-related injuries and illnesses. The purpose is to help employers, employees, and OSHA identify and correct hazards before they cause more harm. In essence, there are three main components to OSHA recordkeeping:

• Recording – Logging work-related injuries and illnesses on OSHA forms (300, 300A, 301). This is an ongoing process throughout the year.
• Reporting – Notifying OSHA of severe incidents (fatalities or serious injuries) within specific time frames (more on this below).
• Electronic Submission – Submitting annual summary data (and in some cases detailed case data) to OSHA’s online Injury Tracking Application, if your establishment meets certain size/industry criteria.

OSHA recordkeeping is required for most businesses. However, there are exemptions for very small employers and low-risk industries. We’ll explore those next, as well as the state-specific considerations for OSHA recordkeeping.

Who Must Keep OSHA Injury and Illness Records?

Safety managers have a lot on their plate, and keeping up with OSHA’s recordkeeping requirements is crucial for compliance. This OSHA recordkeeping update for 2026 is especially important because accurate injury and illness records not only help avoid fines but also improve workplace safety by highlighting hazards. OSHA is prioritizing enforcement, data accuracy, and electronic reporting in 2026, so now is the time to ensure your recordkeeping practices are up to par. This complete guide breaks down who needs to keep OSHA records, what incidents to record, which forms to use, and how training courses and checklists can simplify compliance.

Low-Hazard Industries Exemption: OSHA exempts certain low-hazard industries from routine recordkeeping, regardless of size. These are industries with historically low rates of injuries (OSHA provides a list by NAICS code). Examples include small retail shops, insurance and real estate offices, educational institutions, outpatient clinics, and dental offices. If your business falls into one of these categories, you do not need to keep OSHA injury logs under normal circumstances. However, all employers – even exempt ones – must still follow OSHA’s reporting rules for serious incidents (e.g. report a fatality or severe injury, see the Reporting section below).

Federal vs State OSHA: Federal OSHA’s recordkeeping rules apply to most private sector employers. About half of U.S. states operate their own OSHA-approved State Plan, which covers state/local government workplaces and often the private sector as well. These state programs (like Cal/OSHA in California) generally adopt OSHA’s recordkeeping requirements or have equivalent rules. Always check if your state has additional reporting criteria or forms, but in general the core recordkeeping obligations are similar nationwide.

Multiple Establishments and Contractors: If your company has multiple locations, you need a separate OSHA 300 log for each establishment expected to be operational for at least a year. Corporate safety directors should ensure each site maintains its log and summary. For multi-employer worksites (like construction sites with subcontractors), each employer is responsible for recording injuries of their own workers – even temp or contract workers if you supervise them day-to-day. Coordination with contractors is key so that injuries are recorded by the correct employer.

What Injuries and Illnesses Are Recordable?

Not every minor scrape or sniffle goes on the OSHA log – only recordable injuries and illnesses must be documented. OSHA has specific criteria for what makes a case recordable. In plain terms, a work-related injury or illness is generally recordable if it results in any of the following outcomes:

• Death of the employee (work-related fatality).
• Days away from work (any time missed after the day of the incident due to the injury/illness).
• Restricted work or job transfer (the worker can’t do their routine job or is moved to a different job due to the condition).
• Medical treatment beyond first aid (any care beyond simple first aid measures, such as stitches, prescription medication, surgery, etc.).
• Loss of consciousness (even if the worker wakes up quickly, it’s recordable if caused by work).
• Significant injury or illness diagnosed by a health professional – for example, a doctor-diagnosed case of work-related cancer, chronic irreversible disease (like silicosis), a fractured bone or cracked tooth, or a punctured eardrum.

It’s important to note the injury or illness must be work-related to be recordable. OSHA assumes an injury is work-related if it happened in the work environment or was caused by work activities, unless a specific exception applies (like symptoms purely due to personal health conditions). Work-relatedness can sometimes be a gray area – if in doubt, consult OSHA’s guidelines or a safety professional.

Also, the case must be a new case, not a recurrence of an old injury (unless a new exposure at work aggravated it significantly).

Minor incidents that only require first aid are not recordable. OSHA has a list of treatments considered first aid (like using a bandage, tetanus shot, cleaning a wound, etc.). If the case stays at that level, you don’t record it. But the moment it requires more advanced treatment or leads to lost time or restrictions, it becomes recordable.

OSHA’s official recordkeeping decision tree provides a step-by-step guide to determine if an injury or illness is recordable. This flowchart prompts employers to consider whether an incident is work-related, whether it’s a new case, and if it meets any of the general recording criteria (death, days away, restricted work, medical beyond first aid, etc.). Using such decision trees or checklists during incident investigations can help ensure consistent and accurate recordability determinations.

OSHA Recordkeeping Forms: 300 Log, 300A, and 301 Incident Report

Once you’ve determined an incident is recordable, it needs to be documented on the OSHA forms. OSHA has three primary recordkeeping forms:

• OSHA Form 300 – Log of Work-Related Injuries and Illnesses: This is the running log where each recordable case is entered as a line item. It includes columns for date, employee, injury description, outcome (days away, job transfer, etc.), and classification of the case. You should log each recordable injury or illness within 7 calendar days of learning about it. The OSHA 300 log is typically kept on-site and updated throughout the year.
• OSHA Form 301 – Injury and Illness Incident Report: The Form 301 is a more detailed report for each recordable case. It includes information like how the injury/illness occurred, the body part affected, treatment given, and other details. You can use an equivalent form (such as a state workers’ comp first report of injury, if it contains the same info). A Form 301 (or equivalent incident report) should be completed for each entry on your OSHA 300 log.
• OSHA Form 300A – Summary of Work-Related Injuries and Illnesses: This is the annual summary that totals all the incidents from your 300 log for the year. It shows the number of cases, total days lost, and injury types, but no personally identifying employee info. At the end of each calendar year, you tally up the OSHA 300 log and transfer the totals to the 300A summary form.

Posting and Certifying the Annual Summary: OSHA requires that you post the Form 300A summary in a visible area of the workplace from February 1 through April 30 each year. This lets employees see the total recordable injuries/illnesses for the previous year. The 300A must be certified with a signature by a company executive (highest ranking official at the site or their designee) attesting that it’s true and complete. Failing to post the 300A or have it signed can result in OSHA citations, so mark those dates on your calendar.

Retention of Records: Completed OSHA logs and forms must be kept on file for 5 years following the end of the year they cover. During that period, you must also update the OSHA 300 log if new information arises or a case’s classification changes (for example, if an injury that was recorded as restricted work later results in days away, you’d update the log). The older logs and 301s should be readily accessible – OSHA or workers may request to see them. Employees, former employees, or their representatives have the right to review the 300 log (with personal names removed) and to get copies of their own 301 incident reports on request, by the next business day in most cases.

In summary, maintain your OSHA 300 log continuously, complete a 301 report for each entry, and produce the 300A summary at year-end for posting and submission as required. Treat these records as important compliance documents – keep them accurate and up-to-date.

Reporting Serious Incidents to OSHA (Recordkeeping vs. Reporting)

It’s easy to confuse OSHA’s reporting requirements with recordkeeping. They are related but distinct obligations:

• Recordkeeping is what we’ve discussed – maintaining logs of all recordable injuries and illnesses throughout the year.
• Reporting means contacting OSHA to notify them of particularly serious events within a short timeframe.

What needs to be reported directly to OSHA? All employers must report the following incidents:

• Any work-related fatality – must be reported within 8 hours of learning of the death.
• Any work-related in-patient hospitalization of one or more employees – report within 24 hours.
• Any work-related amputation (loss of limb) – report within 24 hours.
• Any work-related loss of an eye – report within **24 hours】.

This reporting requirement applies to every employer, even those exempt from keeping injury logs. So, for example, a small company with 5 employees doesn’t have to maintain an OSHA 300 log, but if a serious incident like an amputation occurs, they still must call OSHA’s hotline or report online within 24 hours.

Reporting can be done by calling your local OSHA area office (or 1-800-321-OSHA off-hours) or via OSHA’s online reporting form. Be prepared to give details like what happened, how many were hurt, and what the employer is doing about it.

Why reporting matters: OSHA uses these reports to decide if an immediate inspection is warranted. It’s essentially an alert to OSHA of a severe event. Not reporting on time can result in significant penalties, separate from any recordkeeping violations. Remember that reporting is in addition to recording the case on your OSHA log. For instance, if a worker is hospitalized, you both report it to OSHA within 24 hours and log it on the 300 (since a hospitalization is recordable due to days away or medical treatment).

Electronic Submission of Injury Data (Annual OSHA Reporting)

In recent years, OSHA has moved toward electronic data submission to improve transparency and targeting of enforcement. As of 2024 and moving into 2026, the electronic reporting requirements have expanded. Here’s what safety directors need to know:

• Annual Electronic Submission: Certain employers must send OSHA an electronic report of their yearly injuries and illnesses. The deadline each year is March 2 (for the previous calendar year’s data), and submissions are done through OSHA’s online Injury Tracking Application (ITA).
• Who must submit? The requirements depend on your company size and industry:
  • Establishments with 250 or more employees (at any time in the year) must electronically submit their Form 300A Annual Summary each year, unless they are in a partially exempt low-hazard industry.
  • Establishments with 20–249 employees in certain high-hazard industries must also submit the Form 300A summary annually. OSHA provides a list of these industries (which include many manufacturing, construction, healthcare, and other higher-risk sectors).
  • New in 2024: Establishments with 100 or more employees in designated high-hazard industries must submit additional data: not only the Form 300A summary, but also the information from their Form 300 log and Form 301 incident reports (case-specific details) once per year. This is a significant change aimed at gathering more detailed data from medium-large employers in risky industries. If your establishment had 100+ employees at peak and is in one of the specified NAICS codes, you’ll need to upload your 300 and 301 information (with personal identifiers removed) via the ITA.
• Data to submit: For those required to submit, you’ll enter data from the OSHA forms. For 300A, that’s the summary counts of injuries, etc. For the detailed submission (100+ in high-hazard), it includes each recordable case’s details (date, location, outcome, etc., as on your 300 and 301). OSHA now also requires you to include your company’s Legal Company Name in the submission, to improve data quality.
• Why OSHA collects this: OSHA uses this data to identify trends and target inspections. In fact, OSHA plans to publish some of the data on its public website so that researchers, workers, and the public can see companies’ safety records. The idea is that public disclosure will encourage employers to improve safety, and allow comparisons across industries. For safety managers, this means your data accuracy is more important than ever – errors or underreporting could not only bring penalties but also misrepresent your safety program to the world.
• Submission process: The ITA (Injury Tracking Application) is the online portal. You can input data manually via a web form, upload a CSV file, or transmit via an API from compatible safety software. The ITA opens for submissions on January 2 each year and accepts data until March 2. Mark March 2 on your calendar – missing the deadline is a violation. Many companies actually prepare the data right after year-end and submit in January or February to be safe.

Practical tip: If you have to do electronic submissions, make sure you’re gathering the needed information throughout the year. A digital safety management system can simplify pulling reports when it’s time to submit. Also, double-check your OSHA logs for accuracy before submitting – once data is in OSHA’s hands (and possibly public), you want it to be correct.

Training and Checklists for OSHA Recordkeeping Compliance

Mastering OSHA recordkeeping can be challenging, which is why training and checklists are invaluable tools for safety managers. By ensuring your team is educated and following a standardized process, you can greatly reduce errors and oversights in your OSHA logs.

Recordkeeping Training: OSHA and various organizations offer training specifically on the recordkeeping rule. Taking a dedicated course can help those responsible (safety managers, HR, workers’ comp administrators) to understand the nuances of recording and reporting. For example, the OSHA Education Center notes that their Recordkeeping course is “a must-take for all human resources staff, workers comp administrators, … and business owners” who deal with injury logs. Such training covers how to determine recordability, how to fill out Forms 300/301 properly, and common mistakes to avoid. Even experienced safety professionals can benefit from periodic refreshers, especially when rules get updated (like the electronic reporting changes).

It’s also important to train all employees on the basics of injury reporting. Employees should know how and when to report incidents or near-misses internally. OSHA requires that employers inform workers of the procedure for reporting injuries and illnesses and that you cannot retaliate against employees for doing so. Encouraging a reporting culture will ensure you hear about incidents in time to record them within the 7-day window and take action.

Compliance Checklists: Maintaining an OSHA recordkeeping checklist can keep you organized and compliant year-round. Here’s a simplified OSHA Recordkeeping Compliance Checklist you can follow:

1. Determine Recordability for Each Incident: When an injury or illness report comes in, use OSHA’s criteria and maybe a decision tree to decide if it’s recordable. Document your decision. If in doubt, consult OSHA’s FAQs or experts.
2. Record the Case within 7 Days: If it’s recordable, enter it on your OSHA 300 log and complete a Form 301 incident report promptly (within 7 days of learning of the case).
3. Maintain Separate Logs if Required: Keep an OSHA 300 log (and 301s) for each establishment or site, if you have multiple locations. Ensure each log is up to date with all incidents at that site.
4. Protect Privacy Cases: If an injury is a sensitive “privacy concern case” (e.g., sexual assault, HIV infection, etc.), don’t write the employee’s name on the 300 log – use “privacy case” and keep a separate confidential list of names. This keeps personal information protected as required.
5. Review Logs Periodically: Periodically audit your 300 log for accuracy. Make sure the classification (lost time, restricted, etc.) is correct and that you haven’t missed any cases or erroneously included non-recordable cases. Update cases if the situation changes (e.g., an injury becomes more serious than initially thought).
6. Complete Year-End Summary: At the end of the year, total up the columns on the OSHA 300 log and transfer the totals to the Form 300A Annual Summary. Include your establishment information and employment numbers as required on the form.
7. Executive Certification: Have a company executive (owner, officer, or highest manager) review and sign the Form 300A to certify its accuracy. This step is mandated by OSHA – it ensures higher management is aware of the injury numbers.
8. Post the 300A Summary: On February 1, post the signed 300A summary in a noticeable spot (breakroom, bulletin board, etc.) and leave it up until April 30. Make sure it’s not obstructed and that employees know where to find it.
9. Submit Data Electronically (if required): By March 2, electronically submit your data through OSHA’s ITA if your establishment meets the size/industry requirements for submission. Remember that if you have 250+ employees (non-exempt industry) or 20-249 (high-hazard industry), you need to submit the 300A. And if 100+ in high-hazard, submit the 300A plus detailed 300/301 info.
10. Retain and Update Records: File your 300, 300A, and 301 forms and keep them for 5 years. During that time, continue to update the logs if new info arises (e.g., an injured worker later needed days off that you hadn’t recorded initially). Also be prepared to provide copies to OSHA or authorized employee representatives if requested.
11. Report Severe Incidents: In parallel to the above, ensure that any OSHA-reportable incident (fatality, hospitalization, amputation, eye loss) is reported to OSHA within the 8 or 24-hour window. Keep the OSHA area office number handy, and train managers on this requirement so it’s not missed in an emergency.
12. Review Annual Results: Once you complete the year, review your injury and illness data. Look for patterns that could be addressed with safety initiatives. OSHA logs shouldn’t just be a compliance task – use them as a tool to improve safety training and hazard prevention in the new year.

Following a checklist like this can turn recordkeeping from a chaotic scramble into a routine process. Many companies even integrate such checklists into their safety software or calendars so that nothing slips through the cracks.

Leveraging Digital Tools (like Ving): Today’s technology can greatly assist in OSHA recordkeeping and training compliance. For example, Ving is a safety training and compliance platform that can help streamline these tasks. Platforms like Ving offer a wide range of OSHA-related safety training courses (in multiple languages and topics) that can be delivered online to your workforce. While Ving (and similar tools) are not OSHA Outreach trainers (so they cannot issue official OSHA 10 or 30-hour cards – those must come from authorized OSHA trainers in the Outreach program), they do cover virtually all other OSHA-required training topics that can be done online. This means you can ensure your team is trained on hazard communication, PPE, lockout/tagout, and other critical areas through convenient e-learning modules.

A huge benefit of using an online system is tracking and documentation. Ving, for instance, lets you easily track each employee’s training progress and certifications. You can set up reminders for refresher training and even log third-party certifications (such as an OSHA 10-hour card obtained elsewhere) in one centralized dashboard. By having all training records in one place, you’re better prepared if OSHA asks for proof of training or if you need to check who is due for renewal on a qualification. Ving also provides tools like smart checklists and inspection tracking that can be tailored to OSHA compliance tasks. For example, you might use a digital checklist in Ving to remind you of each step in the recordkeeping process (similar to the one above) and to verify completion.

Additionally, many digital platforms can generate reports with the click of a button. Rather than manually compiling data from spreadsheets, you can instantly pull a summary of all recordable incidents or training completion rates. This is extremely handy during audits or OSHA inspections – you have the documentation at your fingertips. In fact, Ving advertises that you can generate compliance reports in seconds for an OSHA visit or for management review.

Bottom line: Training your team and utilizing modern compliance tools can make OSHA recordkeeping much more manageable. A knowledgeable staff will report and record injuries properly, and a good system will keep those records organized, remind you of deadlines, and store all your safety data (including training records and even uploaded OSHA logs) in one place.

By investing in training and leveraging checklists or software, you can transform recordkeeping from a headache into a smooth, routine part of your safety program. This not only helps avoid OSHA penalties but also supports a safer workplace by ensuring incidents are tracked and addressed.

Conclusion

OSHA recordkeeping is a fundamental responsibility for safety directors and managers. In 2026, with OSHA placing emphasis on accurate data and electronic reporting, it’s more important than ever to get it right. By knowing which incidents to record, keeping your OSHA 300 logs and 300A summaries up to date, and meeting all posting and reporting deadlines, you protect your company from fines and help identify trends that can improve safety.

Remember that compliance is an ongoing process – it happens all year long, not just at year-end. Encourage a culture of prompt incident reporting, review your logs regularly, and don’t hesitate to seek out training for yourself or your team on the nuances of OSHA’s recordkeeping rules. Using tools like detailed checklists and digital training/tracking platforms can take a lot of the manual work and uncertainty out of the process.

In the end, effective recordkeeping isn’t just about OSHA compliance – it’s about learning from past incidents to prevent future ones. When you accurately record injuries and illnesses, you create a clear picture of where improvements are needed. That insight, combined with proactive training, is what ultimately keeps workers safe. Stay organized, stay informed on the latest requirements, and you’ll stay compliant with OSHA’s recordkeeping in 2026 and beyond.