The difference between a defensible incident record and a disputed one usually comes down to whether someone filled out Form 301 correctly within the seven-day window. Most HR teams remember the summary posting requirement for Form 300A and forget about Form 301 until a workers' compensation claim, an OSHA investigation, or a plaintiff's attorney asks for the underlying records. A well-kept 301 stack protects the company. An incomplete one becomes evidence against it.
What Form 301 Actually Captures Form 301 is the detailed incident report behind each line on Form 300. It records the injured employee's information, the date and time of the incident, what the employee was doing just before it happened, what happened in enough detail to reconstruct the event, the nature of the injury or illness, and the treatment provider.
The narrative section is the part that matters most. "Slipped and fell" is not enough. "Slipped on water that had pooled near the ice machine, fell to the right, caught her arm on the counter edge, twisted her wrist" is a usable record. The better the narrative, the easier the workers' compensation case, the OSHA investigation, and any internal safety review.
The Seven-Day Filing Window Employers have seven calendar days from learning of a recordable injury or illness to complete Form 301. The clock starts when the employer (through a supervisor or HR) becomes aware of the case, not when the incident itself happened.
What If the Injury Is Reported Late? A late-reported injury still gets a 301, dated from when the employer learned of it. Document the reporting delay in the narrative. OSHA reviewers are more concerned with suppressed reports than with late ones.
Accepted Substitutes and State Equivalents Some workers' compensation first-report forms qualify as a Form 301 substitute if they include the same required information. California, for example, allows the employer's claim report to substitute. Check your state plan before relying on a substitute, because the OSHA federal rule requires all the specific data elements in Form 301 even if the form itself varies.
Retain each 301 for five years after the end of the calendar year. Store them alongside the 300 log and the 300A summaries so investigators and auditors find the full set in one place. Review the OSHA recordkeeping forms page for the latest version of each form and any state-specific substitutions.
Keeping OSHA Form 301 Documentation Audit-Ready Build a simple intake routine: every reported injury triggers a 301 draft within two business days, regardless of whether the recordability decision is final. If the case later turns out not to be recordable, discard the draft. If it is recordable, the work is already most of the way done and you're well inside the seven-day window.
Review every 301 before it's filed. Narrative clarity, completeness of the physician information, and accurate event sequencing are the three most common deficiencies. Train supervisors on what good narratives look like, because they're usually the ones providing the initial account. Pair 301 maintenance with your grievance intake process if the incident also involves interpersonal conflict, because the two workflows often share the same early signals. The OSHA recordkeeping overview is the primary reference for form requirements each year.
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