OSHA 300/300A/301 in QEHS: the fastest path to a clean log

OSHA Part 1904 is one of the most-cited regulations US employers deal with. The paperwork itself (300, 300A, 301) is straightforward. The case-classification decisions — recordable vs. first-aid, restricted work vs. days away, privacy cases — are where programs trip.

In the Incidents module, every new report runs through a guard tree that asks the same three questions OSHA asks: did treatment go beyond first aid, did the case involve days away or job transfer, and is it on the OSHA-covered list of musculoskeletal / hearing / TB disorders? The answer drives the 300-log classification automatically.

The recordability determination hinges on whether treatment goes beyond first aid. The first-aid list in 29 CFR 1904.7(b)(5)(ii) is exhaustive and short: non-prescription medication at non-prescription strength, tetanus immunisations, wound cleaning, bandages, hot and cold therapy, and finger guards. Anything beyond that list makes the case recordable. For the related metrics, see the TRIR, LTIR, and DART glossary entries.

Two obligations programs miss in 2026: records must be retained for five years from the year the case occurred, and establishments with 100 or more employees in OSHA-designated industries must submit data electronically through the Injury Tracking Application (ITA). The electronic-submission rule is what shifted recordkeeping from a paper exercise to a data exercise — and why the case-classification decisions upstream now flow straight to a regulator.

The recordable decision is two decisions stacked. The first is work-relatedness: under 29 CFR 1904.5, an injury or illness is work-related if an event or exposure in the work environment either caused or contributed to the condition, or significantly aggravated a pre-existing condition. The 1904.5(b) exceptions are narrow and specific — the common cold, the flu, blood donations, eating a sandwich, a voluntary fitness activity, and a few others — and an injury that meets an exception is not recordable even if it happened at work. The work-relatedness call is the one programs get wrong under time pressure, because the default is recordable and the exception has to be argued.

The second decision is recordability, and the first-aid list is the line that separates a recordable case from a treatable one. The list is short, it is exhaustive, and it is a closed set: a treatment that appears on it does not make the case recordable, and a treatment that does not appear on it does. Stitches, a prescription, a splint, removal of a foreign body from an eye, or a day away from work all sit beyond the list and all make the case recordable. The trap is treating the list as a guide rather than a rule — a supervisor who reads it as "use judgment" will under-record, and the under-recording shows up in the ITA submission, not in an internal dashboard.

The 301 Incident Report is the per-case record that sits behind every 300-log line. It carries the case description, the objects or substances involved, the sequence of events, and the disposition. The 300 log is the summary; the 301 is the evidence. An auditor who pulls a 300 entry without a matching 301 has found a gap on the spot, which is why the two have to be created together — not the 300 filed now and the 301 back-filled before the audit.

• Privacy case caps apply to a small set of injuries — sexual assault, HIV or hepatitis, tuberculosis, a needlestick or sharps injury with a contaminated sharp, a mental illness, or a case where the employee asks to keep their name off the log. For these, the 300 log uses the employee job title instead of the name, and the 301 is stored separately.
• The 300A annual summary is a single page that aggregates the year case counts by column. It must be certified by an owner, officer, or higher-level employee — a supervisor signature does not satisfy the requirement. The certification is the one step that converts a pile of 300 entries into an annual record.
• Retention is five years plus the current year for the 300, 300A, and 301, kept at the establishment they cover. The retention clock starts the year the case was entered, not the year the case closed, which matters for a long-running lost-time case.

The classification that produces the most audit findings is restricted duty versus days away. A day of restricted work is a day the worker could not perform one or more of their routine job functions; a day away is a day the worker could not come to work at all. The two map to different 300-log columns (H for days away, I for restriction or transfer), and a case can move between them — a worker on restricted duty who is later sent home is counted in both, with the day count split. The platform tracks the return-to-work event that reclassifies the case, so the column totals are the totals the regulator expects, not a reconstruction from memory.

1. Configure the incident form so the recordability guard tree runs on submit — the three OSHA questions (beyond first aid, days away or transfer, on the covered disorder list) drive the 300-log classification without a manual call.
2. Pair every 300 entry with a 301 auto-drafted from the incident record, so the auditor pulling a 300 line always finds its 301.
3. Drive the day count from the return-to-work workflow — the worker on restricted duty who goes home reclassifies automatically, and the H and I totals stay honest.
4. Schedule the 300A certification and the ITA submission as calendar workflows with reminders, so the February-to-April posting window and the March submission deadline do not arrive as surprises.
5. Retain by establishment for five years plus current, with the retention clock on the year of entry, and produce the archive on demand for an inspector.

The fastest path to a clean log is the one that does not rely on the safety manager remembering the rules at the end of the year. The rules are in the form, the form classifies at entry, the 301 is created with the 300, and the day counts move with the worker. For the related metrics, see the TRIR, LTIR, and DART glossary entries; for the program design, the near-miss to CAPA handoff and the incident investigation best practices posts.

The 300 log is an establishment-level record, not a company-level one. Each fixed establishment keeps its own 300, 300A, and 301 for the cases that occurred there, and the annual summary is certified per establishment. A company with five covered establishments produces five logs and five annual summaries, not one consolidated record, and an inspector who asks for the log asks for the establishment log. The entry rule in 29 CFR 1904.29 requires the case on the 300 Log within seven calendar days of receiving the report: the employer has to decide whether the case is recordable and which columns apply, and the decision has to be made while the facts are still fresh — which is the operational case for classifying at the point of entry rather than reconstructing the decision at year end.

The healthcare provider does not make the recordability decision; the employer does. A physician who checks a box on a form is advising, not deciding, and the employer remains responsible for the classification — which is why the platform routes the provider note to the employer decision step rather than the other way around. A case is also not frozen at first classification: if a worker initially expected to return next day is later kept out for a week, the case updates from a restricted-duty case to a days-away case, and the column totals update with it. The record that closes the year is the record as it stood at year end, with every reclassification captured in the audit trail.

The annual summary is the one record a regulator can ask to see without notice, and it is the one a plaintiff can ask for in discovery. The summary is built from the 300 entries, but it is the certification that makes it the record — a signed 300A is the attestation that the underlying entries are complete and accurate. A program that produces the 300A from a live query, rather than from a spreadsheet pasted at year end, produces a summary that matches the detail, which is the only summary worth certifying.