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2026 Reference

OSHA 300. 300A. 301.The recordkeepingevery construction site needs.

A 2026 reference for OSHA recordkeeping under 29 CFR 1904. Recordable criteria, the Form 300 / 300A / 301 split, ITA submission, retention, and the penalties most construction employers underestimate.

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Direct Answer

OSHA recordkeeping under 29 CFR 1904 requires construction employers with more than ten employees to log every work-related injury or illness meeting the recordable criteria on Form 300 within seven calendar days, complete a Form 301 incident report for each case, post the Form 300A summary in the workplace from February 1 through April 30, and submit 300A data electronically through the OSHA Injury Tracking Application by March 2 if the establishment has 20 or more employees. All records must be retained for five years.

The four artifacts of OSHA recordkeeping

Three paper forms plus one electronic submission. Construction sites confuse them constantly because Form 300 and Form 301 are completed in the same window but serve different purposes. The 300A is the only one that gets posted; the ITA upload is the only one that goes to OSHA directly.

Form 300

29 CFR 1904.7

Log of Work-Related Injuries and Illnesses

When used
Running log throughout the calendar year
Who fills it out
Employer (typically safety manager or designee)
Deadline
Within 7 calendar days of learning about each case

Form 300A

29 CFR 1904.32

Summary of Work-Related Injuries and Illnesses

When used
Year-end aggregate, posted in workplace
Who fills it out
Company executive certifies; posted by employer
Deadline
Posted February 1 through April 30 each year

Form 301

29 CFR 1904.29

Injury and Illness Incident Report

When used
One per recordable case, detailed narrative
Who fills it out
Employer or designee, per case logged on 300
Deadline
Within 7 calendar days of learning about each case

ITA Submission

29 CFR 1904.41

Electronic Injury Tracking Application

When used
Annual electronic data submission
Who fills it out
Employer or designated submitter via osha.gov
Deadline
By March 2 each year (Form 300A data)

Recordable injury criteria (29 CFR 1904.7)

Any ONE of the six triggers makes the case recordable. First aid is a closed list under 1904.7(b)(5)(ii). If the treatment is not on the list, the case is medical treatment and is recordable.

Trigger or treatmentRecordable?Note
DeathYESAlways recordable. Also triggers 8-hour fatality report under 1904.39.
Days away from workYESAt least one full calendar day after the day of injury.
Restricted work or job transferYESLimited duties or different job per health care professional recommendation.
Medical treatment beyond first aidYESAnything not on the closed list in 29 CFR 1904.7(b)(5)(ii).
Loss of consciousnessYESEven momentary loss of consciousness is recordable.
Significant diagnosis by health care professionalYESPunctured eardrum, fractured tooth, cancer, chronic disease, etc.
Prescription medication (single dose at clinic)YESAny prescription medication counts as medical treatment, even one dose.
Bandage or gauze pad appliedNOListed first aid under 1904.7(b)(5)(ii)(B).
Non-prescription medication at non-prescription strengthNOListed first aid. If prescription-strength is given, becomes medical treatment.
Tetanus immunization (alone)NOListed first aid. Other immunizations may be medical treatment.
Hot or cold therapyNOListed first aid. Includes ice packs and heat pads.

How to fill out the OSHA 300 log

Five steps. The first two are classification decisions. The last three are paperwork.

  1. 1

    Confirm the case is work-related

    Apply the 29 CFR 1904.5 work-relatedness test.

    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. The work environment includes any location where employees are working as a condition of employment. Travel between job sites counts; travel from home to a single permanent workplace does not. Document the determination either way.

  2. 2

    Apply the recordable criteria

    Check the case against 29 CFR 1904.7.

    The case is recordable if it resulted in any of: death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or a significant diagnosis by a licensed health care professional. If only first aid was provided and none of the other triggers apply, the case is NOT recordable. The first-aid list in 1904.7(b)(5)(ii) is a closed list — anything not on it counts as medical treatment.

  3. 3

    Log the case on Form 300

    Add one line per case within 7 calendar days.

    Record case number, employee name, job title, date of injury or onset, location, and description of the injury or illness and the part of body affected. Mark exactly one outcome column: G (death), H (days away from work), I (job transfer or restriction), or J (other recordable case). Fill in column K (days away count) and column L (days of restricted or transferred work) where applicable.

  4. 4

    Complete Form 301 for each case

    Capture the narrative detail of how it happened.

    Form 301 collects the information that Form 300 summarizes: employee identifying data, treating health care professional and facility, time and location of the incident, what the employee was doing immediately before the incident, what happened, the nature of the injury or illness, and the object or substance that directly harmed the employee. Complete within 7 calendar days of learning of the case.

  5. 5

    Roll up Form 300A and submit electronically

    Year-end summary, posting, and ITA upload.

    At year-end, total each column on Form 300 and transfer to Form 300A. A company executive must certify the summary. Post in a visible workplace location from February 1 through April 30 of the following year. Construction establishments with 20 or more employees at any point during the prior year must submit 300A data electronically via the OSHA Injury Tracking Application by March 2. Larger employers in designated high-hazard industries also submit Forms 300 and 301 case data.

Worked Example: Four Incidents on a 75-Employee GC

A mid-size GC with 75 employees experiences four incidents during 2026. Each one runs through the recordability test, gets logged on Form 300 with a single outcome column, gets a corresponding Form 301, and rolls up to the year-end 300A.

Incident 1: First aid only
NOT recordable

Laborer scrapes shin against rebar. Medic applies bandage and ibuprofen at non-prescription strength. Employee returns to full duty same day. No Form 300 entry. Internal incident log only.

Incident 2: Medical treatment, no restriction
Recordable (column J)

Carpenter receives prescription antibiotic for a puncture wound. Returns to full duty. Form 300 column J (other recordable case). Form 301 completed within 7 days.

Incident 3: Restricted work
Recordable (column I)

Iron worker on lifting restriction for 5 days per physician. Form 300 column I (job transfer or restriction). Column L day count = 5. Counts in DART, not LTIR.

Incident 4: Lost time
Recordable (column H)

Electrician misses 12 calendar days after a fall. Form 300 column H (days away from work). Column K day count = 12. Counts in DART AND LTIR.

Year-end Form 300A totals: three recordable cases (columns H + I + J), zero deaths, one days-away case, one restricted case, one other recordable, 12 days-away total, 5 days-restricted total. Posted in the workplace from February 1 through April 30, 2027. 300A data submitted electronically via the OSHA ITA by March 2, 2027 because the establishment has more than 20 employees.

Form 300 vs 300A vs 301

The three paper forms answer different questions. Use this when an auditor asks for documentation or when an executive needs to certify the year-end summary.

AttributeForm 300Form 300AForm 301
PurposePer-case running logAnnual summaryPer-case incident detail
When createdThroughout the year as cases occurAt year-end from 300 totalsWithin 7 days of each case
What it capturesCase number, employee, outcomeColumn totals + establishment dataNarrative: what happened, how
Posting requirementMade available on requestPosted Feb 1 to April 30Confidential, not posted
CertificationNo formal certificationCompany executive must certifyCompleted by employer or designee
Electronic submissionRequired for 100+ employees in designated industriesRequired for 20+ employees in constructionRequired for 100+ employees in designated industries
Retention period5 years after the covered year5 years after the covered year5 years after the covered year

Six mistakes that trigger OSHA citations

Recordkeeping citations are common because the rules look procedural and most contractors treat them as such. Each of these mistakes shows up repeatedly in OSHA inspection histories.

  1. 01

    Counting every doctor visit as recordable

    A doctor visit is not automatically recordable. If the visit ends with only first-aid measures from the 1904.7(b)(5)(ii) list (a tetanus shot, a bandage, an over-the-counter medication, irrigation of an eye), the case is NOT recordable regardless of who provided the care. The trigger is the treatment, not the provider.

  2. 02

    Missing the 7-day deadline for new cases

    29 CFR 1904.29(b)(3) requires the case to be entered on Form 300 and Form 301 within 7 calendar days of the employer learning about it. Backdating logs at year-end is a recurring source of recordkeeping citations. The discovery date, not the incident date, starts the clock.

  3. 03

    Posting 300A late or in the wrong location

    Form 300A must be posted in a conspicuous place in each establishment where notices to employees are customarily posted, from February 1 through April 30. Posting it only on a company intranet, or only in a corporate office, does not satisfy the requirement for a job-site establishment.

  4. 04

    Recording subcontractor or staffing-agency worker injuries on the wrong log

    Under 29 CFR 1904.31, the employer who supervises the day-to-day work records the case. For a staffing agency worker supervised by the host contractor, the host contractor records the case on its own 300 log. The case is never recorded on both employers logs.

  5. 05

    Failing to submit 300A through the Injury Tracking Application

    A construction establishment with 20 or more employees during the prior year must submit Form 300A data electronically via the OSHA ITA by March 2 each year. Posting the paper 300A in the break room does not satisfy the electronic submission requirement. The two are independent obligations.

  6. 06

    Missing the 8-hour and 24-hour reporting deadlines for severe incidents

    29 CFR 1904.39 requires all employers, including those otherwise exempt from routine recordkeeping, to report any work-related fatality within 8 hours and any in-patient hospitalization, amputation, or loss of an eye within 24 hours. These deadlines apply regardless of company size or industry exemption.

2026 OSHA penalty structure

Civil penalty maximums are adjusted annually for inflation under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015. The figures below reflect 2026 CPI-adjusted maximums per 29 CFR 1903.15(d). Penalties apply per violation; multiple violations on a single citation can compound rapidly.

Serious violation
~$16,131
per violation
OSHA Civil Penalties Adjustments, 29 CFR 1903.15(d)
Other-than-serious violation
~$16,131
per violation
OSHA Civil Penalties Adjustments, 29 CFR 1903.15(d)
Willful or repeated violation
~$161,323
per violation
OSHA Civil Penalties Adjustments, 29 CFR 1903.15(d)
Failure-to-abate
~$16,131
per day beyond abatement date
OSHA Civil Penalties Adjustments, 29 CFR 1903.15(d)
Posting violation (300A)
~$16,131
per violation
OSHA Civil Penalties Adjustments, 29 CFR 1903.15(d)

Penalty figures shown are approximate 2026 CPI-adjusted maximums. OSHA publishes the exact annual figures each January in a Federal Register notice. Always check the current OSHA Civil Penalties page before any enforcement-related decision.

Frequently asked questions

The OSHA Form 300 is the Log of Work-Related Injuries and Illnesses required under 29 CFR 1904. Covered employers must record every work-related injury or illness that meets the recordable criteria within seven calendar days of learning about it. Each case is logged on a separate line with the employee name, job title, date, location, description, and outcome classification (death, days away, restricted or transferred, or other recordable case).

Form 300 is the running log of every recordable case during the calendar year. Form 300A is the year-end summary that aggregates totals by category and must be posted in the workplace from February 1 through April 30. Form 301 is the detailed incident report completed for each case on the 300, capturing how the injury happened. Form 301 must be completed within seven calendar days of the incident becoming known.

No. Employers with ten or fewer employees during the entire previous calendar year are partially exempt from routine recordkeeping under 29 CFR 1904.1. They still must report fatalities within 8 hours and in-patient hospitalizations within 24 hours under 29 CFR 1904.39. Once the employee count exceeds ten at any point in a calendar year, full recordkeeping applies the next year.

Under 29 CFR 1904.7, a work-related injury or illness is recordable if it results in any of the following: death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, loss of consciousness, or diagnosis of a significant injury or illness by a physician or other licensed health care professional. If none of these apply, the case is not recordable.

OSHA defines first aid in 29 CFR 1904.7(b)(5)(ii) as a specific closed list: non-prescription medications at non-prescription strength, tetanus immunizations, cleaning or flushing or soaking of wounds on the skin surface, bandages or gauze pads, hot or cold therapy, non-rigid means of support such as elastic bandages, temporary immobilization devices used to transport, drilling of a fingernail or toenail to relieve pressure, eye patches, removal of foreign bodies from the eye using irrigation or cotton swab, removal of splinters by simple means, finger guards, massages, or drinking fluids to relieve heat stress. Anything not on this list is medical treatment and is recordable.

Construction establishments (NAICS 23) with 20 or more employees at any time during the previous calendar year must submit their Form 300A summary data electronically through the OSHA Injury Tracking Application by March 2 each year. Establishments with 250 or more employees in industries that are not partially exempt must also submit. Effective January 1, 2024, establishments with 100 or more employees in designated high-hazard industries must also submit Forms 300 and 301 data.

Under 29 CFR 1904.33, employers must retain the OSHA 300 log, 300A summary, and 301 incident reports for five years following the end of the calendar year that the records cover. Records must be maintained at the establishment and made available to current employees, former employees, their representatives, OSHA, and the Department of Health and Human Services upon request.

OSHA civil penalties are adjusted annually for inflation. For 2026, serious and other-than-serious violations carry a maximum penalty of approximately $16,131 per violation. Willful or repeated violations, including willful failure to record or report, carry a maximum penalty of approximately $161,323 per violation. Failure-to-abate penalties are approximately $16,131 per day. Exact 2026 figures are published by OSHA each January.

Under 29 CFR 1904.31, each employer is responsible for recording the injuries and illnesses of its own employees. For temporary or leased workers, the employer who supervises the workers on a day-to-day basis records the cases on its own 300 log, even if the workers are technically employed by a staffing agency. The same case is never recorded by both employers.

Under 29 CFR 1904.39, all employers, regardless of size or industry exemption status, must report any work-related fatality within 8 hours and any in-patient hospitalization, amputation, or loss of an eye within 24 hours. Reports go to the nearest OSHA Area Office, the OSHA 24-hour hotline (1-800-321-OSHA), or the online reporting form. These reporting requirements apply even to employers who are otherwise exempt from routine recordkeeping.

When POD is the natural answer

OSHA recordkeeping is where most construction safety programs leak. Field reports describe injuries in plain language. A safety manager later decides whether each one is recordable, then transcribes it onto the 300 log, then re-types it onto a 301, then aggregates it on the 300A in February. Every hand-off is a place where the classification can drift. Plan of Day is voice-first construction reporting that captures injuries and near-misses from the field the moment they happen, routes them through POD's intelligence engine for recordable-versus-first-aid classification, and feeds hundreds of KPIs including TRIR, DART, LTIR, and the 300 log itself. Specialized AI agents flag misclassifications before they reach the year-end summary, so the 300A that gets posted matches the field reality.

Sources

Last updated: May 2026