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Are You Exempt From OSHA's Recordkeeping Requirements?

By Susen Trail | 06/11/2022

Some industries are exempt or partially exempt from complying with 1904, the Occupational Safety and Health Administration, OSHA's recordkeeping standard.  The exempt industries are considered to be low hazard and are identified by their North American Industry Classification System (NAICS), codes.  Industries that are covered by this recordkeeping rule, can be found here.

Businesses that are covered by 1904 but have 10 or fewer employees are exempt from recordkeeping requirements.  We at Simple Safety Coach recommend that all businesses keep track of, and investigate, employee injuries or illnesses to identify trends and hazardous work areas.  Such as an entry that gets icy every winter may have a few injuries year after year.

However, any business with an exempt NAICS code are required to comply with 1904 when they are 'asked' in writing to do so by OSHA, the Bureau of Labor Statistics (BLS), or a state agency operating under the authority of OSHA or the BLS.  Be sure to find out how long the request will stand; it may be for one year or a few years.

All employers with a workplace incident that results in a fatality, in-patient hospitalization, amputation, or loss of an eye (see § 1904.39) are required to report to OSHA.  Fatalities and 3 or more employees in the hospital from one incident must be reported within 8 hours.

When you are covered by 1904 you are required to record the illnesses that occur between January and the end of December on a 300 log, a 301 Incident Report, and a 301 form.  These documents are required to be kept for 5 years.  You may think of the 300 log as a checkbook, each recordable is entered in one line.  OSHA provides clear instructions to help you identify recordable cases in 1904.7, General recording criteria.

The 300A is the Annual Report that must be sent to OSHA.  It is similar to taxes where you group 'expenses' and report the number of recordables by severity, and type.  Such as 5 lost workday cases 3 of which were injuries and 1 was hearing loss and the other was a respiratory condition.


  • Recordable Injuries or Illnesses shall be (OSHA speak for required by law) entered into the 300 log within 7 days of the employer's knowledge of the case. If Jack goes to the doctor on Saturday for a work related injury or illness and tells you on Monday you have 7 calendar days to get the data into the 301 Form and 300 log.
  • Form 300-A is the Summary of the number and type of Work-Related Injuries and Illnesses. It shall be
    • Posted where all employees can see it from February 1st to April 30th. Usual locations are
      • by the time clock
      • in the lunch room
      • by the main entry
    • Received by OSHA on, or before, February 1st

Unfortunately, some injuries or illnesses can have long lasting effects and an employee may come back years later for compensation of medical costs.  It is wise to retain the Incident Reports for 30 or more years.

Whether you are new to managing safety in your workplace or are an experienced and busy Safety Professional, Simple Safety Coach is designed to increase the efficiency and accuracy of all of your recordkeeping documents!

Schedule a Demo of Simple Safety Coach today.  We also offer free trials with full support to see for yourself how fast it is to onboard Simple Safety Coach and escape the paperwork sinkhole of time.

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