OSHA recordkeeping requirements construction companies must follow

The Occupational Safety and Health Administration (OSHA) reviews incidents to identify risk trends, produce accurate injury data for public use, and improve safety standards across the industries they monitor. To help them reach this goal, OSHA sets recordkeeping rules construction leaders must follow, like logging every work-related injury and illness and reporting severe incidents on a deadline. 

This guide provides contractors with the information they need to meet OSHA recordkeeping requirements, including criteria for a recordable injury or illness, required forms, and penalties for noncompliance.

What is OSHA recordkeeping?

OSHA recordkeeping involves tracking workplace injuries, illnesses, and fatalities. The agency also recommends reporting near misses as a preventative measure. 

This data is especially critical in high-risk industries like construction, which recorded about 167,000 nonfatal injuries and illnesses and 1,034 deaths in 2024, the most recent BLS figures. Safety reports and records provide a detailed view of the hazards that pose the greatest threat to crews. Construction leaders use this data to improve jobsite conditions, and OSHA enforces these changes.

Recordkeeping forms

There are three recordkeeping forms OSHA uses to track workplace injuries. Construction companies with 11 or more employees at any point during the calendar year must complete and maintain these forms:

• Form 300 is a running log of work-related injuries and illnesses that occur throughout the year. Contractors must add entries within seven days of each incident.
• Form 300A summarizes all work-related injuries and illnesses from the previous 12 months. A company executive must certify this report and post it in a visible space at every jobsite from February 1 to April 30 each year.
• Form 301 is a detailed injury and illness incident report for each event. Leaders must complete it within seven days of the incident.

What is an OSHA recordable incident?

Before recording an incident, contractors must establish the case is work-related under 1904.5 and that it qualifies as a “new case” under 1904.6. Once confirmed, leaders check OSHA’s recordable criteria in regulatory standard 1904 Subpart C. Common types of recordable incidents include:

• Loss of consciousness: Any time a worker loses consciousness
• Days away from work: If an incident causes a worker to miss one or more days of work
• Restricted work duties or transfers: When an injury or illness requires an activity restriction or job transfer
• Medical treatment beyond first aid: Any care that exceeds OSHA’s definition of “first aid” under 1904.7(b)(5)(ii)
• Significant diagnoses: An injury or illness that leads to a serious diagnosis, such as cancer, a fractured bone, or a punctured eardrum

For incidents resulting in death, employers must report any workplace fatality within eight hours of learning about it and log the incident in Form 300.

Unique incidents

Certain workplace incidents come with their own special recordkeeping requirements. These include:

• Needlestick injuries (1904.8): Leaders should only record lacerations, cuts, punctures, and scratches if they come into contact with another person’s blood or other potentially infectious material. To preserve the worker’s privacy, don’t include the worker’s name on the 300 Log.
• Medical removals (1904.9): Contractors must classify chemical exposure as “poisoning” if the worker qualifies for medical removal.
• Hearing loss (1904.10): Employers only need to record hearing loss if audiograms show a marked deterioration of the worker’s hearing level compared to their baseline.
• Tuberculosis (1904.11): Contractors must categorize work-related tuberculosis cases as “respiratory conditions” in the 300 Log. If an employer later obtains evidence that the diagnosis didn’t result from occupational exposure, they may remove the case from the log.

Exemptions

There are several OSHA recordkeeping exemptions under 1904.5 (b)(2). Contractors don’t need to record an incident if:

• The employee visited the site as a member of the general public rather than an active worker
• A non-work-related event caused the injury or illness, even if symptoms appeared on the jobsite
• Voluntary participation in a wellness program or recreational activity caused the injury or illness
• Eating, drinking, or preparing food for personal consumption resulted in the injury or illness (unless workplace contaminants such as lead or asbestos caused it)
• Performing personal, non-work related tasks outside of working hours on the jobsite led to the injury or illness
• Personal grooming, self medication for a non-work-related condition, or intentional self-infliction directly caused the injury or illness
• A motor vehicle accident in a company parking lot or on a company access road injured a worker who was commuting to or from work
• The illness is a common cold or flu
• The condition is a mental illness (unless the employee provides an opinion from a licensed healthcare professional with sufficient training and experience to prove the illness is work-related)

Common OSHA recordkeeping violations

OSHA investigates each suspected violation and determines a penalty. They may also fine employers per day for uncorrected issues. Examples include:

• Misclassifying an injury or illness: Incorrectly categorizing a recordable incident, such as classifying cumulative hearing loss as an injury rather than an illness
• Failing to include required information on a form: Omitting relevant details of the incident, such as describing a specific injury in vague or unclear terms
• Failing to retain records: Neglecting to keep all records on file for at least five years, or failing to update the 300 Log to include new cases or changes to injury classifications
• Missing a recording or reporting deadline: Failing to record a case on the 300 Log within seven calendar days of learning about it, or failing to report a death within eight hours and a hospitalization, amputation, or loss of an eye within 24 hours
• Missing the annual electronic submission deadline: Failing to submit electronic incident reports by the March 2nd deadline if the organization meets OSHA’s Injury Tracking Application (ITA) criteria

The best way to avoid costly penalties is to prevent OSHA violations in the first place by establishing good recordingkeeping policies.

Penalties for violations

OSHA updates standard penalties annually. A single serious violation may carry a fine of up to $16,550, while willful or repeat violations can result in fines of up to $165,514 per violation. While these figures reflect the maximum fines for recordkeeping infractions, OSHA evaluates violations and enforces penalties on a case-by-case basis.

Turn field incident reports into OSHA-ready logs with Miter

Thorough recordkeeping helps firms comply with OSHA standards, track prevalent jobsite risks, and adhere to construction safety regulations. To ensure OSHA records are accurate, operations leaders need to know what to report, when to report it, and how to avoid violations.

Accurate reports and records start with effective incident capture in the field. Miter Compliance and Miter Safety allow crew members to log injuries and incidents in the app with written statements and voice notes. Miter keeps the 300 Log current from those entries and generates the 300, 301, and 300A when it is time to file. The platform categorizes these records by establishment and jobsite and uses recorded data to track total recordable incident rate (TRIR) and days away, restricted, or transferred (DART).

Frequently asked questions

Which employers are required to keep OSHA records?

All companies that have 11 or more employees at any point during the calendar year must keep OSHA records. Employers also need to complete establishment-level logging for each jobsite. 

Organizations with fewer than 11 employees at all times throughout the entire year are partially exempt and don’t have to keep OSHA records unless specifically requested by OSHA or the Bureau of Labor Statistics (BLS). Most companies in low-hazard industries such as retail, finance, or education are also partially exempt.

However, all employers covered by the OSH Act of 1970 are required to report incidents that result in a death, in-patient hospitalization, amputation, or loss of an eye.

Which employers must submit OSHA records electronically?

Electronic record submission requirements are based on establishment size and industry risk:

• Establishments with 250 or more employees must electronically submit Form 300A annually.
• Establishments in designated industries with 20-249 employees must electronically submit Form 300A annually.
• Establishments in designated industries with 100 or more employees must electronically submit Forms 300, 300A, and 301. 
• Establishments must submit electronic records if OSHA specifically notifies them.

Are there any OSHA recordkeeping exemptions for small or low-hazard businesses?

Yes, companies with 10 or fewer employees are exempt from OSHA recordkeeping requirements. Organizations in certain low-hazard industries under North American Industry Classification System (NAICS) codes are also partially exempt.

How long do employers need to keep OSHA records?

Employers must keep OSHA records on file for at least five years following the incident.

Does an OSHA recordable incident mean the employee is eligible for workers’ compensation?

Not necessarily. OSHA recordable criteria and workers’ comp eligibility operate under separate legal structures and determination rules.

Does OSHA recordkeeping apply separately to each jobsite?

Yes, employers are required to keep separate OSHA logs for each jobsite that’s expected to operate for one year or longer.