Most injury recordkeeping mistakes come from misunderstanding what counts as recordable, not from missing the form itself. OSHA Form 300 is one of the most common HR compliance tripwires because the criteria look simple on paper but get blurry the moment an incident lands outside the textbook case. A sprained wrist from lifting a box is obvious. An ergonomic injury that develops over six months, a diagnosis that follows a workplace incident, or a first-aid treatment that turns into a prescription later all sit in the judgment zone where decisions affect your incidence rates and audit exposure.
What Counts as Recordable on the OSHA 300 Log An injury or illness is recordable when it's work-related and results in death, loss of consciousness, days away from work, restricted work or job transfer, medical treatment beyond first aid, or a significant diagnosis by a physician. OSHA has specific definitions for each trigger, and the line between first aid and medical treatment is where most disputes happen.
Prescription medication crosses the line. Over-the-counter medication at prescription strength crosses the line. Butterfly bandages, ice, and warm compresses usually don't. Review the OSHA criteria every year, because the categories drift at the edges with new guidance.
Who Has to Keep the Log Employers with more than ten employees at any point during the previous calendar year generally have to maintain Form 300, unless they fall under one of OSHA's partially exempt industries. Low-hazard industries like most retail, finance, insurance, and real estate are on the exemption list.
Exempt employers still have to report fatalities and severe injuries within the required timeframes, so the exemption only applies to the logs, not to reporting. Check the OSHA recordkeeping page for the current list of partially exempt industries before relying on an exemption.
When Do You Post the Summary? Post Form 300A (the annual summary) from February 1 to April 30 each year, in a visible common area where employees can see it. The summary covers the prior calendar year's recordable cases.
Common Recordkeeping Mistakes Auditors Catch Missing entries is the most common finding. An incident gets reported, the injured employee heals, and the log entry never gets made. Incomplete entries come next. Dates are fine, but descriptions are vague, or the classification codes don't match the narrative. Misclassifying first aid as medical treatment (or the reverse) is the third pattern.
Keep Form 300 on file for five years after the end of the calendar year it covers. OSHA can inspect it during that window, and so can a plaintiff's lawyer in a workers' compensation or personal injury case.
Building OSHA Form 300 Compliance Into Daily HR Work Recordkeeping works best when it's integrated with your incident reporting process, not bolted on at year-end. Every reported injury should trigger a review against the recordable criteria within five business days. Document the reasoning either way, because the decision not to record is just as auditable as the decision to record.
Train supervisors on what to report and how quickly. Most failures to log come from incidents that never got escalated, either because the employee downplayed it, the supervisor missed it, or the paperwork got lost. Pair Form 300 maintenance with your broader OSHA compliance program so the same incident feeds both the log and your broader safety reporting. Review the OSHA forms page each year for changes to reporting criteria or posting requirements.
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