2025 is Almost Over – Are Your OSHA Logs in Order?

By Phil Molé, MPH

As we move closer to a new year, one of the most important compliance tasks for employers is quickly approaching: OSHA’s annual injury and illness recordkeeping deadlines. Whether you manage safety data directly or oversee HR and compliance operations, now is the time to make sure your team is ready.

In what follows, you’ll get the information you most need to start making sure your OSHA injury and illness records are in order before the next compliance deadlines arrive.

What is the OSHA Recordkeeping Standard?

It might help to have a little background on the Recordkeeping Standard itself.

The OSHA Recordkeeping Standard is all about keeping workplaces safe and transparent. It requires certain employers to track and report work-related injuries and illnesses using three key forms — the OSHA Form 300 Log, Form 301 Incident Report, and Form 300A Annual Summary. The Recordkeeping Standard is among the very first regulations issued by OSHA in 1971, soon after the agency’s creation under the 1970 Occupational Safety and Health Act.

Why the Standard such a high priority for OSHA? Because OSHA knows that injury and illness records tell a story about safety performance, and employers need to preserve that story. Injury and illness records allow employers to spot trends, uncover recurring hazards, and act before someone gets hurt. The records serve a purpose for OSHA, too, because the data highlights national patterns that shape safety regulations and enforcement.

In short, good recordkeeping isn’t just about compliance — it’s a tool for building a stronger, safer workplace for everyone. OSHA requires some employers to maintain injury and illness records precisely so they can use the information to prevent additional injuries, and so OSHA can have a data source to help them focus their own regulatory and enforcement efforts.

Who Must Keep OSHA Logs?

Not all employers need to keep OSHA injury and illness records. However, employers at companies with 11 or more employees at the company level are required to maintain OSHA injury and illness records, unless their primary North American Industry Classification System (NAICS) code is listed among lower-hazard industry sectors OSHA considers partially exempt from Recordkeeping requirements.

The three forms that OSHA requires employers covered by the Recordkeeping Standard to complete and maintain are:

• Form 300 (Log of Work-Related Injuries and Illnesses)
• Form 301 (Injury and Illness Incident Report)
• Form 300A (Summary of Occupational Injuries and Illnesses)

Employers are also “partially exempt” if they had 10 or fewer employees at all times during the reporting year, although they must still report several categories of serious incidents directly to OSHA. These categories, and their associated reporting timeframes, are as follows:

• Fatalities (within 8 hours)
• Inpatient hospitalizations, amputations, or eye losses (within 24 hours)

Key OSHA Recordkeeping Dates and Requirements for 2025

🗓️ February 1: Post Form 300A

By February 1, covered employers must prepare, certify, and post OSHA Form 300A, the Summary of Work-Related Injuries and Illnesses, for the previous calendar year (January 1 – December 31).

This signed summary must remain posted in a visible area — such as a break room or bulletin board — through April 30. Even if no recordable injuries or illnesses occurred, the employer must still complete and post a form documenting that zero recordable injuries and illnesses occurred.

OSHA Form 300A Certification and Accountability

Before posting Form 300A, it must be certified by a company executive — typically an officer, the highest-ranking local official, or the manager responsible for that establishment. Certification verifies the accuracy of the information and emphasizes leadership accountability for workplace safety.

Who does OSHA consider to be a company executive for purposes of signing/certifying the 300A? The regulation itself provides context here. Specifically, 1904.32 (b)(4) says that a company executive can be “an owner of the company (only if the company is a sole proprietorship or partnership),” “an officer of the corporation,” “the highest-ranking company official working at the establishment,” or “the immediate supervisor of the highest-ranking company official working at the establishment.” The site’s EHS person could sign if she or he met one of those criteria.

Who Must Submit Occupational Data Electronically?

Only some establishments at companies covered by the Recordkeeping Standard need to electronically submit injury and illness data to OSHA via the Injury Tracking Application (ITA).

The most current electronic reporting requirements are those enshrined in OSHA’s 2023 electronic reporting final rule, which went into effect in January 2024.

At a very high level, the 2023 OSHA final rule created 4 different categories of electronic reporting obligations, depending on establishment size and industry sector, as shown in the chart below.

Establishment size (# of employees)	Industry sector	Electronic injury and illness reporting requirements
<20	All industries	No electronic reporting requirements
20-249	Listed in Appendix A of 29 CFR 1904	Electronic 300A reporting
100+	Listed in Appendix B of 29 CFR 1904	Electronic 300, 300A and 301 reporting
250+	All industries covered by the Recordkeeping Standard	Electronic 300A reporting

Here’s more detail about how requirements break down for each of the four categories of establishments listed in the table above.

Establishments with < 20 employees
If you have fewer than 20 employees at your establishment at any one time, you don’t need to do electronic injury and illness reporting, whether under current requirements or revised requirements. Just document your employee headcount, making sure it includes all eligible employees.

Certain establishments with 20-249 employees

Establishments with 20–249 employees in certain designated industries (listed in appendix A to subpart E) will continue to be required to electronically submit information from their Form 300A annual summary to OSHA once a year (final § 1904.41(a)(1)(i)).

Establishments with 100+ employees listed in the new Appendix B

Establishments with 100+ employees in certain designated industries (listed in new appendix B to subpart E) will be newly required to electronically submit information from their OSHA Forms 300 and 301 to OSHA once a year (final § 1904.41(a)(2)). The industries listed in new appendix B were chosen based on three measures of industry hazardousness.

Establishments with 250+ employees subject to Recordkeeping Standard

Establishments with 250+ employees in industries that are required to routinely keep OSHA injury and illness records will continue to be required to electronically submit information from the Form 300A to OSHA once a year.

The electronic reporting deadline for employers at all establishments that must submit data via the ITA is March 2, for the previous calendar year’s data. One way to remember the deadline is that one month and one day after the physical 300A is signed and posted, the data is due to OSHA via the ITA, if applicability criteria are met.

If you have multiple establishments that must electronically submit injury and illness data, you can submit the data for all establishments via the ITA in a single .csv file, and it will simultaneously upload to OSHA’s portal.

As previously mentioned, OSHA uses the employer-submitted data to determine the need for new regulations or enforcement initiatives or assess the performance of existing initiatives.

Don’t Forget: Human Resources (HR) Has a Role in OSHA Logs, Too

While OSHA recordkeeping responsibilities often fall under the EHS or safety team, HR departments play a critical role. That’s because employee counts, job classifications, and incident documentation are often managed through HR systems, and HR staff often handle worker’s compensation claims, which follow different rules of applicability but involve some of the same cases as OSHA recordable incidents.

Coordinating early with HR can ensure:

• Employee rosters align with OSHA reporting requirements
• Incident data is consistent across departments
• Certification and posting deadlines are met seamlessly

Cross-functional coordination helps prevent compliance gaps — and can make a big difference during audits or inspections.

Why Recordkeeping Matters

Accurate OSHA recordkeeping isn’t just about checking a compliance box — it’s a critical part of understanding and improving workplace safety. The data employers collect and report helps OSHA identify industry trends, recognize hazards, and guide enforcement priorities.

As mentioned earlier, organization leaders and EHS personnel need this data, too. Injury and illness records provide a window into safety performance, supporting proactive risk management and better resource planning.

Don’t let yourself fall into the self-defeating pattern of seeing OSHA Recordkeeping compliance as a regulatory “homework assignment.” Instead, try to see it as one aspect of a robust and effective incident management program. The incident details captured on Form 301, such as details about what happened and what factors contributed to the incident, are the very things that you as an employer need to be able to prevent future incidents, and the details you should capture for all workplace incidents during investigations.

 

How EHS Software Can Help Improve Incident Management

Modern EHS software can dramatically simplify OSHA recordkeeping. For example, mobile incident reporting capabilities make it easier to initiate incident investigations, upload photos and other documentation, and track follow-up actions. You can also quickly generate all three OSHA forms from your incident records, and if applicable, transmit your data to OSHA via the ITA. In fact, you can quickly compile data for all reporting establishments onto a single .csv file for easy submission.

EHS software can also support analytics and trend reporting — turning compliance data into actionable insights, which is really the ultimate point. For example, think about the several categories of serious incidents you need to report directly to OSHA on short timelines – fatalities, hospitalizations, and incidents involving amputations or loss of eye. These types of serious injuries and fatalities (SIFs) often prove the most challenging to prevent, and in fact, OSHA and Bureau of Labor Statistics (BLS) data show that rates of SIFs over the last 20 years have remained relatively flat, even as rates of less severe injuries and illnesses have dropped significantly. Software with AI capabilities can help by using machine learning (ML) to assess incident descriptions, even for less severe incidents like near misses/close calls, and flagging incidents determined to have a potential for severe injuries and fatalities (PSIF) risk. You can also build in notifications to EHS and company leaders whenever a new PSIF is detected.

If you’re managing multiple sites or struggling with manual processes, incident management software can save time, reduce errors, and improve data accuracy year over year, while also helping you to shift from a reactive to a proactive safety management approach.

Final Thoughts

The annual OSHA recordkeeping cycle is a recurring reminder that safety and compliance go hand in hand. By planning early, coordinating across EHS and HR, and leveraging the right digital tools, organizations can stay compliant — and use their data to make workplaces safer and stronger.

If you’re looking for more information about Recordkeeping, check out our infographic for a refresher on which incidents are reportable or recordable, or download our eBook for FAQs and answers about electronic injury and illness reporting requirements.

Let VelocityEHS Help!

VelocityEHS Incident Management software makes it easy to log, track, and report workplace injuries and illnesses — and to generate and submit OSHA forms in just a few clicks. With built-in dashboards and automation, you’ll save time, ensure compliance, and gain the insights you need to strengthen safety performance.

Our capabilities also include AI PSIF Insights, which identify PSIF risks that may not be obvious, lurking within the details of less serious incidents like near misses and close calls.

In fact, why not see for yourself how we can help? Get in touch today to set up a meeting so you can see our software in action!