OSHA 300 Log recordkeeping rules

Under 1904.30(a), yes — you must keep a separate OSHA 300 Log for every establishment that is expected to be in operation for one year or longer.

• If an establishment is expected to operate one year or more, recordable injuries and illnesses for that physical location must be kept on its own OSHA 300 Log per 1904.30(a).
• If circumstances change (for example, a site originally thought to be short-term later operates a year or longer), you should begin keeping a separate log for that establishment going forward to comply with the rule.

Under 1904.30(b)(1), you may consolidate recordkeeping for short-term establishments — you do not have to keep a separate OSHA 300 Log for each short-term site.

• You may keep one OSHA 300 Log that covers all short-term establishments, or maintain separate logs that cover short-term establishments by company division or geographic region as allowed in 1904.30(b)(1).
• Make sure consolidated logs still include all required information so you can produce records when needed.

Under 1904.30(b)(2), yes — you may keep establishment records at headquarters or another central location, provided you meet the transmission and production requirements.

• You must be able to transmit information about a recordable injury or illness from the establishment to the central location within seven calendar days of receiving notice that a recordable case occurred, per 1904.30(b)(2)(i).
• You must be able to produce and send the records from the central location to the establishment within the time frames required by 1904.35 (employee access) and 1904.40 (providing records to government representatives) when requested, as required by 1904.30(b)(2)(ii).
• Keep a reliable process so you can meet those timeframes (electronic systems, clear reporting steps, responsible staff).

Under 1904.30(b)(2)(i), it means you must send the details about a recordable injury or illness from the establishment to the central records location within seven calendar days after you receive information that the case occurred.

• The seven-day clock starts when the establishment (supervisor, HR, clinic, or other person) first receives information that a recordable injury or illness happened, as stated in 1904.30(b)(2)(i).
• Use processes (electronic reporting, incident forms, phone/email escalation) to ensure the central location gets the information quickly and can keep complete records.

Under 1904.30(b)(2)(ii), your central records office must be able to produce and send the requested records from the central location to the establishment within the time frames required by 1904.35 and 1904.40.

• 1904.35 covers employee access to records; 1904.40 covers production for government representatives. Your central office must meet those timelines and make records available for inspection and copying as required.
• Practically, this means having records organized and a fast method (scanning/email, certified mail, or secure electronic access) to deliver copies when requested.

Under 1904.30(b)(3), you must link each employee to one of your establishments for recordkeeping and record the injury on that establishment's OSHA 300 Log (or on the log that covers the employee's short-term establishment).

• For employees who split time between sites or have no fixed site, pick one establishment to which the employee is linked for recordkeeping; record all their cases on that establishment's OSHA 300 Log as required by 1904.30(b)(3).
• Document how you assigned each multi-site or remote employee to an establishment so you can explain your approach during an audit or inspection.

Under 1904.30(b)(4), if the injury or illness occurs at one of your establishments, you must record it on the OSHA 300 Log of the establishment where the injury occurred.

• If the employee is injured while at one of your establishments, record the case on that establishment's log as required by 1904.30(b)(4).
• If the employee is injured while not at any of your establishments (for example, traveling away from work), record the case on the OSHA 300 Log of the establishment where the employee normally works, per 1904.30(b)(4).
• Note: separate rules on work-relatedness (e.g., travel status) in Part 1904 affect whether a case is recordable at all — see related interpretations about travel and work-related motor vehicle fatalities for details (for example, Work-related motor vehicle fatality).

Under 1904.30(b)(4), if the employee is injured at a location that is not one of your establishments (for example, a customer site), you must record the case on the OSHA 300 Log of the establishment where the employee normally works.

• When an employee is injured away from any of your establishments, record the case at the establishment to which that employee is linked (the place they normally work) as described in 1904.30(b)(4).
• Whether the incident is recordable still depends on the general work-relatedness and recording criteria in Part 1904; consult relevant sections and interpretations (for travel-related work, see Work-related motor vehicle fatality).

Under 1904.30 and related recordkeeping guidance, yes — you may keep records electronically and use software-generated forms so long as they are equivalent to OSHA forms and meet access requirements.

• OSHA's Letter of Interpretation on Software-generated OSHA recordkeeping forms states that electronic or alternative paper forms that meet the requirements for equivalent forms in 29 CFR 1904.29 may be used to satisfy Form 300 and Form 300A requirements.
• The equivalent forms must contain the same information, be as readable and understandable, and be completed using the same instructions as the OSHA forms; employers may maintain records in any file format (e.g., Excel, CSV) provided they can produce equivalent forms when needed, as discussed in the software-generated forms LOI and consistent with central-record rules in 1904.30(b)(2).
• All forms, including electronic equivalents, must be available for inspection and copying by authorized government representatives and for access by employees under 1904.40 and 1904.35.

Under 1904.30 and the software-generated forms Letter of Interpretation, your electronic record system must be able to produce equivalent OSHA Forms and make them available for inspection and copying by authorized government representatives as required by 1904.40.

• The Software-generated OSHA recordkeeping forms LOI explains that systems may store records electronically or in other file formats provided they can generate equivalent versions of OSHA Form 300, 300A, and 301 when needed.
• Systems must also support the access-to-records requirements for employees, former employees, and their representatives under 1904.35. Ensure your system can export readable, printable forms and respond within the timeframes required.

Under 1904.30(b)(1), yes — short-term establishments' recordable injuries and illnesses may be included on an OSHA 300 Log that covers short-term establishments for individual company divisions or geographic regions.

• The regulation explicitly allows maintaining one OSHA 300 Log that covers short-term establishments for divisions or regions in 1904.30(b)(1).
• Make sure the consolidated log still contains the same required information for each case and is organized so you can produce specific records when requested by employees or inspectors.

Under 1904.30, your consolidated short-term OSHA 300 Log must still identify the establishment or location associated with each case so records can be produced and traced to the proper site.

• While 1904.30(b)(1) allows a single log for short-term establishments or for divisions/regions, you must retain enough detail (such as columns or notes) to show where each injury occurred and which short-term site it relates to.
• Good practice: include a field for the short-term location name or code and the date of the incident so you can provide accurate records under 1904.35 and 1904.40.

Under 1904.30(b)(3), you must link that teleworking employee to one of your establishments for recordkeeping purposes; record any work-related injury on that establishment's OSHA 300 Log.

• The rule requires that each employee be linked to an establishment for recordkeeping per 1904.30(b)(3). You can choose the establishment logically responsible for that worker (for example, the office where their supervisor is based or the location listed in payroll records).
• Keep documentation of the linkage decision so you can demonstrate how you map teleworkers to establishments during inspections or audits.

Under 1904.30(b)(3) and (b)(4), record the injury on the OSHA 300 Log of the establishment to which the employee was linked at the time of the injury; if you change their linked establishment later, new incidents are recorded on the new establishment's log going forward.

• The rule requires that each case be recorded on the log of the establishment the employee is linked to at the time of the injury per 1904.30(b)(3) and that injuries occurring away from establishments be recorded at the employee's normal establishment per 1904.30(b)(4).
• When you reassign an employee to a different establishment, document the effective date of the reassignment so you can show which log applies to any particular incident.

Under 1904.30 and OSHA's travel-related interpretation, if the fatality occurred while the employee was engaged in work activities in the interest of the employer, it is work-related and should be recorded on the OSHA 300 Log of the appropriate establishment per recordkeeping rules.

• 1904.30(b)(4) tells you where to record (establishment where the employee normally works if injury occurred away from your establishments); whether the case is recordable depends on work-relatedness rules in Part 1904.
• OSHA's Letter of Interpretation on Work-related motor vehicle fatality explains that travel-status injuries are presumed work-related when they occur "in the interest of the employer," but there are limited exceptions (such as when the employee has established a “home away from home” at a temporary residence). Use that guidance to determine recordability and then record at the appropriate establishment per 1904.30(b)(4).

Under 1904.30 together with OSHA's guidance on musculoskeletal treatment, if the only treatment is first aid or stretching and the case does not meet any other recording criteria (days away, restricted work, transfer, medical treatment beyond first aid, loss of consciousness, or diagnosis by a physician/LHCP), then the case is generally not recordable.

• 1904.30 governs where to record cases but does not change the recording criteria; whether a musculoskeletal case is recordable depends on the general criteria in Part 1904.
• OSHA's memorandum on Recordability of musculoskeletal injuries explains that cases treated only with first aid, Active Release Techniques (ART), or exercise/stretching are generally not recordable unless they meet another recording criterion (for example, restricted work). If the case meets a criterion (e.g., a work restriction), then record it on the log of the employee's linked establishment per 1904.30(b)(3).

Under 1904.30 together with OSHA's paraffin wax interpretation, if the only treatment provided is heated paraffin wax used alone, the treatment is considered first aid and the case is not recordable.

• The location rules in 1904.30 tell you where to record cases that are recordable, but recordability itself follows the criteria in Part 1904.
• OSHA's Paraffin wax as medical treatment LOI states that heated paraffin wax is a form of hot therapy and is first aid for recordkeeping purposes; when used alone, it does not trigger recording unless combined with other treatments that meet recording criteria (e.g., prescription medication, physical therapy, restricted work). If the case does meet another recording criterion, record it on the OSHA 300 Log for the employee's linked establishment per 1904.30(b)(3).

Under 1904.30 and OSHA's software-generated forms guidance, employees and their representatives have the right to access OSHA records (including equivalent electronic forms), and the employer must provide access in the timeframes required by 1904.35.

• 1904.30(b)(2)(ii) requires that central record locations be able to produce and send records when required by 1904.35 (employee access).
• The Software-generated OSHA recordkeeping forms LOI clarifies that electronic equivalents are permitted provided they are as readable and understandable as the OSHA forms and can be produced on request for employees, former employees, and their representatives.

Under 1904.30(b)(2)(ii) and 1904.40, you must produce the OSHA Forms (or their equivalent electronic versions) for the establishment(s) requested, and you must do so within the time frames set by 1904.40.

• 1904.30(b)(2)(ii) requires central recordkeepers to be able to send records when required by 1904.35 and 1904.40.
• The Software-generated OSHA recordkeeping forms LOI reiterates that electronic equivalents must be available for inspection and copying by authorized government representatives.

Under 1904.30(b)(2)(i), you must transmit information about a recordable injury or illness to the central location within seven calendar days of receiving information that a recordable case occurred; you should not wait indefinitely to transmit while you chase confirmations.

• The seven-day requirement in 1904.30(b)(2)(i) starts when the establishment first receives information that the case is recordable, not when every detail is finalized.
• If additional details become available later, update the central record promptly so the log remains accurate and complete.

Under 1904.30 and OSHA's electronic submission guidance, central recordkeeping is compatible with the annual electronic submission requirements, but employers must still meet their submission deadlines and ensure accurate data is reported.

• 1904.30(b)(2) allows central storage, but you must be able to produce and transfer records when required under 1904.35 and 1904.40.
• OSHA's memorandum on Electronic injury record submission enforcement explains the requirements and deadlines for electronic submittal (for example, annual Form 300A data submission deadlines) and OSHA's focus on enforcement for failures to submit. Ensure your central system can compile and export the required Form 300A (and where applicable Form 300 and 301) data for electronic submission.