OSHA Recordkeeping
How to Automate OSHA 300 Log Reporting With AI
Structured incident data can support an OSHA 300 recordkeeping workflow, but the employer remains responsible for recordability, corrections, posting, submission, and certification. Buyers should test how a product prepares reviewable 301, 300, and 300A records from the same incident evidence.
By Matthew Hart
CEO, Soter
Written for safety managers and EHS leaders responsible for OSHA injury and illness recordkeeping.
What OSHA 300 recordkeeping actually requires
OSHA injury and illness recordkeeping is governed by 29 CFR Part 1904, and it runs on three forms that do three different jobs. The OSHA 300 Log is the running list of recordable cases. The 300A is the annual summary of that list. The 301 is the detailed report behind each case. Everything else, the retention rules, the posting window, the electronic submission, hangs off those three documents.
The obligation includes filling the forms correctly, keeping them long enough, posting the summary on time, and submitting the data if your establishment is in scope. Each of those has a rule with a number attached, and each creates a chance for delay or transcription error in a manual process. Software can be tested on the mechanical parts of the workflow, while the employer remains responsible for recordability, completeness, posting, and certification.
The three forms, side by side
The forms are often treated as one task, but they have different owners, different content, and different deadlines. Keeping them straight is the first requirement for any tool that claims to automate them.
| Form | What it is | What goes on it | Who and when |
|---|---|---|---|
| OSHA 300 | Log of Work-Related Injuries and Illnesses | One line per recordable case, classified by outcome | Maintained through the year, entry within 7 days |
| OSHA 300A | Annual Summary | Yearly totals rolled up from the 300 Log | Certified by a company executive, posted Feb 1 to Apr 30 |
| OSHA 301 | Injury and Illness Incident Report | The detailed record for a single case | Completed within 7 days of learning of the case |
Two deadlines sit on top of this. Under 1904.29(b)(3), a recordable case has to be entered on the 300 Log and the 301 within seven calendar days of learning about it. Under 1904.32, the 300A summary has to be certified by a company executive and posted from February 1 to April 30 of the following year. Separately, severe events covered by the rule require a direct report to OSHA: under 1904.39, a work-related fatality is reported within eight hours, and an in-patient hospitalization, amputation, or loss of an eye within twenty-four hours.
Recording and reporting are separate duties
The two are constantly confused, and the confusion causes real mistakes. Recording is the ongoing paperwork: keeping the 300 Log, the 300A, and the 301 under Part 1904. Reporting is the immediate phone-or-portal notification to OSHA of a severe event under 1904.39. A case can be both, one, or neither, and treating them as the same thing leads to either a missed eight-hour fatality report or an over-notified minor injury.
| Aspect | Recording (Part 1904) | Reporting (1904.39) |
|---|---|---|
| What it is | Logging recordable cases on the 300, 300A, 301 | Notifying OSHA of a severe event |
| Trigger | Any case meeting the 1904.7 criteria | Fatality, or in-patient hospitalization, amputation, loss of eye |
| Timing | Enter within 7 calendar days | 8 hours (fatality) or 24 hours (the others) |
| Who it goes to | Kept on site, summarised and posted | Reported directly to OSHA |
Test whether a recordkeeping product treats these as separate duties. It should draft the recordkeeping forms and flag severe-event reporting deadlines without implying that a log entry completes the direct report.
Where the errors actually happen: the recordability decision
The hard part of the 300 Log is deciding whether a given case belongs on it. The general recording criteria in 1904.7 make a work-related case recordable if it results in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or a significant injury or illness diagnosed by a licensed health care professional. The distinction between medical treatment and first aid, and between restricted work and a normal shift, requires the underlying facts and the rule to remain visible to the reviewer.
Ask the vendor to show the criteria and the reasoning behind each proposed call on screen, before a reviewer confirms it. Three details catch products out. The count of days away or days restricted may be capped at 180 calendar days under 1904.7(b)(3)(vii). First aid, including a non-prescription medication taken at nonprescription strength, does not trigger recording on its own. And under 1904.7(b)(4)(viii), a restriction recommended by a licensed health care professional is recorded as a restricted work case even when the employee performs all routine job functions anyway. The employer's reviewer still confirms the final decision.
How to test the path from an incident to the log
A credible recordkeeping workflow starts from the incident data you already capture. SoterAI captures incidents through conversation and media and structures the information into a record for review. From there, ask the vendor to demonstrate each recordkeeping transfer.
- Test the 301 draft. Compare the detailed report with the captured incident record and note every manual correction.
- Test recordability support. Check whether the 1904.7 criteria and reasoning remain visible for the reviewer to confirm.
- Test outcome classification. Verify death, days away, restriction or transfer, other recordable cases, and day counts.
- Test the 300 Log transfer. Confirm the line, columns, privacy treatment, and seven-day timing against the approved case.
- Test the 300A roll-up. Reconcile the annual totals with the maintained log before review and executive certification.
Measure how much reviewer time and correction remain in the seven-day window. Verify that the annual summary rolls up from the maintained log and that each total can be traced back to the cases behind it.
A recordability call, worked through
Consider a common borderline case. A worker reports lower-back soreness after moving stock. An occupational health nurse, acting as a licensed health care professional, recommends two days of lighter duties and an over-the-counter pain reliever. Is it recordable? Walk the 1904.7 criteria. There is no death, no loss of consciousness, and no diagnosis of a significant injury. The medication, taken at nonprescription strength, falls under first aid, which does not trigger recording on its own. The deciding factor is what the lighter duties cover. Under 1904.7(b)(4)(i), restricted work occurs when the employee is kept from one or more routine job functions or from the full workday, or when a licensed health care professional recommends that they not perform them. If the recommendation reaches a routine job function or the full workday, the case is a recordable restricted work case.
One point catches employers out. Under 1904.7(b)(4)(viii), the case is recorded as restricted work even if the employee does all of their routine job functions anyway, so a worker who ignores the recommendation does not remove the entry. The judgement left to the reviewer is narrower than it looks: whether the recommended duties touch a routine job function or the full workday at all. A product trial can apply the same case more than once and compare the proposed reasoning. The employer's reviewer then confirms, corrects, or rejects the proposal with a documented basis.
Key takeaways
- OSHA recordkeeping runs on three forms under 29 CFR 1904: the 300 Log, the 300A summary, and the 301 report.
- Records are kept five years (1904.33); the 300A is certified by an executive and posted February 1 to April 30 (1904.32).
- The recordability decision is the hard part; any AI assistance should be treated as a draft and confirmed by a person.
- Test whether structured incident capture can support preparation of the 300, 300A, and 301 records within the same review process.
What automation removes, and what it does not
Test automation for repeated transcription, duplicate entry, and timing mistakes. Verify that the product keeps records structured for the full five-year retention required by 1904.33, making them easier to retrieve and update when OSHA requests them.
What it does not remove is accountability. The 300A must be certified by a company executive, and that certification is a statement that a person stands behind the numbers. The recordability of a borderline case is a professional judgement. And whether your establishment must submit data electronically, through the Injury Tracking Application by March 2, depends on establishment size and industry. Establishments with 20 to 249 employees in Appendix A industries submit 300A data. Establishments with 250 or more employees submit 300A data when Part 1904 requires them to keep records. Establishments with 100 or more employees in Appendix B industries also submit 300 and 301 data. Employers with ten or fewer employees at all times during the previous calendar year are partially exempt from routinely keeping these records under 1904.1, though they must still report the most serious events. Use OSHA's current coverage application and confirm State Plan requirements where applicable.
Where SoterAI fits
SoterAI captures incidents through conversation and media and structures the information into a record for review. To evaluate it for OSHA recordkeeping, ask the team to demonstrate whether that record can support a 301 draft, proposed recordability analysis, outcome classification, and 300 and 300A preparation while preserving human review and certification.
Also test retention and retrieval, and whether the log and related forms stay connected through the workflow. Responsible reviewers still check recordability, and a company executive still certifies the 300A.
Sources
- 29 CFR 1904.7: General recording criteriaRecordability criteria, first aid, restricted work, and the 180-day cap.
- 29 CFR 1904.29: FormsForm definitions and the seven-calendar-day entry requirement.
- 29 CFR 1904.32: Annual summaryExecutive certification and the February 1 to April 30 posting window.
- 29 CFR 1904.33: Retention and updatingFive-year retention and OSHA 300 Log update requirements.
- 29 CFR 1904.39: Severe-event reportingEight-hour and 24-hour reporting duties for covered severe events.
- 29 CFR 1904.41: Electronic submissionCurrent establishment-size, industry, form, and March 2 submission rules.
See how a reported incident becomes a structured, auditable record. Read the records management use case.