OSHA’s Recordkeeping Standard, 29 CFR 1904, requires that certain employers maintain annual records of workplace injuries and illnesses. The records are maintained throughout the calendar year on the OSHA Form 300 Log of Work-Related Injuries and Illnesses (300 Log) and are summarized on the OSHA Form 300A Summary of Work-Related Injuries and Illnesses (300A Summary) at the end of each calendar year. The 300A Summary is required to be posted in the workplace every Feb. 1 through April 30 to show records from the previous year’s injuries and illnesses, even if no work-related injuries or illnesses occurred during the previous year.
Helping your company comply with OSHA regulations is one of the key benefits of ADP TotalSource®. If your company is not partially exempt (either by industry, size, or both) from OSHA recordkeeping requirements, ADP® will help you fulfill this responsibility by providing your company with its preliminary 300 Log and 300A Summary at the end of January each year. The preliminary 300 Log and 300A Summary are available through your MyTotalSource® website. Please see access instructions below.
As the worksite employer, you may need to take additional steps to ensure your 300 Log and 300A Summary fully capture the information required by OSHA. The preliminary 300 Log and 300A Summary are based on workers’ compensation data reported to TotalSource and may not contain all the information necessary to complete the 300 Log and 300A Summary. The
preliminary 300 Log, for example, may be missing adequate details describing the injury or cause of injury because that information was not provided when the injury or illness was reported.
Additionally, since workers’ compensation and OSHA recordable injuries are not directly correlated, there may have been injuries at your workplace that were not reported to workers’ compensation or denied by workers’ compensation that should be included on your 300 Log and 300A Summary. For example, OSHA requires that controlling worksite employers record data for injuries and illnesses for temporary employees and sub-contracted employees used by those employers. TotalSource does not have access to temporary and/or sub-contracted employee injury and illness data and, as such, it will not be included on your preliminary 300 Log and 300A Summary.
OSHA updated electronic recordkeeping requirements in 2023
The new rule retained the requirement to electronically submit OSHA form 300A Summary data by March 2, every year. This requirement applies to:
§ Establishments with 250+ employees in industries that must routinely keep records, and
§ Establishments with 20 to 249 employees in designated high-hazard industries listed in Appendix B to Subpart E of 29 CFR Part 1904
The new rule updated these requirements.
§ Establishments with 100 or more employees in designated high-hazard industries must electronically submit OSHA 300 Log, OSHA 300A Summary and Form 301 Incident Report data.
Check OSHA’s ITA Coverage Application to see if your establishment is affected.
Recording workplace exposures to COVID-19
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COVID-19 can be a recordable illness if a worker is infected by performing his/her work-related duties. However, employers are only responsible for recording cases of COVID-19 if all the following are true:
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PureSafety course available on myLearning@ADP
The course “OSHA 300 Recordkeeping Requirements” is available on-demand through ADP’s learning management system, myLearning@ADP for free! Access to myLearning@ADP is through your MyTotalSource website.
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How to access preliminary OSHA 300 Log and OSHA 300A Summary in MyTotalSource
- Enter your Paygroup and click ‘GO’
- Click on the ‘Workers Comp’ tab
- Click on ‘300A (OSHA Summary)’ and/or ‘OSHA 300 Log’
- Enter ‘2022’ for the year
- Click ‘Get’ and review reports
- Print and sign both reports
- Post OSHA 300A Summary
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Questions
If you have any questions about the information on your preliminary OSHA 300 Log or 300A Summary and/or would like additional guidance on OSHA recordkeeping requirements, such as partial exemptions, please contact your TotalSource Risk and Safety Consultant for assistance.
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FAQ
Do I need to maintain records for injuries or illnesses in my workplace?
To find out if you are required to prepare and maintain records, first determine your NAICs code. You can see if your industry is exempt from recordkeeping rules. There are certain low-risk industries that are exempt. Many employers with more than 10 employees are required to keep a record of serious work-related injuries and illnesses. Minor injuries requiring first aid only do not need to be reported.
How long must I retain OSHA recordkeeping records?
The records must be maintained at the worksite for at least five years.
What if an employee asks for OSHA recordkeeping record?
If requested, copies of OSHA recordkeeping records must be provided to current and former employees, or their representatives.
What is the severe injury reporting requirement?
Employers must report any worker fatality within 8 hours and any amputation, loss of an eye, or hospitalization or a worker within 24 hours.
What are the electronic records submission requirements for my company?
The Injury Tracking Application (ITA) is accessible from the ITA launch page, where you can provide the Agency your OSHA Form 300A information. Employers are required to submit their completed OSHA Form 300A by March 2 for the previous year records.
- Establishments with 20 or more employees, in certain high-hazard industries, continue to electronically submit Form 300A Annual Summary information once a year to OSHA.
- Establishments with 100 or more employees in the highest-hazard industries to submit Form 300 Log and Form 301 Incident Report information once a year to OSHA. These establishments would continue to be required to electronically submit information from their Form 300A Annual Summary.
- Establishments with 250 or more employees, not in designated high-hazard industries, would not longer be required to electronically submit recordkeeping information to OSHA.
The OSHA Injury Tracking Application (ITA) has transitioned its login procedure to the public's one account access to government applications, Login.gov. All current and new account holders must connect their ITA account to a Login.gov account with the same email address to access the application for the 2024 collection of Calendar Year 2022 Form 300A data.
§ Before proceeding, please review the following guidance on how to connect your accounts: Create a Login.gov Account
§ If you have additional questions, please visit the FAQs. If none of the FAQs address your question, a Help Request Form is available from that page.
https://www.osha.gov/recordkeeping