OSHA Recordkeeping Requirements: What Must Be Logged and When

Last updated: August 12, 2026

You’re running a workplace, someone gets hurt, and the clock starts ticking. OSHA recordkeeping requirements: what must be logged when? The short version is blunt: record qualifying work-related injuries and illnesses on the OSHA 300 Log, enter them within 7 calendar days, and keep the records for 5 years. The hard part is choosing which cases qualify, because that turns on severity, work-relatedness, and whether an exception applies. For the authoritative rule set, start with OSHA’s recordkeeping page and 29 CFR Part 1904: https://www.osha.gov/recordkeeping.

What Actually Gets Recorded Under OSHA Recordkeeping Requirements

An employee gets hurt or sick, and the case is work-related. Fine. The first question is simple: does it meet OSHA’s recordability test, or does an exception knock it off the log? Yes means it belongs on the OSHA 300 Log. No means it stays off, even when the incident was ugly or costly. Clean and boring. That’s the rule.

The core cases OSHA expects you to record are:
– death
– days away from work
– restricted work or job transfer
– medical treatment beyond first aid
– loss of consciousness
– a diagnosed significant injury or illness
– certain needle sticks, tuberculosis cases, hearing loss, and other specific conditions

That sounds wide open, but the practical rule is tighter than a lot of people assume. A cut that gets a bandage and a tetanus shot is often not recordable because OSHA treats a tetanus vaccination as medical treatment, while the wound care itself may still be first aid; when in doubt, check OSHA guidance or consult a qualified professional. A sprain that sends someone home for two shifts usually is recordable because it involves days away or restriction. And a worker who feels sick at work is not automatically recordable unless the illness is work-related and fits one of the criteria. Rabbit hole avoided.

Should you be the one making the call in real life, I would not trust memory. Pull the OSHA forms and the injury details together, then work the case one by one. The main form is the OSHA 300 Log; the event summary goes on the OSHA 301 Incident Report; and the annual count goes on the OSHA 300A Summary. OSHA’s own recordkeeping page is the place I’d check first: https://www.osha.gov/recordkeeping. The regulation itself is set out in 29 CFR Part 1904, and OSHA’s guidance there is worth reading if your cases are borderline.

1. Confirm the event happened in the work environment or qualifies as work-related.
2. Ask whether it caused death, days away, restriction, transfer, medical treatment beyond first aid, or loss of consciousness; if you are unsure, consult OSHA guidance or a qualified professional.
3. Check for a specific OSHA exception, such as a common cold, personal grooming, or a non-work-related event.
4. If the case is recordable, enter it on the OSHA 300 Log within 7 calendar days after you determine it is recordable.
5. Complete the OSHA 301 details and keep both records with the annual 300A summary.

Quick check: still wondering whether it was first aid or medical treatment? Then you’re in the right branch of the tree, but verify the answer against OSHA guidance or a qualified professional.

If You’re Trying to Decide Whether a Specific Incident Belongs on the Log

One incident in front of you? Start with severity, then exceptions. Fastest route. But if the person was not an employee, or the event was not work-related, the answer flips right away.

Here’s the practical split I use:

Situation	Best Path	Why Other Options Fail
Minor cut, bandage only, no work restriction	Usually do not log	No OSHA recordable outcome if it is truly first aid only
Laceration stitched by a clinician	Log it	Sutures are medical treatment, not first aid
Worker misses a shift for a sprain	Log it	Days away from work makes it recordable
Temporary lifting restriction after injury	Log it	Restricted work is recordable even if no days are missed
Employee faints, recovers, returns	Usually log it	Loss of consciousness is generally recordable
Flu caught from a coworker	Often do not log	Work-relatedness and exception questions usually make this hard to record unless there is a clear occupational exposure

If you want the cleanest path through a single case, use this process:

1. Write down exactly what happened, when it happened, and what treatment was given.
2. Separate first aid from medical treatment. OSHA’s first-aid list is specific, so don’t improvise.
3. Check whether the case caused days away, restriction, or transfer.
4. Decide whether the event was work-related under OSHA’s work-relatedness rules.
5. Look for exceptions and special rules before you log it.
6. If the case is recordable, enter it within 7 calendar days and support it with the 301 details.

A lot of generic articles get this wrong by treating “it happened at work” as enough. It is not. A worker can slip in the break room and still not have a recordable case if the outcome falls under an exception or does not meet a recording criterion. On the flip side, a small-looking injury can absolutely be recordable if it leads to restriction or real treatment. Outcome, not drama. That is what controls the log.

Quick check: choosing between “log it” and “document it internally only”? You need the severity test, not just the incident report, and you should verify borderline calls with OSHA guidance or a qualified professional.

OSHA Recordkeeping Deadlines and What “When” Means in Practice

A case becomes recordable, and timing matters immediately. But if you are only collecting facts after the event, you still need to move fast enough to meet the 7-calendar-day rule once you decide it belongs on the log.

Here is the working timeline:
– enter recordable cases on the OSHA 300 Log within 7 calendar days of learning the case is recordable
– update the log if the outcome changes, such as when days away become restricted work or a case later turns fatal
– complete the OSHA 300A annual summary after the calendar year ends
– post the 300A summary where employees can see it for the required posting period
– keep the records for 5 years following the end of the calendar year they cover

The most common mistake I see in plain-language guidance is mixing up the incident date, the treatment date, and the log-entry deadline. Those are not the same thing. If someone is hurt on Monday but the diagnosis arrives Friday, the 7-day clock does not start from the injury date in a simplistic way if you did not yet know it was recordable. Once you know, you should log it promptly. The calendar is unforgiving.

Using software? Fine. The tool matters less than the discipline. A spreadsheet can work for a small site if it is controlled and backed up. Dedicated EHS platforms can reduce missed deadlines, but they do not fix bad judgment. I would trust any system less than I trust the person applying OSHA’s criteria.

A practical workflow looks like this:

1. Capture the incident the same day in your internal report system.
2. Assign one person to decide recordability, so the case does not drift.
3. Check medical notes, restricted-duty letters, and supervisor statements together.
4. Mark the log entry date and calendar the 7-day deadline.
5. Review the case again if the employee’s status changes.
6. At year-end, prepare the 300A summary and verify totals before posting.

OSHA’s recordkeeping page and the electronic reporting instructions on OSHA’s site are the authority I would rely on for timing and submission questions. If your workplace is covered by a state-plan OSHA program, check that state’s rules too; some track federal rules closely, but some have extra obligations.

Quick check: if your system only reminds you at year-end, it is too late for the cases that mattered all year.

Special Cases That Change the Answer

Needles, hearing loss, tuberculosis, or a hospitalization? Then normal “first aid versus medical treatment” thinking is not enough. Those cases have their own rules, and missing them is a common compliance failure.

Here are the special cases that trip people up:

• Needlestick and sharps injuries: these are often recordable even when they do not cause immediate illness, because OSHA treats bloodborne pathogen exposures separately.
• Hearing loss: standard threshold shifts can trigger recording under OSHA’s hearing loss criteria if the case meets the other conditions OSHA sets.
• Tuberculosis: certain occupational TB cases are recordable when they meet the testing and diagnosis rules.
• Work-related need for prescription medication or surgery: that usually signals medical treatment, which makes the case recordable if it is work-related.
• Hospitalization: even if a case is not clear at first, inpatient hospitalization can trigger separate reporting obligations, and the recordkeeping analysis should be revisited fast.

For these cases, I would not wait around for someone to “see how it goes.” I would pull the exact OSHA rule for the category and document the reasoning. That protects you better than a vague note like “monitoring only.”

The real trade-off here is time. Special cases take longer to classify, and that slows busy safety teams. Still, skipping them is worse. A generic article often leaves readers thinking all recordability questions turn on stitches, stitches, and more stitches. Nope. Some cases are recordable because the regulation says so, not because the injury looked dramatic.

Quick check: if the case involves blood exposure, a test result, hearing, TB, or hospitalization, stop using the simple first-aid test and use the special rule instead.

How I’d Handle the Annual OSHA 300A Summary and Record Retention

Now the question is bigger than one case. It’s the whole year. Your job shifts from deciding recordability to proving your records are complete, accurate, and kept long enough. But if your logs were never maintained correctly during the year, the 300A summary will just expose the gaps.

The annual summary is where you total the year’s recordable injuries and illnesses from the OSHA 300 Log and certify the totals. The summary is not a substitute for the log. It is the year-end mirror of the log.

If I were cleaning up a year’s records, I would do it in this order:
1. Reconcile every incident report against the 300 Log.
2. Check whether any cases changed status during the year.
3. Confirm that the 301 forms support the log entries.
4. Tally the 300A summary from the final log, not from memory.
5. Certify the summary carefully; this is not a box to click casually.
6. Post the summary for employees in the required time window.
7. Archive the log, 301s, and summary for 5 years.

The 5-year retention rule matters because old cases can affect trend analysis, audits, and follow-up questions. If you delete records early, you do not just lose paperwork. You lose the chain of proof that supports the log. That is a real problem if OSHA asks questions later or if a claim, inspection, or internal review reaches back in time.

Who this section is not for: if your site is exempt from OSHA recordkeeping because of size or industry classification, the annual summary may not apply the same way. Even then, you should verify the exemption instead of assuming it. Exemptions are narrower than people think and can change with state-plan rules.

Quick check: if you are sitting on a stack of incident reports in December and wondering how to turn them into a compliant summary, you are in year-end cleanup mode.

Edge Cases Where the Normal Advice Breaks Down

If the situation looks simple but feels wrong, then assume you are in an edge case. That is usually where recordkeeping mistakes happen.

• Situation: the employee is a temp or contractor
• What changes: you may not be the employer that logs the case.

• What to do instead: determine who had day-to-day supervision and who owns the worksite recordkeeping duty under the OSHA rule and contract terms.

• Situation: the injury happened during a commute or offsite meal break

• What changes: work-relatedness may fall away.

• What to do instead: check whether the event happened in the work environment or involved a work task, not just a workday.

• Situation: the worker has a pre-existing condition

• What changes: aggravation can still be recordable if work makes the condition worse and it meets OSHA’s criteria.

• What to do instead: document the baseline condition, the work event, and the outcome carefully.

• Situation: the employee refuses treatment or leaves against advice

• What changes: refusal does not erase recordability if the case still involved days away, restriction, or medical treatment.

• What to do instead: record the case based on the actual outcome, not the employee’s preference.

• Situation: the case is mental health or stress-related

• What changes: these cases are often harder to connect to work and to diagnose in a recordable way.

• What to do instead: get a clear diagnosis and analyze work-relatedness under the same OSHA framework you would use for any illness.

• Situation: the case later becomes more serious

• What changes: the log entry must be updated.
• What to do instead: revise the classification when the outcome changes, rather than leaving the original entry stale.

Quick check: if your instinct is “this one is weird,” that usually means the normal shortcut will fail.

The Cleanest Way to Stay Compliant Without Over-Logging

If your real problem is avoiding both missed cases and bloated logs, then your goal is not to log everything. Your goal is to log the right things, on time, with enough support to defend the decision.

I would use this decision order every time:
1. Is it work-related?
2. Did it cause a recordable outcome?
3. Does an OSHA exception remove it?
4. Does a special rule apply?
5. Is it logged within 7 calendar days?
6. Are the 301 details and 300A totals aligned