OSHA's recordkeeping requirements under 29 C.F.R. Part 1904 are often misunderstood as applying only to manufacturing or construction. In reality, they apply to most employers with 10 or more employees in the private sector, regardless of industry. The February 1 posting deadline for the OSHA Form 300A annual summary is a fixed annual compliance obligation that many office-based companies miss.
Who Must Comply
OSHA recordkeeping applies to employers with 10 or more employees at any point during the previous calendar year. Low-hazard industries are partially exempt under 29 C.F.R. § 1904.2, including most office-based SIC codes. Even exempt employers must report work-related fatalities (within 8 hours) and hospitalizations of 3+ employees, amputations, or loss of an eye (within 24 hours) under 29 C.F.R. § 1904.39.
The Three Forms
- Form 300: Log of work-related injuries and illnesses maintained throughout the year. Retained 5 years.
- Form 301: Incident report completed within 7 calendar days of a recordable injury. Retained 5 years.
- Form 300A: Annual summary certified by a company executive and posted February 1 through April 30 in a visible location.
What Is Recordable?
A work-related injury is recordable if it results in: days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, a significant diagnosed injury, or a needle stick. First aid treatment alone does not make an incident recordable.
Electronic Submission Requirements
Under 29 C.F.R. § 1904.41, establishments with 250+ employees must submit Form 300A data electronically to OSHA's Injury Tracking Application (ITA) by March 2. Establishments in high-hazard industries with 20–249 employees must also submit. A 2024 rule expansion requires establishments with 100+ employees in specific high-hazard industries to submit Form 300, 300A, and 301 data.
Penalties (2025)
- Other-than-serious violations: Up to $16,550 per violation
- Willful or repeated violations: $16,550 to $165,514 per violation
How Compliance Singularity Handles OSHA Recordkeeping
Compliance Singularity determines your OSHA obligations based on employee count and NAICS code. It builds the February 1–April 30 Form 300A posting requirement and the March 2 ITA electronic submission deadline into your annual compliance calendar. The system tracks whether you meet the electronic submission thresholds and updates automatically as your headcount changes.