What changed with OSHA recordkeeping
OSHA has been steadily expanding its electronic recordkeeping requirements over the past several years. The most significant recent change requires more employers to electronically submit detailed injury and illness data directly to OSHA through the Injury Tracking Application (ITA).
Previously, only establishments with 250 or more employees had to electronically submit their OSHA 300 Log, 300A Summary, and 301 Incident Reports. Now, establishments with 100 or more employees in designated high-hazard industries must also submit this detailed data annually.
Who is affected
Employers with 100+ employees in high-hazard industries
If your business is in one of the designated high-hazard industries and has 100 or more employees at any point during the year, you must now electronically submit your complete OSHA 300 Log, 300A Summary, and 301 forms.
High-hazard industries include but are not limited to:
- Construction
- Manufacturing
- Agriculture
- Warehousing and transportation
- Healthcare facilities
- Food processing
Employers with 20-249 employees in certain industries
These employers must continue to electronically submit the OSHA 300A Annual Summary. This requirement has been in place since 2017 and remains unchanged.
Employers with 10 or fewer employees
Most employers with 10 or fewer employees remain exempt from routine OSHA recordkeeping requirements entirely. However, you must still report any workplace fatality within 8 hours and any amputation, loss of an eye, or inpatient hospitalization within 24 hours.
Key changes to understand
Electronic submission requirements
The expanded electronic submission rule means OSHA will have access to far more granular data about workplace injuries and illnesses. Here is what you need to submit and when:
- OSHA 300A Annual Summary: Due by March 2 each year (for the previous calendar year)
- OSHA 300 Log: Detailed log of each recordable injury and illness
- OSHA 301 Incident Reports: Individual reports for each incident
All electronic submissions go through OSHA's Injury Tracking Application at https://www.osha.gov/injuryreporting.
Public disclosure
One of the most significant aspects of the expanded rule is that OSHA plans to publish some of this data publicly. While personally identifiable information will be removed, your establishment name, industry, and injury data may be accessible to the public.
This means your workplace safety record could become visible to potential employees, customers, competitors, and the media.
Anti-retaliation provisions
The updated rules strengthen anti-retaliation protections for employees who report injuries or illnesses. Employers must:
- Inform employees of their right to report injuries without retaliation
- Have a reasonable procedure for reporting that does not discourage reporting
- Not take adverse action against employees who report injuries
OSHA has increased enforcement of anti-retaliation provisions and will scrutinize employers whose injury rates appear artificially low compared to industry averages.
What you need to do now
Step 1: Determine your recordkeeping obligations
Check whether your establishment size and industry code (NAICS code) trigger the expanded electronic submission requirements. OSHA provides a lookup tool for covered industries.
Step 2: Audit your current recordkeeping
Review your OSHA 300 Log for accuracy and completeness:
- Are all recordable injuries and illnesses documented?
- Are entries made within 7 calendar days of learning about an incident?
- Is the 300A Summary posted from February 1 through April 30?
- Are records retained for the required 5-year period?
Step 3: Establish an electronic submission process
If you have not already registered for OSHA's Injury Tracking Application, do so now. Designate someone in your organization to be responsible for annual electronic submissions.
Step 4: Review your reporting culture
Make sure your workplace encourages injury reporting rather than discouraging it. OSHA's anti-retaliation provisions mean that any practice that could be perceived as discouraging reports — including safety incentive programs that reward zero injuries — could trigger enforcement action.
Step 5: Update your safety plan
Your written safety plan should reflect current OSHA recordkeeping requirements. If your plan references outdated submission rules or thresholds, update it.
Common recordkeeping mistakes
Not recording all recordable injuries
Many small businesses underrecord because they do not understand what qualifies as a recordable injury. Generally, a work-related injury or illness is recordable if it results 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 healthcare provider
Confusing first aid with medical treatment
OSHA defines first aid narrowly. If treatment goes beyond the specific first aid measures listed in the standard — for example, if a wound requires stitches or a prescription medication — the injury is recordable.
Not keeping records for five years
OSHA requires you to retain your 300 Log and 301 forms for five years following the year they cover. Many employers discard records too early, which creates compliance issues during inspections.
Failing to update the log
The 300 Log is a living document. If an injury initially classified as first aid later requires medical treatment, you must update the log to reflect the change.
How ComplyStack helps with compliance
Keeping up with changing OSHA requirements is a challenge for any small business. ComplyStack generates workplace safety plans that incorporate current federal and state-specific recordkeeping requirements — so you know exactly what you need to track, report, and submit based on your business size and industry.
