OSHA 300 log and injury records for contractors

OSHA's injury and illness recordkeeping rule is 29 CFR Part 1904. It tells employers which work-related injuries and illnesses to write down, on which forms, how fast, and how long to keep them. For a contractor these records matter twice: OSHA can ask for them, and owners, general contractors and sureties ask for the safety numbers built from them when they prequalify you. Every rule below was checked against Part 1904 in the eCFR on 7 Nov 2026 and is put in our own words.

Who has to keep the records

  • Small employers. If the company had 10 or fewer employees at all times during the last calendar year, it is partly exempt and does not need to keep the log unless OSHA or the Bureau of Labor Statistics tells it in writing to do so (1904.1). Size is counted across the whole company, not one site.
  • Some industries are partly exempt by classification (1904.2 and its appendix). Construction is not on that list.
  • Everyone covered by the OSH Act, exempt or not, must report the serious events in the next section (1904.39).

The log covers everyone on your payroll, and also workers not on your payroll whom you supervise day to day, such as temporary workers (1904.31).

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Report serious events by phone or online

From 1904.39, in our words:

  • A work-related fatality: report to OSHA within 8 hours.
  • A work-related 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 OSHA's toll-free number, or through the online form on osha.gov.

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Every answer comes with a full explanation.

The three forms

From 1904.29:

  • OSHA 300, Log of Work-Related Injuries and Illnesses: one line per recordable case.
  • OSHA 301, Injury and Illness Incident Report: the details of each case.
  • OSHA 300A, Summary of Work-Related Injuries and Illnesses: the year's totals.

Each recordable case goes on the 300 and the 301 within 7 calendar days of learning about it. Equivalent forms, including computer records, are allowed if they hold the same information. In privacy cases, such as certain sexual assault or mental illness cases, the name is left off the log and kept on a separate confidential list.

What is recordable

From 1904.7, a work-related new case is recordable if it results in any of:

  • death
  • days away from work
  • restricted work or transfer to another job
  • medical treatment beyond first aid
  • loss of consciousness
  • a significant injury or illness diagnosed by a physician or other licensed health care professional

First aid alone does not make a case recordable. Part 1904 defines what counts as first aid, so look it up there rather than guessing. Cases with days away are logged with the number of calendar days away.

The annual summary and how long to keep it

  • At year end (1904.32): review the log, correct it, complete the 300A summary, have a company executive certify it, and post it.
  • Posting: no later than 1 February of the next year, left up until 30 April.
  • Keep the 300 log, the privacy case list, the summary and the 301 forms for 5 years after the end of the year they cover, and update the stored logs if a case changes (1904.33).
  • Sites: keep a separate log for each establishment expected to operate for a year or longer. Short-term sites can share one log (1904.30).

Electronic submission

From 1904.41: establishments with 20 to 249 employees in the industries listed in that section's appendix, which includes construction, submit their 300A information to OSHA electronically each year, and establishments with 250 or more that must keep records do the same. The section sets the due date as 2 March of the year after the year covered. Read 1904.41 for the further forms some larger establishments must send.

Injury rates and the experience mod

Prequalification forms ask for rates, not raw counts, so that a big contractor and a small one can be compared. A rate divides the number of cases by the hours worked and scales it to a fixed number of hours. The fixed base and the method are given in OSHA's 300A instructions and by the Bureau of Labor Statistics, not in Part 1904, so use the form's own instructions when you fill one in.

A worked comparison, using a base of 1,000,000 hours chosen for this example only (it is not the base the forms use):

  • Contractor A: 4 recordable cases in 380,000 hours: 4 / 380,000 x 1,000,000 = 10.5 per million hours
  • Contractor B: 3 cases in 190,000 hours: 3 / 190,000 x 1,000,000 = 15.8 per million hours

Check: 10.5 x 0.38 = 3.99, about 4; 15.8 x 0.19 = 3.00. B has fewer cases but the worse rate, because it worked half the hours.

The experience modification rate is a different number. It is a workers' compensation insurance factor based on the company's claims history against what is expected for its payroll and class codes, with 1.0 as average. It changes the premium. See general liability vs builder's risk vs workers' comp for a worked premium.

Common mix-ups

  • Recording only lost-time cases. Restricted work, medical treatment beyond first aid and the other criteria count too.
  • Thinking small companies report nothing. The 8-hour and 24-hour reports apply to everyone covered.
  • Posting the log. It is the 300A summary that is posted, 1 February to 30 April.
  • Mixing the rate with the mod. One comes from OSHA records, the other from insurance claims.

On the NASCLA exam

The bulletin lists subject areas, not topics. We place jobsite safety under General Requirements, 25 of the 115 scored questions. The listed OSHA reference is 29 CFR 1926, the construction standards; Part 1904 is a separate part, so do not expect to find these recordkeeping rules in your 1926 book. See NASCLA OSHA topics for the 1926 values.

Practice it

Read bonding capacity and surety prequalification for where these numbers end up, and NASCLA OSHA topics for the construction standards.

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