The Form Nobody Fills Out Until It Is Too Late
CFR reference: 29 CFR Part 1904
29 CFR Part 1904. Recordable injuries, the 300A summary posting requirement, and the severe injury reports OSHA expects within 8 or 24 hours of an event.
OSHA recordkeeping is governed by 29 CFR Part 1904 — the standard that requires employers to record work-related injuries and illnesses on three connected forms: the OSHA 300 (the running log of every recordable case), the OSHA 301 (the incident report for each case, with details OSHA can audit), and the OSHA 300A (the annual summary posted on the workplace bulletin board). The standard sounds simple — write down the injuries, post a summary, keep the records — but it is one of the most under-maintained programs in small operations, and one of the easiest for OSHA to cite because the gap is on paper.
The partial exemption is the first thing to check. Under 1904.1, employers with 10 or fewer employees at any point during the prior calendar year are exempt from routine recordkeeping (they still have to report severe events to OSHA). Certain low-hazard industries are also exempt — see Subpart B Appendix A. Most small manufacturers, warehouses, and contractor operations in the Triad do NOT qualify for the partial exemption. They have 11+ employees and their NAICS code is not on the exempt list. The first question I ask is "what was your peak headcount last year?" — and the answer almost always pulls them into the recordkeeping requirement they did not realize applied to them.
The most-cited recordkeeping subsection is 1904.32 — failure to post or properly complete the 300A annual summary. Every covered employer must post the 300A from February 1 through April 30 each year, in a conspicuous place where employees can see it. The form must be signed and certified by a company executive (CEO, owner, designated official, or supervising official). In small operations, what I most often find is no 300A at all — because there is no 300 log, so there is nothing to summarize. The second most common state is a 300A taped to the breakroom wall from 2019, never updated and never re-posted.
The second most-cited subsection is 1904.29 — failure to record an injury within 7 calendar days. Recordable cases must be entered on the 300 log within 7 days of the employer learning about them. The OSHA 301 incident report (or an equivalent form) must be completed for each case as well. In facilities I walk through, the question "where is your OSHA 300 log?" is often met with a confused look. If the log exists, it is in the HR office, and the last entry is from a previous calendar year — even though Workers' Comp records show three injuries since.
The third area is severe injury reporting under 1904.39. Regardless of recordkeeping exemption status, every employer in the US must report to OSHA: fatalities within 8 hours, and inpatient hospitalizations, amputations, or losses of an eye within 24 hours. These reports go to the OSHA Area Office or the federal 1-800-321-OSHA hotline. A delayed or missed severe injury report is its own citation, and it is one OSHA pursues aggressively because the case usually leads to a follow-up inspection of the underlying hazard.
What an OSHA Compliance Officer checks during a recordkeeping audit: they ask for the OSHA 300 log for the current year and the past five years (the retention requirement under 1904.33). They cross-check the 300 log against Workers' Comp first reports, insurance claims, and any incident reports the employer keeps. They look at the 300A — is it posted? Is it certified? Is the certification date current? They ask whether any case from the past three years involved an inpatient hospitalization, amputation, or eye injury — and they verify whether that report went to OSHA in time. If electronic submission is required (establishments with 250+ employees, or 20+ in certain high-hazard industries), they verify the 300A was submitted to ITA by March 2.
Corrective action: download the current OSHA 300 log, 301 incident form, and 300A summary from osha.gov (free, fillable PDFs). Reconstruct the past five years using whatever incident records you have — Workers' Comp filings, internal incident reports, employee handbook copies of injury notes. Designate one person as the recordkeeping owner. Build a calendar reminder for February 1 every year to certify and post the 300A. Build a calendar reminder for each severe injury reporting requirement so it is not missed if something happens. Train supervisors on what counts as recordable — the line between first aid and medical treatment is narrow and frequently misclassified. Total fix time for a small operation: 4–8 hours of focused work. Total cost: zero, beyond a printer and a clipboard. The cost of getting it wrong: each missing year of records is a separate citation, and the penalty range for recordkeeping violations under 1903.15 reaches up to $16,550 per item.
I ask for the OSHA 300 log on almost every walkthrough. Most of the time it does not exist. The HR lead has never been asked about it, and the office manager assumes "we are too small for that." Headcount is usually well over 10 employees, which means the partial exemption does not apply. I check the breakroom wall — no 300A. I cross-reference the past three years against Workers' Comp records and find multiple recordable cases the company never logged. When something serious happened — a fingertip amputation in 2023 — nobody called OSHA within 24 hours because nobody knew that requirement existed. None of this is the result of bad faith. It is the result of nobody being assigned the responsibility, and nobody knowing what counts.
No. Employers with 10 or fewer employees at all times during the previous calendar year are partially exempt from routine OSHA recordkeeping under 29 CFR 1904.1. Certain low-hazard industries (NAICS codes listed in 1904 Subpart B Appendix A) are also exempt regardless of size. All employers — regardless of size or industry — must still report fatalities, in-patient hospitalizations, amputations, and losses of an eye to OSHA per 1904.39.
Under 29 CFR 1904.7, an injury or illness is recordable if it is work-related and results in death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, loss of consciousness, or a significant injury or illness diagnosed by a licensed health-care professional. First-aid-only cases are not recordable. The definition of first aid is narrow — for example, butterfly bandages count as first aid; sutures do not.
The 300A annual summary must be posted in a conspicuous location at each establishment from February 1 through April 30 of the year following the year covered. It must be certified by a company executive before posting. Failure to post is one of the most common recordkeeping citations during scheduled inspections.
Field Note by Vince Lawrence — GigLine Safety & Compliance — Kernersville, NC — (336) 329-8899