Subpart D
You must review the OSHA 300 Log, create an annual summary, certify that summary, and post it where employees can see it. See the basic requirements in 1904.32(a).
You must review the OSHA 300 Log as extensively as necessary to ensure entries are complete and correct. The rule requires whatever level of review is needed to identify and fix deficiencies in the Log entries; see 1904.32(b)(1) and the general annual-review requirement in 1904.32(a)(1).
You must total the columns on the OSHA 300 Log and enter the calendar year, company name, establishment name and address, the establishment’s annual average number of employees covered by the Log, and the total hours worked by those employees. See 1904.32(b)(2)(i) and 1904.32(b)(2)(ii).
If you had no recordable cases, you must still complete the summary and enter zeros for each column total. The rule explicitly requires entering zeros when there are no recordable cases; see 1904.32(b)(2)(i).
Yes — you may use an equivalent electronic or paper form so long as it contains the same information, is as readable and understandable, follows the same instructions, and includes the employee access and employer penalty statements. OSHA allows equivalent and software-generated forms if they meet the equivalence requirements in 1904.29(b)(4) and the summary-content requirements in 1904.32(b)(2)(iii). See also OSHA’s letter confirming software-generated forms can satisfy Part 1904 requirements at https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29.
A company executive must certify they have examined the OSHA 300 Log and reasonably believe, based on knowledge of how the information was recorded, that the annual summary is correct and complete. That certification requirement is set out in 1904.32(b)(3).
A qualifying company executive is one of: an owner (for sole proprietorships/partnerships), a corporate officer, the highest-ranking company official working at the establishment, or that official’s immediate supervisor. See the list in 1904.32(b)(4) and its subparts.
You must post a copy of the annual summary in each establishment in a conspicuous place where employee notices are customarily posted, and keep it posted from no later than February 1 through April 30 following the year covered. See 1904.32(b)(5) and 1904.32(b)(6).
No — the posted annual summary must not be altered, defaced, or covered by other material while it is on display. The regulation requires that the posted summary remain unaltered and visible to employees; see 1904.32(b)(5).
You must report the annual average number of employees covered by the OSHA 300 Log and the total hours worked by those employees for the calendar year covered; use your payroll and time records to calculate those figures. The requirement to enter those items is in 1904.32(b)(2)(ii). For practical computation methods, employers commonly average quarterly employee counts or use total employee-hours divided by 2,080 for full-time equivalents, but keep documentation of the method used in case of inspection under 1904.
Yes — any equivalent form used instead of the OSHA 300–A summary must also include the employee access and employer penalty statements that appear on the OSHA Form 300A. This is required by 1904.32(b)(2)(iii) and the equivalence rules in 1904.29(b)(4).
Yes — the regulation explicitly allows the immediate supervisor of the highest-ranking company official working at the establishment to be the certifying company executive. See 1904.32(b)(4)(iv).
Yes — you may maintain your Part 1904 records electronically and produce equivalent forms for posting, provided the electronic system can generate forms equivalent to OSHA Forms 300 and 300A and meet access requirements. OSHA’s letter about software-generated forms confirms electronic records and equivalent forms are acceptable when they meet 1904.29(b)(4) and (b)(5) requirements; see OSHA’s interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29 and the annual-summary content rules at 1904.32(b)(2).
It requires the executive to have reviewed and be familiar with how entries were made (including investigations, recordkeeping procedures, and corrections) and to believe the summary accurately reflects those records before signing. That standard for certification is explained in 1904.32(b)(3) and ties to the year-end review duty in 1904.32(a)(1).
You must post a copy of that establishment’s annual summary in each establishment in a conspicuous place where notices to employees are customarily posted; each establishment needs its own posted summary. See 1904.32(b)(5).
No — the regulation requires a copy to be posted in conspicuous places where employee notices are customarily posted in the establishment; electronic recordkeeping is allowed for maintaining records, but the posting requirement itself is satisfied by posting in the workplace per 1904.32(b)(5). Employers using electronic systems should still produce and post the summary where employees will see it unless they have another arrangement that meets the regulation and ensures employee access. See also OSHA’s guidance allowing electronic records if they can produce equivalent forms in https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29.
You must post the summary no later than February 1 of the year following the year covered and keep the posting in place until April 30. See 1904.32(b)(6).
You must correct any deficiencies you identify so that the OSHA 300 Log and the annual summary are complete and accurate. The duty to review and correct deficiencies is stated in 1904.32(a)(1).
Yes — the annual summary totals reflect cases recorded on the OSHA 300 Log, which are populated from the Form 301 incident reports; you must total the Log columns (which summarize the Form 301 data) when completing the summary as required by 1904.32(b)(2)(i) and 1904.29.