Forms 300, 300A, and 301 — who must keep records, what gets recorded, when to post, when to submit, and how to report severe injuries immediately. Everything PSM-covered facilities need to know.
OSHA's recordkeeping standard (29 CFR Part 1904) is separate from the PSM standard (29 CFR 1910.119), but PSM-covered facilities must comply with both. Part 1904 requires employers to record work-related injuries and illnesses — and those records become critical evidence during PSM incident investigations and OSHA inspections.
When OSHA inspects a PSM-covered facility after a process safety incident, the 300 Log is one of the first documents requested. Incomplete or inaccurate records — particularly failure to record a near-miss as a near-miss or recordable — can compound enforcement liability. Keep records accurate and current.
Most employers with 10 or more employees must maintain OSHA injury and illness records. Certain low-hazard industries are partially exempt (retail, services, finance, real estate). PSM-covered facilities are never exempt — refineries, chemical plants, and similar operations are always covered regardless of size.
Each form has a distinct purpose, timeline, and retention requirement. Together they create a complete record of workplace injuries and illnesses at your establishment.
The running log where every recordable case is entered throughout the year. One entry per recordable case, recorded within 7 calendar days of learning about the injury or illness.
Annual summary totaling all recordable cases from the 300 Log for the prior calendar year. Must be certified by a company executive and posted in a visible workplace location.
Detailed incident report for each recordable case. Captures full details about the injury, the employee, the event, and the medical treatment received. Must be completed within 7 calendar days.
A case is recordable if it is work-related, is a new case, and meets at least one of the general recording criteria below. All criteria must be evaluated — if any apply, the case goes on the 300 Log.
Any work-related fatality must be recorded, regardless of the time between injury and death. Also triggers an 8-hour phone notification to OSHA.
Any case resulting in days away from work beyond the day of the injury or onset of illness — even one day away triggers recordability.
Restriction from performing routine job functions, or transfer to another job for any part of a day beyond the day of injury or illness.
Treatment by a healthcare professional beyond first aid. First aid includes OTC medications, bandaging, cleaning wounds, tetanus shots, and similar minor care.
Any work-related loss of consciousness, regardless of duration and regardless of whether any other criteria apply.
Any cancer, chronic irreversible disease, fractured or cracked bone, or punctured eardrum diagnosed by a healthcare professional.
All work-related needlestick injuries and cuts from sharp objects contaminated with another person's blood or other potentially infectious material.
Medical removal under OSHA's standards, or a standard threshold shift in hearing in one or both ears (hearing loss standard).
First aid is a defined list in Part 1904.7(a). If treatment goes beyond that list, it is recordable. Going to a doctor does not automatically make a case recordable — what matters is what treatment was provided, not where. Conversely, treatment at an on-site nurse that exceeds first aid is still recordable.
Deadlines under Part 1904 are fixed and non-negotiable. Missing them is itself a citable violation. Build these dates into your EHS calendar for every year.
OSHA's electronic recordkeeping rule requires certain establishments to submit injury and illness data through the online ITA portal at injurytracking.osha.gov. Requirements are based on establishment size and industry.
Establishments with 250 or more employees that are already required to keep Part 1904 records must electronically submit their Form 300A data annually by March 2.
Establishments with 20–249 employees in designated high-hazard industries — including petroleum refining (NAICS 324110) and chemical manufacturing (NAICS 325) — must also submit Form 300A data annually.
OSHA's 2023 final rule expanded requirements for establishments with 100+ employees in high-hazard industries to also submit Form 300 Log and Form 301 data — not just the 300A summary.
Separate from recordkeeping, OSHA requires immediate telephone notification for the most serious work-related events. These are not optional and not substituted by electronic submission. You must call.
Report any work-related death within 8 hours of learning about it. The clock starts when the employer (or supervisor) becomes aware — not when it occurred.
Report any work-related in-patient hospitalization of one or more employees within 24 hours. ER visits alone — without admission — do not trigger this requirement.
Any work-related amputation or loss of an eye must be reported within 24 hours, regardless of whether hospitalization occurs. "Amputation" includes partial amputations.
Option 1: Call the OSHA 24-hour hotline: 1-800-321-OSHA (6742)
Option 2: Call your nearest OSHA Area Office during business hours
Option 3: Use the online reporting form at osha.gov/severeinjuryreport
Reports must include: establishment name, location, time of incident, number of employees affected, a brief description of the incident, and contact information for the employer.
Select your state to find your OSHA Regional Office contact information. For the nearest Area Office (which handles local inspections and complaints), visit osha.gov/contactus/bystate.
Select your state to see your regional office contact details and whether your state operates its own OSHA-approved State Plan.