Retention of old OSHA forms

You must keep your copies of the OSHA 200 and 101 forms for five years after the year to which they relate. This requirement is stated in 1904.44.

• The five-year count begins at the end of the calendar year the records cover (for example, records for 2022 must be retained through the end of 2027).
• Keep in mind other legal or contractual obligations (litigation holds, state requirements) could require longer retention.

No — you are not required to update your old OSHA 200 and 101 forms. 1904.44 explicitly states employers do not have to update those older forms.

• Even though you do not have to change them, you must retain the original copies for five years and make the information available as required by the recordkeeping rules.

You must continue to provide access to the OSHA 200 and 101 data as though those forms were the OSHA 300 and 301 forms. 1904.44 requires employers to make the data available for employee access and government inspection in the same way the newer forms are treated.

• That means the records must be intact, readable, and available for inspection or copying under the access provisions in Part 1904 (see the general 1904 page for related provisions).
• If you rely on electronic records, they must produce equivalent, readable output when needed; see OSHA’s interpretation on software-generated forms at https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29.

Yes — you may store the old OSHA 200 and 101 forms electronically so long as you can produce equivalent, readable records and provide access in the same manner as OSHA 300/301 records. OSHA’s interpretation about software-generated forms explains electronic records are acceptable if they meet the equivalency and accessibility requirements in Part 1904; see https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29 and the general Part 1904.

• The electronic format must be as readable and understandable as the original forms and be producible on request for employees or OSHA inspectors.

No, 1904.44 does not require you to convert historical OSHA 200 and 101 records into new OSHA 300/301 forms. 1904.44 states you must keep the old forms for five years and provide access as if they were OSHA 300 and 301, but it does not mandate reformatting historical records.

• However, for current and future compliance you must follow electronic submission rules (for example, requirements described in the enforcement guidance for electronic submissions) where applicable; see OSHA’s memorandum on electronic injury record submission enforcement at https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16.

No — you are not required to update or revise old OSHA 200 and 101 forms once created. 1904.44 states employers are not required to update those old forms.

• Nonetheless, employers should make good-faith recordkeeping determinations at the time cases are recorded and, where corrections are necessary to reflect accurate information for current compliance or to respond to an inspection, you can document corrections or attach an explanatory note instead of altering the original document.
• For guidance on making recordability determinations you can refer to relevant Part 1904 guidance and interpretations (for example, see the discussion in other letters of interpretation linked from 1904).

Yes — even if you use software-generated, equivalent forms for recordkeeping, you still must retain copies of the OSHA 200 and 101 forms for five years after the year to which they relate. 1904.44 requires the five-year retention.

• OSHA’s interpretation on software-generated forms at https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29 explains electronic equivalents are allowed provided they produce equivalent output and are available for inspection in accordance with the access rules in Part 1904.

The five-year retention period begins after the calendar year to which the OSHA 200 and 101 records relate. 1904.44 uses the phrase "five years following the year to which they relate," meaning records for a given calendar year must be kept through the end of the fifth calendar year after that year.

• Example: records for 2020 must be retained through December 31, 2025.

Yes — you may produce electronic equivalents of old OSHA 200 and 101 records during an OSHA inspection if those electronic records are equivalent, readable, and can be produced on request. 1904.44 requires making the information available as though the old forms were OSHA 300 and 301, and OSHA’s interpretation on software-generated forms clarifies electronic records are acceptable when they meet the equivalency and access provisions in Part 1904; see https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29.

• OSHA inspectors may ask for copies and must be able to view or obtain the information in a readable format during the inspection.

State Plans must have standards and enforcement programs at least as effective as federal OSHA, but individual State Plans may adopt different or more stringent recordkeeping rules. 1904 is the federal recordkeeping rule and 1904.44 sets the federal five-year retention for OSHA 200 and 101.

• If you operate in a State Plan state, check your State Plan’s regulations or contact the state agency because some States may impose different retention or update requirements (State Plans are discussed in other OSHA interpretations; for example, see references to State Plan application in related letters such as https://www.osha.gov/laws-regs/standardinterpretations/2024-10-22).

After the required five-year retention period ends, you may dispose of the OSHA 200 and 101 records unless another obligation requires longer retention. 1904.44 sets the five-year rule but does not preclude longer holds.

• Before destroying records, confirm there are no ongoing inspections, litigation holds, other regulatory retention rules, or company policies that require keeping them longer.
• When in doubt, consult legal counsel or your records-retention policy to avoid inadvertent destruction during an active matter.

No — you are not required to update old OSHA 200 and 101 forms simply because a later determination changes recordability. 1904.44 states old 200 and 101 forms need not be updated.

• That said, employers should make good-faith recordability determinations at the time of recording. If a later event (for example, a medical opinion or an OSHA inspection) requires amendment for current compliance or reporting, document the change (for example, with an addendum or note) so the historical record and rationale are preserved.
• For guidance about making recordability determinations, see other Part 1904 guidance and letters of interpretation (for example, the common-cold exception discussion at https://www.osha.gov/laws-regs/standardinterpretations/2023-11-15).

Yes — employees must be given access to OSHA 200 and 101 records in the same manner as they would be given access to OSHA 300 and 301 records. 1904.44 requires employers to provide access to the data as though the old forms were the OSHA 300 and 301.

• Employee access rights and procedures are covered under the Part 1904 provisions (see the general 1904 resource and the software interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29 for electronic access considerations).

Equivalent electronic records in formats like Excel or CSV are acceptable if they contain the same information, are as readable and understandable as the OSHA forms they replace, and can be produced when access is required. OSHA’s interpretation on software-generated forms explains that electronic equivalents must meet the equivalency standards in Part 1904 and be producible for access and inspection; see https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29 and the general 1904.

• Ensure your electronic files can generate output that is essentially the same as the OSHA forms and can be provided to employees or OSHA representatives upon request.