OSHA 300 Recordkeeping: The Injury and Illness Log That Drives EMR and Insurance Rates

OSHA 29 CFR 1904 requires employers to maintain records of work-related injuries and illnesses. The OSHA 300 log is the central record; OSHA 301 forms document individual incidents; OSHA 300A is the annual summary posted annually. Construction contractors with more than 10 employees must maintain these records. The data feeds into experience modification rates (EMR) that affect workers compensation premiums, which affect bidding competitiveness.

Getting OSHA recordkeeping right is both regulatory compliance and operational safety intelligence. Incorrect recording (over- or under-recording) produces regulatory risk and distorts the safety data the organization uses for improvement. This post covers OSHA recordkeeping basics.

Who Must Keep Records

Coverage requirements:

Construction industry is fully covered. Every construction contractor with more than 10 employees maintains OSHA 300 logs. Smaller contractors have partial exemptions but should still track safety data for their own management.

Recordable Injury Criteria

Specific criteria for recordability:

Not all workplace incidents are recordable. First aid injuries aren't recordable. Minor cuts or bruises treated on-site typically aren't. The thresholds determine what gets logged.

Medical Treatment vs First Aid

The medical treatment / first aid line matters:

Specific OSHA list defines first aid. Anything beyond the first aid list is medical treatment and recordable. Prescription medication, sutures, physical therapy — all medical treatment.

OSHA 300 Log

OSHA 300 log captures each incident:

Log maintained through the year. Each case updated as case progresses (days away continues as lost time extends). Privacy case provisions allow identity protection for sensitive cases.

OSHA 301 Incident Report

Detailed incident report for each case:

OSHA 301 is more detailed than 300 log. State-equivalent forms sometimes accepted. Form must be completed within 7 days of incident and retained for 5 years.

OSHA 300A Summary

Annual summary with specific posting requirement:

300A posting is mandatory February 1 through April 30. Posted in employee-visible location. OSHA inspectors may check compliance during site visits.

Rate Calculations

OSHA data produces key metrics:

TRIR is the commonly-cited safety metric. Industry average varies by construction sector. Contractor TRIR below industry average suggests strong safety; above average suggests opportunity.

Electronic Submission

OSHA requires electronic submission:

Electronic submission creates public data that can be compared across contractors. OSHA uses data to target inspections and identify high-hazard operations. Public visibility of poor safety data affects reputation.

Impact on EMR

Recordable injuries affect EMR:

Many clients require EMR below 1.0 for contractor qualification. EMR above 1.0 can disqualify from competitive bidding on significant work. EMR is calculated from actual workers comp claim data but tracks closely with recordable injuries.

Bottom Line

OSHA 300 recordkeeping captures workplace injuries and illnesses for construction contractors with more than 10 employees. Recordable criteria distinguish true recordable injuries (medical treatment beyond first aid, days away, restricted work, etc.) from minor events (first aid only). OSHA 300 log, OSHA 301 reports, and OSHA 300A summary are the recordkeeping structure. TRIR, DART, and related rates derive from the data. Electronic submission produces public data. Recordkeeping affects EMR which affects insurance premiums and contractor qualification. Getting recordkeeping right is both compliance and operational intelligence — accurate data supports safety improvement; inaccurate data either creates regulatory risk (under-recording) or distorts the metrics clients use to evaluate (over-recording). Systematic recordkeeping with proper training produces the accurate data that drives real safety improvement.