OSHA recordkeeping in 2026: what changed and what stays the same
A current guide to OSHA 300, 300A, and 301 requirements — electronic submission, recordability determinations, and the proposed changes to injury tracking.
Founder & CEO
The QEHSEthos Team built the QEHS platform after a decade managing EHS programs in heavy industry. We write about safety culture, regulatory strategy, and how software can get out of the way.
7 min read
Reviewed by QEHSEthos Team — Founder & CEO
OSHA recordkeeping under 29 CFR 1904 requires employers to record work-related injuries and illnesses on the OSHA 300 Log, post the 300A summary annually, and maintain records for five years. The electronic submission rule requires establishments with 100+ employees in designated industries to submit data through the ITA.
The recordability determination hinges on whether treatment goes beyond first aid. The first aid list in 1904.7(b)(5)(ii) is exhaustive — non-prescription medication, tetanus shots, wound cleaning, bandages, hot/cold therapy. Anything beyond this list makes the case recordable. For definitions: [TRIR](/glossary/trir), [LTIR](/glossary/ltir), [DART](/glossary/dart).