The Log Review on January 22
A safety manager at a 300-person distribution business opens last year's OSHA 300 Log at 8:15 a.m. on January 22. The executive who will sign the annual summary has asked one question: does everything on the log agree with itself? The manager has three sites, two people who entered cases, and a spreadsheet with a few hand-edited cells.
Nobody doubts that cases were recorded. The doubt is smaller and more practical. Do the case numbers run in order? Do the day counts match the totals? Does the summary add up to the log?
An internal check of this kind does not ask whether a case should have been recorded. It asks whether the record you already have is complete, consistent and traceable to the rule. By the end of this article you will be able to run that check line by line, with each test tied to its citation, and know what to do when a line fails.
Reference material with citations, not legal advice. You decide recordability and compensability, and you file.
What an OSHA Recordkeeping Audit Checklist Tests
An OSHA recordkeeping audit checklist is a consistency test. It starts from the decisions already made and checks that the paper reflects them.
It does not replace those decisions. Whether an injury is work-related, whether treatment went beyond first aid, and whether work was restricted are determinations the employer makes under Part 1904. The rule text and its citation can sit beside the decision, but you make it. If a check below makes you doubt an earlier decision, re-read the cited text and decide again. This checklist will not hand you the answer.
Three ground rules keep the exercise clean:
- Audit one establishment at a time. A separate OSHA 300 Log must be kept for each establishment expected to operate for one year or longer (29 CFR 1904.30(a), eCFR current October 15, 2026). Multi-site employers should read how multiple locations affect the 300 log first.
- Audit the closed calendar year. Compare the log against the 301s and the summary for that year only.
- Keep a findings list. Record what you checked, what failed, what you changed, who changed it and on what date.
Ten Checks, Each Tied to Its Source
Completeness and timing
1. Every recordable case has a log entry and a 301. An employer must enter each recordable injury or illness on the OSHA 300 Log and the 301 Incident Report within seven calendar days of receiving information that a recordable case has occurred (29 CFR 1904.29(b)(3)). The recipient is the establishment's own record. Test it by listing the cases from your incident file and matching each to a log line and a 301. Then compare the entry date with the date the employer learned of the case. If many entries run past seven days, find out why.
2. Case numbers are continuous and unique. This one is good practice rather than a rule we can quote: each case should have a unique number that matches between the log and the 301. Look for gaps, duplicates and numbers reused after a deletion. A gap is not an error by itself. A case may have been entered and later removed, but you should be able to say why. If you have privacy cases, 1904.29(b)(6) requires a separate, confidential list of their case numbers and employee names, so check that list against the log too.
3. No case appears twice. A case that starts in one year and causes days away in the next calendar year is recorded only once, in the year it occurred (29 CFR 1904.7(b)(3)(ix)). The source puts it plainly: "No, you only record the injury or illness once." Search the current year's log for cases that began in the prior year.
Classification and day counts
4. Each case carries one classification. A single case should be checked into one outcome column, not two. Section 1904.7 writes its paragraphs in that order: (b)(4) uses the job transfer or restriction box when a case "does not involve death or days away from work," and (b)(5) uses the medical-treatment box only when there was no death, days away, restriction or transfer. Check the form instructions for how to select the outcome column. If a case's outcome changed during the year, the entry should show the final outcome you decided on.
5. Day counts are consistent and capped correctly. Employers may cap the count of days away from work or days of restriction at 180 calendar days on the OSHA 300 Log (29 CFR 1904.7(b)(3)(vii)). Check that no entry exceeds the cap. Check that the days-away and restricted-days columns add to the totals row. The counting rule is in the text: you begin counting "on the day after the injury occurred or the illness began" (1904.7(b)(3)(i)), and you count calendar days "regardless of whether or not the employee was scheduled to work" (1904.7(b)(3)(iv)). Our article on counting days away from work walks through the method. Use one method for every case.
Privacy and the summary
6. Privacy cases follow the exclusive list. Section 1904.29(b)(7) sets out the privacy concern cases, and the employee's name is left off the log only for those. The text says:
"this is a complete list of all injuries and illnesses considered privacy concern cases for part 1904 purposes" — 29 CFR 1904.29(b)(8) (eCFR current October 15, 2026)
Test every "privacy case" entry against that list. A name withheld for any other reason is a finding. Keep the separate confidential list of names with the log so the employer can identify the cases.
7. Log totals reconcile to the 300A. The annual summary is built from the log. Add each total column from the log and compare it with the matching line on the 300A. Check the establishment's employee count and hours as well. Any difference needs a written explanation. How a log feeds the summary is covered in how to fill out the OSHA 300 log.
8. Certification and posting are correct. A company executive certifies the 300A, and that person must be one of four categories: an owner (sole proprietorship or partnership only), an officer of the corporation, the highest-ranking company official working at the establishment, or that official's immediate supervisor (29 CFR 1904.32(b)(4)). The summary must be posted no later than February 1 of the year following the year covered by the records, and it stays posted until April 30 (29 CFR 1904.32(b)(6)). Check that the signer fits one of the four categories and that you kept proof of the posting dates.
Retention and access
9. Retention is intact. 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(a)). Open the folder for each of the last five years and confirm all three record types are present. The employer remains responsible for retention wherever the files live. See how long to keep OSHA 300 logs.
10. You can meet the access clocks. When an employee, former employee or employee representative asks for the 300 Log, the employer must provide a copy by the end of the next business day, and may not charge for the first copy (29 CFR 1904.35(b)(2)(iii), (vi)). When an authorized government representative asks for Part 1904 records, the employer must provide copies within four business hours (29 CFR 1904.40(a)). Test it: can the person who holds the logs produce a clean copy for any site within those windows?
When a Check Fails: Correcting the Log
Most findings are small: a transposed total, a missing 301, a privacy entry that does not fit the list. The aim is to fix the record without destroying the history of what it said.
A practical approach to how to correct an OSHA 300 log:
- Mark, don't erase. This is internal practice, not an OSHA requirement: strike through or annotate the old value and write the new one, with the date and the person making the change. If your log is a spreadsheet, keep a dated copy of the version before the change.
- Write the reason down. "Total corrected after recount of restricted days" is enough.
- Re-decide only through the rule. If a finding means a recordability decision may have been wrong, re-read the relevant section of Part 1904 and decide. The correction follows from your decision, not from the checklist.
- Carry the change to the 300A. If a log total changes before the 300A is certified, the summary changes, and the executive who certifies it should see the update.
For stored records, 29 CFR 1904.33(b)(1) says that during the five-year storage period "you must update your stored OSHA 300 Logs to include newly discovered recordable injuries or illnesses and to show any changes that have occurred in the classification of previously recorded injuries and illnesses." If a case's description or outcome changes, you "remove or line out the original entry and enter the new information." Under (b)(2) and (b)(3), you are not required to update the annual summary or the 301s, though you may. If the 300A for that year was already posted or submitted, ask OSHA or your State Plan how to handle the amended figures.
Where the sources conflict or stop
Some questions have no single answer in the text you can quote. Case-numbering conventions and the handling of an amended prior-year 300A that was already posted or submitted are the usual ones. Where you rely on an interpretation, note its source and date in your findings list. A documented reading is easier to defend than an undocumented habit.
What OSHA Can See and Request
An internal audit is worth doing partly because several parties can look at the record. Employees and their representatives can request the log under 1904.35. Government representatives can request records under 1904.40, with the four-business-hour window above.
OSHA can also look at what you submitted. Covered establishments submit injury and illness data through the Injury Tracking Application (ITA) by March 2 of the year after the covered year. For calendar-year 2025 data, that date is March 2, 2026 (checked 2026). Under 29 CFR 1904.41, establishments with 20–249 employees in designated higher-hazard industries submit 300A data, and establishments with 100 or more employees in the Appendix B industries also submit 300 and 301 data (OSHA interpretation, 2024-04-16). OSHA tells compliance officers to refer to the ITA database during all inspections to identify employers that were required to submit records but did not. In March 2026, OSHA also issued a non-responder enforcement memo for calendar-year 2025 Form 300A data.
For this reason, add one more test to the checklist: the figures you submitted should match the figures on the log you hold.
Penalties exist for recordkeeping and posting violations, but we print no dollar figures. Federal OSHA adjusts its maximum penalties for inflation each year, so read the current amounts on OSHA's penalties page. State Plans set their own penalties, so employers in California, Michigan or North Carolina should check their State Plan agency. The point of the audit is accuracy of the record. The penalty schedule says nothing about how any particular case would be treated.
Where Tools Fit, and Your Next Step
Most employers run this check with a spreadsheet and a free blank OSHA form, and that works if someone owns it. The weak points are known ones: totals that do not update, edits with no trail, and a self-check that happens once, in January, under time pressure. A workbook can recompute those comparisons so a person reviews findings instead of adding columns by hand.
The OSHA Recordkeeping Self-Audit Workbook is built for that review. It runs consistency checks on the log data you enter, such as continuity, column totals and tallies against the 300A, and lists what does not reconcile. It does not decide recordability, and it submits nothing to OSHA. You decide, and you file. It suits a single-state employer with a handful of sites as well as a larger group.
A planned app would carry the same comparisons into a live record, but nobody can sign up for it today. The deadline and rule logic in it is being built to carry citations and "last verified" dates for each row, and you can see where that stands on the waitlist page.
Your next step this week:
- Pull the closed year's log, 301s and 300A for one establishment.
- Run checks 1 through 10 and write the findings list.
- Fix what is wrong, with dates and reasons.
- Confirm any open question with OSHA or your State Plan agency before posting or submitting.
Reference material with citations, not legal advice. You decide recordability and compensability, and you file.
