Three forms, one set of facts
It is January 28 at a 300-employee manufacturer with two plants. The operations manager, who also owns injury reporting, has three things on her desk: a printed OSHA 300 Log for the larger plant, a draft 300A, and a folder of 301 incident reports.
A plant manager asks which of these goes on the break-room wall. The controller asks whether the signer has to be the plant manager or someone above. An HR colleague asks whether the 301s are also sent to OSHA, and whether posting the 300A counts as the electronic submission everyone mentions in March.
She knows the three forms are related. She is not sure where one stops and the next begins, or which duty belongs to which form.
By the end of this guide you will be able to say what each form records, who sees it, which clock governs it, and which deeper guide covers the details.
Reference material with citations, not legal advice. You decide recordability and compensability, and you file.
OSHA 300 vs 300A vs 301: what each form is for
The three forms form one chain, and each draws on the one before it. The 301 Incident Report holds the details of a single case. The 300 Log lists each recordable case for an establishment, one line per case. The 300A summarizes the year's log into totals.
Because each form reuses facts from the one before, a fact entered correctly once should not need to be re-typed twice more. Most errors in the record set come from re-keying: a date changed on the log but not on the 301, or a total on the 300A that no longer matches the log.
The recordkeeping duties sit in 29 CFR Part 1904 (checked 2026). An employer must enter each recordable case on the OSHA 300 Log and the 301 Incident Report, both kept in the employer's own records, within seven calendar days of receiving information that a recordable injury or illness has occurred (29 CFR 1904.29, checked 2026).
The clock runs from information that a recordable case occurred. Recordability is your decision, so the clock cannot start until you have enough information to make it.
The table below sets out the clocks that attach to this record set. Each row gives the trigger, the unit, the recipient and the source.
| Duty | Trigger | Unit | Recipient | Source |
|---|---|---|---|---|
| Enter the case on the 301 and the 300 Log | Receiving information that a recordable injury or illness has occurred | 7 calendar days | Employer's own records | 1904.29 (checked 2026) |
| Post the 300A summary | The end of the year the records cover | No later than February 1, posted through April 30 | Posted at the establishment for employees | 1904.32 (NCDOL reproduction, February 2026) |
| Submit data electronically | The end of the covered year | March 2 of the following year | OSHA, through the ITA | 1904.41 (ITA user guide, checked 2026) |
Each form has its own guide. For the incident record, see OSHA Form 301. For the line-by-line log, see the OSHA 300 Log guide. For the yearly roll-up, see the OSHA 300A annual summary. The broader duty set is in the OSHA recordkeeping requirements overview.
One log per establishment
A separate 300 Log must be kept for each establishment expected to operate for one year or longer (29 CFR 1904.30, checked 2026). A two-plant employer therefore keeps two logs and produces two 300As. For the mechanics of filling in each line, see how to fill out the OSHA 300 Log.
What the rule says, and what you decide
The log is only as sound as the decisions behind it. The rules supply tests and citations. You apply them to the facts and decide.
Recordability and counting days
Whether an injury is work-related, whether it meets a recording criterion, and whether treatment counts as medical treatment or first aid are all your calls. OSHA's 1904.7 text sets the criteria. The rule says you may "cap" the total days away at 180 calendar days on the log. It also says that a case starting in one year and causing days away in the next is recorded only once, in the year it occurred (checked 2026).
You decide when the cap applies and which year the case belongs to. The rule gives the limit and the counting principle. It does not make the call for you.
Privacy cases on the 300 Log
Some cases are privacy concern cases, and for those the employee's name is kept off the 300 Log. In practice, the entry reads "privacy case" where the name would go. Section 1904.29(b) sets out the list, and it is closed:
"this is a complete list of all injuries and illnesses considered privacy concern cases for part 1904 purposes" — 29 CFR 1904.29(b)(7) (checked 2026)
Because the list is complete, you cannot add a case to it because it feels sensitive. You also cannot ignore a case that fits it. You decide whether a given case falls on the list, using the regulation text.
The 301 carries more case-level detail than the log line does, which is why the privacy question matters for what you hand to whom. The deeper guide on the incident form, OSHA Form 301, covers what belongs on it. The way a first report can double as the 301 is covered in first report of injury as OSHA 301.
Posting is not submitting
Two duties get confused every winter: posting the 300A and submitting data electronically. They are separate, with different triggers, recipients and sources.
Posting and certification
An employer must post the 300A summary no later than February 1 of the year following the year covered by the records, and keep it posted until April 30 (29 CFR 1904.32, NCDOL reproducing the rule, February 2026).
A company executive certifies the 300A. Under 1904.32 (checked 2026), that person is one of four:
- an owner, in a sole proprietorship or partnership only;
- an officer of the corporation;
- the highest-ranking company official working at the establishment;
- that official's immediate supervisor.
So the answer to the January 28 question about who signs is a role, not a name. Posting detail is in the 300A posting requirements guide.
Electronic submission
Does posting the 300A satisfy electronic submission? No. Posting puts the summary in front of employees at the establishment. Submission delivers data to OSHA through the Injury Tracking Application (ITA).
Covered establishments must submit by March 2 of the year after the covered year. For calendar-year 2025 data, the date is March 2, 2026 (ITA user guide, checked 2026).
Coverage depends on size and industry, under 29 CFR 1904.41 (OSHA interpretation, 2024-04-16):
- Establishments with 20–249 employees in designated higher-hazard industries (Subpart E, Appendix A) must submit 300A data.
- Establishments with 100 or more employees in Appendix B industries must also submit 300 and 301 data.
The industry lists are in the regulation appendices. Confirm your industry classification with OSHA rather than relying on a summary.
A reader searching for which 301 privacy fields are not submitted to ITA needs the current field-level answer, and that belongs to OSHA. The ITA user guide describes the data collected. Check it before each submission season, because the guide can change from year to year. Do not rely on a blog summary for which fields go in. The ITA guide covers the channel in more depth.
OSHA also treats the database as an enforcement tool. Its 2024 guidance tells compliance officers to check the ITA database during all inspections for employers that were required to submit but did not. In March 2026, OSHA's ITA Non-Responder Enforcement Program memo had area offices match open inspections against establishments that may not have submitted calendar-year 2025 300A data.
You decide whether your establishment is covered, and you submit. Nothing in ClaimsIntake submits to OSHA for you.
Keeping the record defensible
A complete record set can still fail if you cannot show what you knew, when you knew it, and what rule you applied.
Retention and access
OSHA 300 Logs, 300A summaries and 301 Incident Reports must be kept for five years following the end of the calendar year the records cover (29 CFR 1904.33, checked 2026). Retention stays your responsibility. See how long to keep OSHA 300 logs.
Access clocks are short:
- When an employee, former employee or employee representative asks for the 300 Log, you must give the requester a copy by the end of the next business day, and the first copy is free (1904.35, checked 2026).
- When an authorized government representative asks for Part 1904 records, you must provide copies within four business hours (1904.40, checked 2026).
An owner who can only find the log by phoning a colleague on leave will struggle with a four-business-hour clock.
Temporary workers and multiple sites
For temporary, leased or contract workers, OSHA's day-to-day supervision test applies. Employers must record the recordable injuries and illnesses of workers they supervise on a day-to-day basis, even if those workers are not on the payroll (2018 interpretation). Which employer records a given worker is a decision you document.
Recording is not reporting
Recording is not the same as reporting. A work-related fatality must be reported to OSHA within 8 hours, and an in-patient hospitalization, amputation or loss of an eye within 24 hours (29 CFR 1904.39, checked 2026). These reports go to OSHA by phone, hotline or online, and they are separate from the log. States add their own clocks. The workplace injury reporting requirements overview maps the first-report side.
Where tools fit
Most employers in this size band run on a spreadsheet and email. That works, and many people have built theirs carefully. It holds dates well. What it does not hold is the rule that produced a date, or a record of which rule version was in force when a clock started.
The state and federal channels, OSHA's ITA included, are free and authoritative. They handle one filing at a time, and the record behind each filing is yours to keep.
For employers who want the 300, 300A and 301 chain handled in one file, the OSHA 300, 300A and 301 Log Workbook computes a log from decided cases and rolls it into the 300A totals. You still decide recordability and enter your decisions. A 20–100-employee single-state employer is usually better served by the store workbooks than by anything subscription-based.
The ClaimsIntake app is not live. It is being built so that a single injury report will feed the pre-filled 301, a 300 log made from decided cases only, and a 300A roll-up with certification, posting and ITA reminders. It will not decide recordability or submit anything to OSHA. Each rule in its table will carry an agency citation and a "last verified" date. To follow progress, join the waitlist.
Your next step
Before the next January, check five things:
- Confirm you have one log per establishment.
- Name the certifying executive for each 300A, using the four categories in 1904.32.
- Calendar February 1, March 2 and April 30 as three separate dates, since they involve three different recipients and duties.
- Confirm with OSHA whether each establishment is covered by 1904.41.
- Check the ITA user guide for the current field-level requirements before you submit.
Then use the OSHA 300 vs 300A vs 301 chain as a checklist: for any date on your 300A, you should be able to trace it back to the log line and the 301 behind it.
Reference material with citations, not legal advice. You decide recordability and compensability, and you file.
For updates as the app takes shape, add your email to the waitlist.
