OSHA 300 vs 300A vs 301

All three forms exist because they answer different questions. The 300 asks "what happened this year?", the 300A asks "how much, in total?", and the 301 asks "what exactly happened in this one case?" Understanding which question you are answering makes the rest of recordkeeping considerably easier.

This guide is an orientation, not legal advice, and obligations differ by employer. The authority is 29 CFR Part 1904, and the forms themselves are published on OSHA's recordkeeping forms page.

The three forms at a glance

Form 300 — the log

The 300 is the running list. Each recordable case gets one line, recording who was involved, their job title, the date, where it happened, a short description, and then the part that drives everything downstream: how the case is classified.

Classification is by outcome, in a strict order of severity — death, days away from work, job transfer or restriction, or other recordable case. A case is counted in the most serious column that applies, not in several. Alongside it you record the number of days away and the number of days on transfer or restriction, and whether the case was an injury or one of the illness categories.

Two details catch people out. Day counts are capped at 180 calendar days per case for each of the away and restricted columns, so a long-term absence stops accumulating at that point (1904.7). And the days counted are calendar days, not scheduled work days — weekends and holidays count if the worker would have been unable to work.

Form 300A — the annual summary

The 300A takes a year of the 300 log and reduces it to totals: how many cases in each classification, how many days away and restricted, and how many fell into each injury and illness category. It also carries the establishment's details and its average number of employees and total hours worked for the year — which is what makes rate calculation possible.

It is the only one of the three that employees routinely see. A company executive certifies that they have examined the log and believe the summary is correct, and the signed summary is posted where notices to employees are customarily displayed, from 1 February to 30 April of the following year (1904.32). It is posted even if there were no recordable cases that year — a zero summary still goes up.

Separately from posting, some establishments must submit their 300A data electronically to OSHA through the Injury Tracking Application. Which establishments that covers depends on size and industry, and it has changed more than once — check the current requirement rather than relying on what applied a few years ago.

Form 301 — the incident report

The 301 is the case file: how the injury or illness occurred, what the employee was doing beforehand, what object or substance was involved, and details of treatment including the physician and facility. One form per recordable case, completed within seven calendar days of learning the case occurred.

Because it holds the most detail about an individual, it is the form with the tightest handling considerations, and an equivalent form — many organizations use their insurance or workers' compensation report — may be used in its place provided it captures the same information.

How one case flows through all three

A single injury does not produce three separate pieces of work. It produces one investigation whose output lands in three places:

1. An event occurs and is reported. Someone determines whether it is work-related and whether it meets the recording criteria in 1904.4.
2. If recordable, it gets a line on the 300, classified by outcome.
3. The detail of that case is captured on a 301.
4. If the outcome changes — an employee initially sent home returns on restricted duty, or a case becomes days-away later — the 300 line is updated. Classifications are not frozen at first entry.
5. At year end, the log totals become the 300A, which is certified and posted.

Establishments, not companies

Records are kept per establishment — a single physical location where business is conducted — rather than merged across a company. A firm with four sites keeps four logs and posts four summaries, each showing that site's own cases.

This matters more than it first appears. It means a site's rate is calculated from its own cases and its own hours, so a good year at headquarters cannot mask a bad one at a plant. It also means employees who work at multiple locations, or at no fixed location, need a rule for which establishment they are linked to.

Who has to keep them

Not every employer. There are two broad partial exemptions: employers who had ten or fewer employees at all times during the previous calendar year (1904.1), and establishments in certain lower-hazard industries (1904.2).

"Partially exempt" is the important phrase. Exempt employers still have to report severe outcomes to OSHA — a work-related fatality, and any in-patient hospitalization, amputation or loss of an eye — within the timeframes in 1904.39, and they may be required to keep records if OSHA or the Bureau of Labor Statistics asks in writing. State plans may also impose requirements beyond the federal rule. If you believe you are exempt, confirm it against the current regulation rather than assuming.

Retention and access

The 300 log, the 300A summary and the 301 reports are kept for five years following the end of the calendar year they cover, and the 300 log must be updated during that period if new information about a recorded case comes to light (1904.33). Employees, former employees and their representatives have rights of access to these records under 1904.35.

Where people go wrong

• Treating first aid as recordable. First aid only, as OSHA defines it, is not recordable. The definition is specific and worth reading rather than guessing at.
• Counting scheduled days instead of calendar days. Weekends count.
• Double-classifying a case. One case, one column — the most serious that applies.
• Never revisiting a case. Outcomes evolve; the log is meant to be updated during the retention period.
• Merging establishments. One combined log across sites defeats the point of establishment-level records.
• Forgetting to post a zero year. The 300A goes up whether or not anything happened.

Sources

• OSHA — 29 CFR Part 1904 — recording and reporting occupational injuries and illnesses
• OSHA — Injury and illness recordkeeping forms (300, 300A, 301)
• OSHA — 1904.1 — partial exemption for employers with ten or fewer employees
• OSHA — 1904.2 — partial exemption for establishments in certain industries
• OSHA — 1904.7 — general recording criteria, including the 180-day cap
• OSHA — 1904.32 — annual summary, certification and posting
• OSHA — 1904.33 — retaining and updating records
• OSHA — 1904.39 — reporting fatalities and severe injuries to OSHA
• OSHA — Injury Tracking Application — electronic submission