Employers required to keep OSHA injury and illness records must record each recordable case on the OSHA 300 Log and prepare an OSHA Form 301 (or equivalent) within seven (7) calendar days after receiving information that a recordable work-related injury or illness has occurred. This form, officially titled the Injury and Illness Incident Report, captures detailed information about each incident that goes beyond what appears on the annual log. For safety managers and EHS professionals, understanding how to complete Form 301 correctly is essential for meeting OSHA recordkeeping requirements and building a reliable database of incident information.
OSHA Form 301 serves a specific function within the broader injury and illness recordkeeping system established under 29 CFR Part 1904. While Forms 300 and 300A provide summary-level data, Form 301 documents the circumstances surrounding each individual case. This incident-level detail helps employers identify patterns, address hazards, and demonstrate compliance during inspections. The following guide covers who must complete the form, what qualifies as a recordable case, how to fill out each section properly, and how to avoid common compliance pitfalls.
OSHA Form 301 is the Injury and Illness Incident Report that employers use to document specific details about each recordable work-related injury or illness. The form creates an individual case file for every entry that appears on the OSHA 300 Log. Where Form 300 tracks cases at a summary level across the calendar year, Form 301 captures the narrative of what happened, how it happened, and what treatment the employee received.
The form collects three categories of information: employee details, case information (including four narrative fields describing what happened), and treatment details.
Employers must retain completed Form 301 records for five years following the end of the calendar year in which the incident occurred. These records must be available for review by OSHA compliance officers upon request. Unlike Form 300A (which must be posted in each establishment in a conspicuous place where notices to employees are customarily posted from February 1 through April 30), Form 301 contains sensitive employee information and is not posted in the workplace.
Not every employer is required to maintain OSHA injury and illness records. Under federal OSHA, employers are partially exempt from routine recordkeeping if (a) the company had ten or fewer employees at all times during the previous calendar year (29 CFR 1904.1), or (b) the establishment is classified in a partially exempt low-hazard industry listed in Appendix A to Subpart B (29 CFR 1904.2). The size exemption is based on peak employment across the entire company, not individual establishments. A company with 50 total employees spread across six locations is not exempt due to size, regardless of how few employees work at each site. Employers who are not exempt must complete Form 301 (or an equivalent) for each recordable case and maintain a separate OSHA 300 Log for each establishment expected to be in operation for one year or longer.
Even employers that are partially exempt from routine recordkeeping must still report work-related fatalities, in-patient hospitalizations, amputations, and losses of an eye to OSHA under 29 CFR 1904.39, and may still have recordkeeping or electronic submission obligations if OSHA or the Bureau of Labor Statistics notifies them in writing under 29 CFR 1904.41 or 29 CFR 1904.42.
Reporting timeframes are strict: fatalities must be reported within 8 hours of learning of the death, and in-patient hospitalizations, amputations, or losses of an eye within 24 hours of learning of the event. OSHA only requires reporting a fatality if the death occurs within 30 days of the work-related incident, and only requires reporting an in-patient hospitalization, amputation, or eye loss if it occurs within 24 hours of the work-related incident.
Before completing Form 301, employers must determine whether the incident meets OSHA's recordability criteria. An injury or illness is recordable if it is work-related and results in:
Work-relatedness is presumed when an injury or illness results from an incident or exposure in the work environment. The work environment includes the employer's premises as well as any other location where employees perform work duties. OSHA provides specific exceptions for cases that occur in the work environment but are not considered work-related (such as injuries from voluntary participation in wellness programs or symptoms arising solely from non-work activities).
Certain conditions require recording regardless of treatment: any work-related case of cancer, chronic irreversible disease, fractured or cracked bone, or punctured eardrum must be recorded. Needlestick injuries and cuts from sharps contaminated with another person's blood or potentially infectious material are also recordable. Standard threshold shifts in hearing that meet OSHA's audiometric criteria require recording, though employers may wait up to 30 days to retest the employee before recording; if the retest does not confirm the shift, no recording is required (29 CFR 1904.10).
The distinction between first aid and medical treatment is one factor in determining whether an incident requires Form 301 documentation. A case is recordable if it meets any of the general recording criteria listed above. Receiving only first aid does not automatically exempt a case from recording. If the injury results in days away from work, loss of consciousness, or meets another recording criterion, it is still recordable regardless of the treatment provided.
OSHA defines first aid as a specific list of treatments under 29 CFR 1904.7(b)(5)(ii). OSHA's first aid list includes bandages, hot/cold therapy, non-prescription medications, and other treatments that do not make a case recordable.
Medical treatment includes any care that goes beyond these listed first aid procedures.
When evaluating a borderline case, ask whether the treatment appears on OSHA's first aid list. OSHA's first aid list is exhaustive: treatments not on that list are generally considered medical treatment. However, diagnostic procedures (such as X-rays and blood tests) and visits solely for observation or counseling are explicitly excluded from the definition of medical treatment under 29 CFR 1904.7(b)(5)(i). A case becomes recordable when it meets any of OSHA's general recording criteria.
In practice: A worker cuts her hand on sheet metal. If the occupational health nurse cleans the wound and applies a bandage, no Form 301 is needed. If the same cut requires three sutures at the clinic, the case is recordable and Form 301 must be completed within seven days.
Employers have seven calendar days from the date they learn of a recordable injury or illness to complete Form 301. The clock starts when any employer representative (supervisor, HR, safety manager) receives information that a recordable incident occurred. Employers should complete the form with the best available information and update the OSHA 300 Log if the case classification or outcome changes.
The form contains three main sections. The first section captures employee information: full name, street address, city, state, ZIP code, date of birth, date of hire, and gender. This information establishes the identity of the affected worker and provides demographic data for incident analysis.
The second section documents case details. Record the case number (which should match the entry on Form 300), the date of injury or illness, the time the employee began work, and the time of event.
Four narrative fields require careful attention:
The first narrative field asks what the employee was doing just before the incident. Describe the specific activity, tools, equipment, or materials involved. Rather than writing "operating machinery," provide detail: "feeding 4-foot steel rods into the cutting station of the band saw."
The second narrative field asks what happened. Explain the sequence of events that led to the injury or illness: "The rod slipped during feeding, pulling the worker's left hand toward the blade. The blade guard was in place but did not prevent contact with the worker's fingertip."
The third narrative field asks what injury or illness resulted. Identify the body part affected and the nature of the harm: "Laceration to the tip of the left index finger requiring six sutures."
The fourth narrative field asks what object or substance directly caused the harm: "Band saw blade."
The third section records information about medical treatment: the name of the treating physician or healthcare professional, the facility where treatment was given (if away from the worksite), whether the employee was treated in an emergency room, and whether the employee was hospitalized overnight as an in-patient.
The person completing Form 301 should ensure the information is accurate and complete.
Common failure point: Vague incident descriptions create problems during inspections and trend analysis. "Employee hurt back" provides no actionable information. "Employee strained lower back while lifting 50-pound box from floor level to shoulder-height shelf without assistance" enables root cause analysis and corrective action.
Certain injuries and illnesses require special handling to protect employee privacy. Privacy concern cases require employers to enter "privacy case" on Form 300 instead of the employee's name. Form 301 still requires completion with full details, but employers must maintain these forms with heightened confidentiality.
OSHA defines privacy concern cases as:
Employees may also voluntarily request that their names not be entered on the log for other illnesses not listed above. This voluntary request option does not apply to injuries.
Employers must keep a separate, confidential list linking case numbers to employee names for all privacy concern cases. This list enables employers to update case information and provide details to OSHA if requested during an inspection. When describing privacy concern cases on Forms 300 and 301, employers may use discretion to avoid including intimate details, but must still capture enough information to identify the cause and general severity.
What to do next:
OSHA's injury and illness recordkeeping system uses three interconnected forms. Understanding how they work together prevents gaps in documentation and supports effective safety program management.
Form 300 is the Log of Work-Related Injuries and Illnesses. Employers record every recordable case on this running log throughout the calendar year. Each line captures the employee's name (or "privacy case"), job title, date of injury or illness onset, location, description, classification (injury vs. illness type), and outcome (days away, restricted duty, job transfer, or other recordable case). The log provides a summary view of all incidents.
Form 301 is the detailed incident report corresponding to each line on Form 300. If the log shows 12 recordable cases for the year, there should be 12 completed Form 301 reports. The case numbers must match between the two forms. Form 301 captures the narrative detail that Form 300's columnar format cannot accommodate.
Form 300A is the Summary of Work-Related Injuries and Illnesses. At the end of each calendar year, employers total the entries from Form 300 and transfer those totals to Form 300A. The summary shows total case counts by category (deaths, cases with days away, cases with job transfer or restriction, other recordable cases) plus total days away and days of restriction. A company executive must certify the summary's accuracy before posting.
Retention and access requirements for all three forms are detailed in the next section.
Audit evidence to collect: Maintain a file containing Form 300, all associated Form 301 reports, and the certified Form 300A for each of the past five years. This documentation package should be readily accessible for OSHA inspections.
Employers must retain the OSHA 300 Log, the privacy case list (if one exists), the annual summary (Form 300A), and the OSHA 301 Incident Report forms for five years following the end of the calendar year they cover. During this retention period, employers must update the stored Form 300 to include any changes in case outcomes (such as a case initially recorded as restricted duty that later results in days away from work). When an authorized government representative requests access to these records, you must provide them within four business hours.
Access rights vary by requester. Current and former employees have the right to review the Form 300 Log for any establishment where they worked. They may also request a copy of their own Form 301. Employers must provide access to Form 300 by the end of the next business day following a request. Copies of an employee's own Form 301 must also be provided by the end of the next business day.
Authorized employee representatives (such as union representatives) may access Form 300 and must receive copies by the end of the next business day. Their access to Form 301 is limited to Section 2 (the case description portion) and excludes employee identifying information. Representatives must receive these redacted copies within seven calendar days. These employer recordkeeping responsibilities reflect OSHA's commitment to transparency and worker involvement in safety programs. These access requirements are detailed in 29 CFR 1904.35.
OSHA compliance officers and representatives from the Bureau of Labor Statistics may access all forms, including employee names and complete Form 301 records, during OSHA inspections or surveys.
OSHA permits employers to use equivalent forms in place of Form 301. State workers' compensation reports or insurance claim forms often capture similar information. To qualify as equivalent, a substitute form must contain all the information requested on Form 301 and must be as readable and understandable. Many employers attach supplemental sheets to their workers' compensation first reports to capture any OSHA-required fields not present on the insurance form.
Several errors appear repeatedly in OSHA recordkeeping audits. Recognizing these patterns helps employers strengthen their processes before problems occur.
Late Form 301 completion violates OSHA recordkeeping requirements and may result in citations during inspections. Missing the seven-day recording deadline is a common recordkeeping breakdown when incident information flows through multiple departments before reaching the person responsible for OSHA records. Understanding the penalties for recordkeeping violations reinforces why establishing a clear internal reporting chain matters. A supervisor may document an injury in a shift log, but if that information does not reach the safety manager for two weeks, the Form 301 deadline has passed. Establish a clear reporting chain that moves incident information to the recordkeeper within 24 to 48 hours, leaving adequate time for form completion.
Incomplete incident descriptions reduce the value of recordkeeping data and raise questions during inspections. Each narrative field should answer who, what, when, where, and how with enough specificity to support hazard analysis. Train supervisors on the level of detail expected, and review a sample of completed forms quarterly to identify description quality issues.
Misclassifying recordable incidents leads to both under-reporting and over-reporting. Some employers record every visit to a healthcare provider, even when only first aid was administered. Others fail to record cases where employees receive prescription medication or require restricted duty. Reference OSHA's first aid list when evaluating each case, and document the rationale for borderline decisions.
Failing to update records when outcomes change creates inaccurate year-end totals. An employee initially placed on restricted duty may later require days away from work. The original Form 300 entry must be updated to reflect the more serious outcome. Build a tickler system to follow up on open cases at 30, 60, and 90 days.
Neglecting privacy requirements exposes sensitive employee information. Forms 301 for privacy concern cases should be stored separately from routine incident files, with access limited to personnel who have a legitimate need.
Safety managers new to OSHA recordkeeping or those looking to strengthen existing processes can use the following action sequence.
Immediate actions (this week):
Short-term actions (next 30 days):
Ongoing actions (quarterly and annually):
Accurate injury and illness records do more than satisfy regulatory requirements. OSHA Form 301 data reveals patterns in workplace injuries and enables targeted corrective actions. EHS software with incident management modules can streamline this process, helping employers who use this information to drive corrective actions see measurable reductions in incident rates over time. OSHA Form 301 is not simply a compliance form; it is a tool for building safer workplaces.
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