The Basics of OSHA Recordkeeping (2025)
By Mairis Ramos, Director of OSHA Education / Environmental Manager (Tulsa, OK)
Mairis Ramos hales from Venezuela as an Industrial Engineer with 10 years of experience in Safety, Environment and Occupational Health. Her ability to implement accident reduction programs is a testament to her commitment to excellence and innovation in the field of industrial engineering.
Recordkeeping is a cornerstone of occupational safety and health management in the United States. The Occupational Safety and Health Administration (OSHA) requires employers to document and report work-related injuries and illnesses through a standardized system. These records not only fulfill legal obligations but also help organizations prevent hazards, improve safety culture, and protect employees.
In 2025, OSHA has reinforced its recordkeeping standards with updated electronic submission rules, stricter penalties, and expanded transparency. Understanding the fundamentals of recordkeeping is essential for employers, managers, and safety professionals.
Purpose of OSHA Recordkeeping
The main objectives of OSHA’s recordkeeping system include:
- Data Collection and Analysis: Tracking injury and illness trends to identify risks.
- Hazard Prevention: Using data to develop preventive strategies.
- Transparency: Ensuring workers and the public have access to relevant safety data.
- Policy Support: Contributing to nationwide health and safety programs.
Applicability of Recordkeeping
Not all employers are subject to the same requirements. The following criteria apply in 2025:
- Covered Employers: Businesses with 11 or more employees in non-exempt industries.
- Exempt Employers: Certain low-hazard industries (finance, retail, small service providers).
- Universal Reporting: All employers, regardless of size, must report fatalities, hospitalizations, amputations, and eye losses directly to OSHA.
OSHA Forms and Requirements
Employers must use three key forms:
- Form 300 – Log of Work-Related Injuries and Illnesses Records all significant work-related incidents, including employee name, job title, injury type, and days away from work.
- Form 301 – Injury and Illness Incident Report Provides detailed documentation of each recordable case. Must be completed within 7 calendar days of notification.
- Form 300A – Summary of Work-Related Injuries and Illnesses Consolidated annual summary of incidents. Must be signed by a company executive and posted from February 1 to April 30.
Recordable Cases
An incident is recordable if it results in:
- Death, days away from work, restricted work, or transfer to another job.
- Loss of consciousness.
- Diagnosis of significant injuries or illnesses (fractures, punctured eardrum, cancer, chronic diseases).
- Certain occupational conditions (hearing loss, tuberculosis, needlesticks, silica-related illness).
- Update 2025: COVID-19 cases must still be recorded when work-related exposure is evident.
Electronic Submission (2025 Updates)
Not all employers are subject to the same requirements. The following criteria apply in 2025:
- Establishments with 100+ employees in high-hazard industries must submit Forms 300, 301, and 300A electronically.
- Establishments with 20–249 employees in high-risk industries must continue submitting Form 300A.
- Submissions must include the Employer Identification Number (EIN).
- OSHA publishes non-personal data online, enhancing transparency and benchmarking.
Posting, Retention, and Employee Rights
Not all employers are subject to the same requirements. The following criteria apply in 2025:
- Posting: Form 300A must be displayed where employees can view it, each year from Feb 1 – Apr 30.
- Retention Records must be kept for five years.
- Employee Rights: Workers, representatives, and OSHA inspectors can request access to records. Employers must provide them within four business hours.
Common Mistakes and Penalties
Frequent compliance errors include:
- Failure to update logs within the required time frame.
- Misclassifying restricted work or medical treatment cases as non-recordable.
- Not posting the 300A summary.
- Missing electronic submission deadlines.
Penalties (2025):
- Serious violations: $16,000+ per case.
- Willful/repeated violations: $161,000+ per case.
- Daily fines for failure to abate.
Recommendations
To improve compliance and enhance workplace safety, employers should:
- Implement Safety Management Systems – Integrate recordkeeping into broader safety programs with leadership commitment.
- Train Staff – Educate supervisors and HR personnel on OSHA definitions and reporting obligations.
- Conduct Internal Audits – Regularly review logs for accuracy before electronic submission.
- Adopt Digital Tools – Use software platforms that streamline data collection and ensure compliance with deadlines.
- Foster Reporting Culture – Encourage workers to report injuries without fear of retaliation, supported by OSHA’s anti-retaliation provisions.
- Review OSHA’s Top 10 Violations Annually – Use this data to focus preventive strategies where most employers fail.
Conclusion
Basic OSHA recordkeeping is more than a legal requirement—it is a preventive tool that protects workers and organizations alike. In 2025, with stricter submission requirements and heightened penalties, employers must approach recordkeeping strategically. Companies that adopt proactive systems, invest in training, and integrate data-driven approaches will not only ensure compliance but also strengthen their safety culture and reputation.