Subpart B
Under 1904.3, yes — OSHA will consider records created for another government agency to meet OSHA's Part 1904 requirements if OSHA accepts those records under a memorandum of understanding (MOU) with that agency or the records contain the same information that Part 1904 requires. See Keeping records for more than one agency in 1904.3.
Under 1904.3, "contain the same information" means the other agency's records include all the data elements and details that Part 1904 requires employers to record (for example the items normally recorded on OSHA Forms 300, 300A, or 301). See Keeping records for more than one agency in 1904.3.
Under 1904.3, contact your nearest OSHA Area Office or State Plan agency for help in determining whether those records meet OSHA's requirements. See Keeping records for more than one agency in 1904.3.
Under 1904.3 and the April 29, 2025 Letter of Interpretation, yes — you may use software-generated forms as long as they meet the equivalent-form requirements in Part 1904 (i.e., they include the same information, are as readable and understandable, and are completed using the same instructions as the OSHA forms). See Keeping records for more than one agency in 1904.3 and the Software-generated OSHA recordkeeping forms interpretation (Apr. 29, 2025).
Under 1904.3 and the April 29, 2025 Letter of Interpretation, no specific file format is required — equivalent forms may be maintained in any file format (for example Excel or CSV) provided they contain the same information and are as readable and understandable as the OSHA forms. See Keeping records for more than one agency in 1904.3 and the Software-generated OSHA recordkeeping forms interpretation (Apr. 29, 2025).
Under 1904.3 and the April 29, 2025 Letter of Interpretation, yes — if another agency's records are used to satisfy OSHA requirements, you must still make those records available to authorized government representatives and to employees or their representatives under OSHA's access rules. See Keeping records for more than one agency in 1904.3 and the Software-generated OSHA recordkeeping forms interpretation (Apr. 29, 2025).
Under 1904.3, yes — if OSHA has an MOU with another agency that accepts that agency's records, OSHA will consider those records as meeting Part 1904 requirements. See Keeping records for more than one agency in 1904.3.
Under 1904.3, yes — if the state agency (a State Plan) either has an MOU with OSHA accepting its records or the state forms contain the same information Part 1904 requires, those state forms will be considered to meet OSHA's recordkeeping requirements. See Keeping records for more than one agency in 1904.3.
Under 1904.3 and the April 29, 2025 Letter of Interpretation, equivalent electronic forms must produce forms that have the same information and are as readable and understandable as the OSHA forms; employers are also allowed to keep records on computer systems provided the system can produce equivalent forms when needed for access requirements. See Keeping records for more than one agency in 1904.3 and the Software-generated OSHA recordkeeping forms interpretation (Apr. 29, 2025).
Under 1904.3, you can use another agency's records to satisfy OSHA only if they contain the same information required by Part 1904 — if a required OSHA field is missing, you must add or maintain the missing information so the combined records contain the same information OSHA requires. See Keeping records for more than one agency in 1904.3.
Under 1904.3 and OSHA's April 16, 2024 memorandum, no — even if you use another agency's records to meet Part 1904, you still must meet OSHA's electronic submission requirements and deadlines if your establishment is covered (for example OSHA Form 300A data must be submitted to OSHA by March 2 for the prior calendar year where required). See Keeping records for more than one agency in 1904.3 and the Electronic injury record submission enforcement memorandum (Apr. 16, 2024).
Under 1904.3 and the April 29, 2025 Letter of Interpretation, yes — employers may use third-party or software services to maintain records for multiple agencies provided the records meet OSHA's Part 1904 content and equivalency requirements and are available for inspection and access as required by OSHA. See Keeping records for more than one agency in 1904.3 and the Software-generated OSHA recordkeeping forms interpretation (Apr. 29, 2025).
Under 1904.3 and the April 29, 2025 Letter of Interpretation, yes — equivalent forms must be completed using the same instructions as the OSHA forms they replace so that the information recorded is consistent, readable, and understandable. See Keeping records for more than one agency in 1904.3 and the Software-generated OSHA recordkeeping forms interpretation (Apr. 29, 2025).
Under 1904.3, if OSHA determines the other agency's records do not meet Part 1904 requirements, the employer must correct or supplement its records so they comply with Part 1904; employers may request help from their nearest OSHA Area Office or State agency to determine required fixes. See Keeping records for more than one agency in 1904.3.