Determining Whether Your company Must Maintain OSHA Injury and Illness Records

Some companies may be exempt from OSHA injury and illness recordkeeping requirements depending on their company size or industry classification. Because OSHA requirements can vary, contractors should review the OSHA guidance and determine whether their organization must maintain the OSHA recordkeeping forms.

This article provides general information and links to OSHA resources to help you understand the requirements.

Small Employer Exemption (10 or Fewer Employees)

In general, companies that had 10 or fewer employees at all times during the previous calendar year are not required to keep OSHA injury and illness records.

However, OSHA or the Bureau of Labor Statistics (BLS) may still require a company to keep records if the employer receives a written request to participate in a survey or data collection.

For details on how OSHA determines employer size and recordkeeping requirements, see:
https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904.1

Industry Exemption

Some businesses are exempt from OSHA recordkeeping requirements because their industry classification is considered low hazard.

If your establishment’s NAICS industry classification is listed in Appendix A of OSHA’s Recordkeeping Standard (29 CFR 1904), you may not be required to maintain OSHA injury and illness records unless OSHA or BLS specifically instructs you to do so.

You can review the regulation and industry exemption list here:
https://www.osha.gov/laws-regs/regulations/standardnumber/1904

OSHA Reporting Requirements Still Apply

Even if your company qualifies for a recordkeeping exemption, all employers must still report certain serious workplace incidents to OSHA.

These include incidents that result in:

• A fatality

• Inpatient hospitalization

• Amputation

• Loss of an eye

More information about OSHA reporting requirements is available here:
https://www.osha.gov/injuryreporting

OSHA Forms and Recordkeeping Resources

If your organization determines that it must maintain OSHA injury and illness records, OSHA provides official forms and instructions:

• OSHA Injury and Illness Recordkeeping Forms (300, 300A, 301):
  https://www.osha.gov/recordkeeping/forms

• OSHA Recordkeeping Overview and Guidance:
  https://www.osha.gov/recordkeeping

Need More Information?

OSHA is the authoritative source for determining whether your organization must maintain injury and illness records. Contractors should review OSHA’s guidance or consult their internal safety or compliance team if they have questions about their recordkeeping obligations.