OSHA 300, 300A and 301 Forms: A Construction Contractor's Guide to Injury & Illness Recordkeeping

Key takeaways:

• Any construction company with more than 10 employees at any time last year has to keep OSHA injury and illness records. Every employer, whatever its size, has to report a fatality to OSHA within 8 hours and an in-patient hospitalization, amputation, or loss of an eye within 24 hours.
• A recordable case goes on the OSHA 300 Log and a 301 Incident Report within 7 calendar days. After the year ends, a company executive certifies the 300A summary, which stays posted from February 1 to April 30. The records are kept for five years.
• For 2026 data, post the 300A by Monday, February 1, 2027. Covered establishments submit to OSHA's Injury Tracking Application by Tuesday, March 2, 2027. In construction, that means every establishment with 20 or more employees, and foundation, structure, and building exterior contractors with 100 or more also submit their 300 and 301 data.

OSHA's recordkeeping rule asks three things of a construction company. Every recordable injury and illness goes on the Form 300 log within seven calendar days. Each one gets a detailed Form 301 incident report. At year end, the totals go on Form 300A, which a company executive certifies and which stays posted from February 1 to April 30. The next cycle is close: the 2026 log closes December 31, the 300A goes up February 1, 2027, and covered establishments submit their data electronically by March 2, 2027.

OSHA's Recordkeeping Training Presentations page includes a tutorial on completing the forms, which takes about 30 minutes and covers who keeps records, how OSHA decides work-relatedness, the three forms, the 300A, and electronic submission. This guide covers the same rules for construction: what's recordable, how to fill out each form, who records which workers on a multi-employer site, the deadlines, and where incident information usually breaks down between the first report and the TRIR a GC or owner asks for.

The Three Forms at a Glance

An insurance form can stand in for the 301 if it has the same information, is as readable, and is completed using the same instructions. Many employers use one, or add OSHA's missing fields to it.

Who Has to Keep OSHA Records

The 10-employee rule. A company that had 10 or fewer employees at all times during the last calendar year doesn't have to keep OSHA injury and illness records, unless OSHA or the Bureau of Labor Statistics asks it in writing. Above that, construction companies keep records, because no construction industry is on OSHA's list of partially exempt industries. The severe-injury reporting rule applies to every employer either way.

Whose injuries go on your log. You record the injuries and illnesses of everyone on your payroll: labor, salaried, part-time, seasonal, and migrant workers. You also record workers who aren't on your payroll if you supervise them day to day, which covers most temporary and leased workers.

On a multi-employer site, the rule follows supervision. If a subcontractor supervises its own crew day to day, the subcontractor records that crew's injuries. If you supervise a contractor's employees day to day, you record them. Self-employed workers aren't covered, and neither are the owners of a sole proprietorship or partners in a partnership.

Which log. You need a separate OSHA 300 Log for each establishment expected to operate for a year or longer, so a multi-year project gets its own log. Jobsites that will last less than a year can share one log, or go on a log for a company division or region. Logs can be kept at headquarters or another central location, as long as information about each case gets there within 7 calendar days and you can produce the records on time when an employee or a government representative asks.

Is It Recordable? The Decision Tree

Under 29 CFR 1904.4, a case is recordable when the answer is yes to three questions, in order.

1. Is it work-related? OSHA presumes an injury or illness is work-related if an event or exposure in the work environment caused or contributed to it, or significantly aggravated a pre-existing condition. There are nine exceptions in 1904.5(b)(2). The ones that come up on jobsites:

• An injury from eating or drinking for personal consumption, such as choking on lunch.
• An injury from personal grooming.
• A cold or the flu.
• A motor vehicle accident in a company parking lot or access road while the employee is commuting.
• Symptoms that show up at work but come solely from something outside work.

2. Is it a new case? It's new if the employee hasn't had a recorded injury or illness of the same type to the same part of the body. It's also new if they had one but recovered completely, and something at work brought the symptoms back.

3. Does it meet a recording criterion? The general criteria in 1904.7 are death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, and loss of consciousness. A significant injury or illness diagnosed by a physician or other licensed health care professional is also recordable, even with none of those. That covers cancer, a chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum. Sections 1904.8 through 1904.11 add specific rules for contaminated needlesticks and sharps, medical removal under an OSHA standard, hearing loss, and tuberculosis.

Most borderline construction cases come down to two definitions:

• First aid is a complete list in 1904.7(b)(5)(ii). Treatments on the list:
  • Non-prescription medicine at non-prescription strength.
  • A tetanus shot.
  • Cleaning or soaking a wound.
  • Bandages, butterfly bandages, or Steri-Strips.
  • Hot or cold therapy.
  • Non-rigid support such as an elastic wrap.
  • Temporary immobilization while transporting the injured worker.
  • Draining a blister.
  • Eye patches, and flushing a foreign body from the eye with only water or a cotton swab.
  • Removing splinters by simple means.
  • Finger guards.
  • Massage.
  • Drinking fluids for heat stress.
• Treatment that isn't on the list is medical treatment. Visits to a physician or other licensed health care professional solely for observation or counseling don't count as medical treatment, and neither do diagnostic procedures such as x-rays and blood tests.
• Restricted work means the employee can't do one or more of the routine functions of their job, meaning work they regularly do at least once a week, or can't work the full workday they'd otherwise have been scheduled to work. That applies whether the employer keeps them from it or a physician or other licensed health care professional recommends it.

Filling Out Forms 300 and 301

Seven calendar days. Each recordable case goes on the 300 Log and a 301 Incident Report within seven calendar days of receiving the information that a recordable injury or illness happened. Calendar days, not workdays.

Counting days away and restricted days. Count calendar days, weekends and holidays included, if the employee couldn't have worked them because of the injury. You can stop counting at 180 days, and entering 180 is enough.

Privacy cases. For some cases, you write "privacy case" in place of the employee's name and keep a separate, confidential list of names and case numbers. These are:

• Injuries to an intimate body part or the reproductive system.
• Injuries from a sexual assault.
• Mental illnesses.
• HIV, hepatitis, or tuberculosis.
• Needlesticks and cuts from sharps contaminated with another person's blood or other potentially infectious material.
• Other illnesses, when the employee asks.

Keep the log current. When a case changes, update the entry. A first-aid case that turns into stitches becomes recordable. A recorded case can add days away, or a restricted case can become a days-away case. The log has to stay current for the full five-year retention period.

The Annual Summary: Form 300A

At the end of each calendar year, you have to:

1. Review the log. Check the 300 Log as closely as needed to make sure it's complete and correct.
2. Create the summary. Total each column, entering zeros if there were no cases. Add the company and establishment details, the annual average number of employees, and the total hours worked.
3. Certify it. A company executive has to certify that they examined the log and reasonably believe the summary is correct and complete. That means an owner of a sole proprietorship or partnership, an officer of the corporation, the highest-ranking company official working at the establishment, or that person's immediate supervisor.
4. Post it. Put it up no later than February 1 where employee notices are usually posted, and keep it up, unaltered and uncovered, until April 30.

The 300A gets posted even in a year with no recordable cases.

Severe Injuries: The 8-Hour and 24-Hour Clocks

Severe-injury reporting under 1904.39 runs on its own clock, and it applies to every employer, including those exempt from keeping records.

• Fatality: report to OSHA within 8 hours of the death.
• In-patient hospitalization, amputation, or loss of an eye: report within 24 hours.

Report by phone or in person to the nearest OSHA Area Office, by phone to 1-800-321-OSHA (1-800-321-6742), or online through OSHA's reporting application. You only have to report a death that occurs within 30 days of the work-related incident, and a hospitalization, amputation, or loss of an eye that occurs within 24 hours of it. If you keep OSHA records, the case goes on the log too.

Electronic Submission and the 2027 Dates

Some establishments also have to submit their recordkeeping data electronically through OSHA's Injury Tracking Application (ITA). For construction:

• 20 to 249 employees: construction is on the designated industry list (Appendix A to Subpart E), so every construction establishment of this size submits its 300A information.
• 250 or more employees: every establishment that keeps records submits its 300A information.
• 100 or more employees, in foundation, structure, and building exterior contracting (NAICS 2381): these establishments also submit their 300 and 301 case information. NAICS 2381 is the only construction industry on the Appendix B list.

The thresholds count employees at the establishment at any time during the previous calendar year.

The March 2 deadline is set in 29 CFR 1904.41(c). OSHA accepts late submissions through December 31, but March 2 is the deadline.

Employee Rights, Access, and Retention

Reporting procedure. You have to set up a reasonable procedure for employees to report work-related injuries and illnesses promptly and accurately, and tell every employee about it. A procedure that would deter or discourage a reasonable employee from reporting isn't reasonable.

Rights. Employees have to be told that they have the right to report work-related injuries and illnesses, and that employers can't discharge or discriminate against them for reporting.

Access. When an employee, a former employee, or their representative asks for the 300 Log, they get a copy by the end of the next business day, with names left on except for privacy cases. An employee gets their own 301 by the end of the next business day as well.

Retention. Keep the 300 Log, the privacy case list, the 300A, and the 301s for five years after the end of the year they cover. Update the stored 300 Logs if you learn about new recordable cases or changes during that time.

From First Report to TRIR

Every recordable case follows the same path. A worker reports an injury, which is the first notice of injury, or what insurers call the first notice of loss. Someone investigates. Someone decides whether it's recordable. The case goes on the 300 and the 301 within seven days. It's counted on the 300A after year end. Then it shows up in the two numbers GCs, owners, and insurers ask for:

TRIR = number of recordable cases × 200,000 ÷ total hours worked by all employees

DART = number of cases with days away, restricted work, or job transfer × 200,000 ÷ total hours worked

The 200,000 stands for 100 full-time workers working 40 hours a week, 50 weeks a year. Here's where construction stood in the Bureau of Labor Statistics' 2024 data, the latest available:

On paper, the path breaks at every handoff:

• The first report is a phone call nobody wrote down.
• The investigation lives in someone's email.
• Recordability gets decided from memory when the log is due.
• The 300 is a spreadsheet at headquarters that the jobsite updates when someone remembers, so the seven-day clock runs out quietly.
• At year end, the hours worked come from payroll while the cases come from the field, and nobody reconciles them.

The TRIR that results goes into prequalification packages, where GCs and owners compare it against everyone else's.

How SafetyClerk Helps

Recordkeeping is easier when every incident starts as a record instead of a conversation.

On SafetyClerk projects, incidents are reported, tracked, and resolved in the same system as observations and near misses. When a worker checks out, they sign an incident waiver confirming they weren't injured on the job, which leaves a daily record of each worker leaving the site uninjured. Check-in and check-out log the hours for each worker, the denominator every rate depends on. SafetyScore uses incidents, near misses, and issue resolution as inputs, alongside training, certifications, and daily activity.

The rebuilt Incident module takes a case from first report through investigation and recordability, fills in the 300 and the 301 within the seven-day window, totals the year for the 300A, and produces the data for the Injury Tracking Application. If time tracking is also paired with it, TRIR and DART are also automatically calculated every day and shown to you.

Frequently Asked Questions

Does my construction company have to keep an OSHA 300 log? Yes, if it had more than 10 employees at any time during the last calendar year. No construction industry is on OSHA's partially exempt list. Smaller companies don't keep the log unless OSHA or BLS asks in writing, but every employer has to report severe injuries.

What's the difference between OSHA Forms 300, 300A, and 301? The 300 is the log, with one line per recordable case. The 301 is the detailed incident report for each case. The 300A is the annual summary of the log, which a company executive certifies and which stays posted from February 1 to April 30.

How long do I have to record an injury? Seven calendar days from receiving the information that a recordable injury or illness occurred, on both the 300 and the 301.

When is the OSHA 300A due in 2027? Post the certified 2026 summary by February 1, 2027 and keep it up through April 30. Covered establishments submit their 2026 data through OSHA's Injury Tracking Application by March 2, 2027.

Is an injury that needs stitches recordable? Yes. Stitches and staples are medical treatment. A cut closed with butterfly bandages or Steri-Strips is first aid and isn't recordable on that basis.

Who records an injury to a subcontractor's employee? The employer that supervises the worker day to day. On most jobsites that's the subcontractor. If a GC supervises a contractor's employees day to day, the GC records the injury.

When do I have to report an injury to OSHA directly? A fatality within 8 hours, and an in-patient hospitalization, amputation, or loss of an eye within 24 hours. That applies to every employer, whether or not it keeps records.

How do you calculate TRIR and DART? Multiply the number of cases by 200,000 and divide by the total hours worked. TRIR counts every recordable case, and DART counts only cases with days away, restricted work, or job transfer. In 2024, construction averaged 2.2 and 1.3.

This guide provides general information about OSHA's recordkeeping rule and isn't legal advice. State plans can have their own requirements. Confirm questions about a specific case with OSHA or qualified counsel.

Start every incident as a record, and the 300A takes care of itself.

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