OSHA Recordkeeping Policy and Procedure Template

OSHA Recordkeeping Policy and Procedure Template

[Company / Employer Name]
[Department or Division (if applicable)]
[Street Address]
[City, State/Province, ZIP/Postal Code]
Phone: [Main Phone Number]
Effective Date: [MM/DD/YYYY]
Review Date: [MM/DD/YYYY]

1. Purpose

The purpose of this OSHA Recordkeeping Policy and Procedure (“Policy”) is to establish a consistent process for recording, summarizing, and retaining work-related injuries and illnesses in accordance with applicable OSHA recordkeeping requirements.

This Policy is intended to:

• Define roles and responsibilities for OSHA recordkeeping.

• Describe how incidents are evaluated for recordability.

• Standardize the use of OSHA Forms 300, 300A, and 301 (or equivalent forms).

• Ensure that injury and illness records are accurate, timely, and complete.

2. Scope

This Policy applies to:

• All employees of [Company Name] at [all U.S. locations / this establishment / specified sites].

• All temporary, seasonal, and part-time employees supervised on a day-to-day basis by [Company Name].

• Any other workers whose injuries or illnesses must be recorded by [Company Name] under applicable OSHA recordkeeping rules.

This Policy does not replace legal advice. If any provision conflicts with current OSHA regulations, OSHA regulations and official guidance take precedence.

3. Definitions

For purposes of this Policy, the following terms are used in a general, non-technical sense. Always refer to current OSHA regulations for formal definitions.

• Recordable Case – A work-related injury or illness that meets OSHA criteria for recording on the OSHA 300 log (for example: death, days away from work, restricted work or job transfer, loss of consciousness, or certain significant diagnoses).

• Work-Related – An injury or illness that occurs in the work environment and arises out of employment, subject to OSHA’s specific inclusion and exclusion criteria.

• OSHA 300 Log – Log of Work-Related Injuries and Illnesses used to list each recordable case for the calendar year.

• OSHA 300A Summary – Year-end summary of all cases on the OSHA 300 log.

• OSHA 301 (or Equivalent) – Incident report with detailed information about each recordable case.

• Privacy Case – Certain sensitive cases that OSHA allows employers to list as “privacy case” on the log instead of using the employee’s name.

4. Roles and Responsibilities

4.1 Senior Management / Company Executive

• Approve this Policy and any significant revisions.

• Annually certify the accuracy and completeness of the OSHA 300A Summary.

• Allocate resources (staff, training, systems) needed to implement this Policy.

4.2 OSHA Recordkeeping Coordinator

[Title: e.g., Safety Manager, HR Manager, EHS Director]

• Serve as the primary contact for OSHA recordkeeping questions.

• Maintain the OSHA 300 log, OSHA 300A summary, and OSHA 301 or equivalent forms for each recordable case.

• Determine recordability in consultation with supervisors, HR, and, when appropriate, medical professionals.

• Ensure recordable cases are entered on the OSHA 300 log within required timeframes (e.g., within 7 calendar days of receiving information that a case is recordable).

• Coordinate any required electronic submissions of injury and illness data to OSHA.

• Oversee annual reviews and internal audits of injury and illness records.

4.3 Supervisors and Managers

• Ensure that all workplace injuries and illnesses are reported promptly according to company procedures.

• Provide factual information needed for incident reports and recordkeeping decisions.

• Cooperate with safety/HR staff during incident investigations and follow-up actions.

• Communicate recordkeeping obligations and reporting expectations to team members.

4.4 Human Resources

• Coordinate with the Recordkeeping Coordinator and supervisors to obtain employee information needed for OSHA 301 or equivalent forms.

• Align OSHA recordkeeping with workers’ compensation and leave management processes (while avoiding prohibited retaliation).

• Support training and communication related to incident reporting and recordkeeping.

4.5 Employees

• Promptly report all work-related injuries, illnesses, and near misses to their supervisor or designated contact, regardless of severity.

• Provide accurate information about the incident and any medical treatment received.

• Participate in investigations and return-to-work planning as appropriate.

5. Incidents Covered by this Policy

This Policy applies to work-related injuries and illnesses that may be OSHA-recordable, including but not limited to:

• Fatalities.

• Injuries or illnesses resulting in days away from work.

• Injuries or illnesses resulting in restricted work or job transfer.

• Cases involving loss of consciousness.

• Certain significant diagnoses as defined by OSHA (e.g., fractures, punctured eardrums, certain chronic conditions).

• Specific types of recordable cases (e.g., certain needlestick injuries, hearing loss cases, work-related tuberculosis or other specific conditions as defined in current OSHA rules).

Non-recordable incidents may still require internal incident reports or corrective actions. This Policy does not limit which events the company chooses to investigate for safety reasons.

6. Forms and Records Used

[Company Name] uses the following forms to meet OSHA recordkeeping requirements:

• OSHA 300 – Log of Work-Related Injuries and Illnesses (or equivalent log) for each establishment.

• OSHA 300A – Summary of Work-Related Injuries and Illnesses, prepared and certified annually.

• OSHA 301 – Injury and Illness Incident Report (or equivalent internal incident report) for each recordable case.

Internal forms may be electronic or paper-based, provided they capture all required information.

7. Recordkeeping Procedure

7.1 Incident Reporting

1. Employee Reporting

   • Employees must report any injury, illness, or near miss as soon as reasonably possible to their supervisor or designated contact.

2. Supervisor Notification

   • Supervisors must notify the Recordkeeping Coordinator (and HR/safety, as applicable) promptly upon receiving a report.

3. Initial Incident Documentation

   • A preliminary incident report is completed by the supervisor, safety representative, or other designated person using the company’s incident reporting form.

7.2 Determining Work-Relatedness and Recordability

1. The Recordkeeping Coordinator reviews available information, including:

   • Incident reports and investigation findings.

   • Medical documentation (where available and appropriate).

   • Applicable OSHA recordkeeping rules and interpretations.

2. The Coordinator determines whether the case is:

   • Work-related (under OSHA’s criteria), and

   • OSHA-recordable (i.e., meets one or more recordability criteria).

3. If additional information is needed, the Coordinator may:

   • Request follow-up details from supervisors, employees, or medical providers (subject to privacy and confidentiality protections).

   • Consult with HR or legal counsel as needed.

7.3 Entering Cases on the OSHA 300 Log

For each recordable case:

• A unique case number is assigned.

• An OSHA 301 or equivalent incident report is completed or updated.

• The case is entered on the OSHA 300 log for the relevant establishment within the required time (e.g., within 7 calendar days of learning that it is recordable).

• The entry includes all required information: employee name (or “privacy case” if applicable), job title, date, location, description, classification, days away, days restricted/transfer, and type of case.

7.4 Updating Days Away and Restricted Work

• The Recordkeeping Coordinator tracks days away from work and days of job transfer or restriction based on information from supervisors, HR, and medical providers.

• The OSHA 300 log is updated as these day counts change, subject to applicable maximums and OSHA guidance.

• If the classification of the case changes (for example, from “restricted work” to “days away”), the log is updated accordingly.

8. Privacy Cases and Confidentiality

• For cases meeting OSHA’s privacy case criteria, the employee’s name will not be entered on the OSHA 300 log. Instead, the log will list “privacy case” in the name column, and the company will maintain a separate confidential list linking the case number to the employee’s identity.

• Medical information and personally identifiable information shall be handled in accordance with company confidentiality policies and applicable laws and regulations.

• Access to detailed incident reports and medical records is limited to authorized personnel.

9. Annual Summary and Posting (OSHA 300A)

• At the end of each calendar year, the Recordkeeping Coordinator:

  • Reviews the OSHA 300 log for accuracy and completeness.

  • Prepares the OSHA 300A Summary using total cases, days away/restricted, and injury/illness categories.

• A company executive reviews and certifies the OSHA 300A Summary as true, accurate, and complete to the best of their knowledge.

• The certified OSHA 300A Summary is posted at each required establishment in a conspicuous location where employee notices are normally displayed for the period required by OSHA (for example, from February 1 to April 30 of the following year), or as otherwise required by current regulations.

10. Electronic Submission (If Required)

• If [Company Name] is required to submit injury and illness data electronically to OSHA or another designated system, the Recordkeeping Coordinator:

  • Identifies which establishments and forms are subject to electronic submission.

  • Gathers and verifies the necessary data.

  • Completes electronic submissions by the deadlines specified in current OSHA rules.

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11. Training and Communication

[Company Name] will provide training and communication appropriate to roles and responsibilities, which may include:

• Employee training on how and when to report injuries and illnesses.

• Supervisor and manager training on incident reporting, documentation, and their responsibilities under this Policy.

• Safety/HR staff training on OSHA recordkeeping criteria, forms, and updates.

• Periodic reminders (e.g., during safety meetings or via internal communications) about reporting obligations and non-retaliation.

12. Non-Retaliation

[Company Name] prohibits retaliation against any employee who, in good faith:

• Reports a work-related injury or illness.

• Raises concerns or questions about safety, recordkeeping, or OSHA compliance.

• Participates in incident investigations or provides information.

Any concerns about retaliation should be reported to [HR / Compliance / designated contact] for review and appropriate action.

13. Audits, Reviews, and Continuous Improvement

• The Recordkeeping Coordinator and/or Safety/HR will periodically review injury and illness records for accuracy, trends, and opportunities for improvement.

• Internal audits may include sampling entries on the OSHA 300 log and verifying them against incident reports, medical notes (as appropriate), and workers’ compensation records.

• Findings may lead to:

  • Corrections to the log or incident reports.

  • Updates to this Policy and related procedures.

  • Additional training, engineering controls, or process changes to reduce risk.

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14. Record Retention

• OSHA injury and illness records, including OSHA 300 logs, OSHA 300A summaries, and OSHA 301 or equivalent incident reports, will be maintained for at least five (5) years following the end of the calendar year that they cover, or longer if required by law or company policy.

• Records may be maintained in paper or electronic form, provided they are accurate, secure, and retrievable.

15. Conflicts with Law and Policy Revisions

• If any provision of this Policy conflicts with current OSHA recordkeeping regulations or other applicable laws, those laws and regulations will govern.

• [Company Name] reserves the right to revise this Policy at any time to reflect changes in law, OSHA guidance, organizational structure, or best practices.

• Revisions will be communicated to affected employees, supervisors, and departments.

16. Acknowledgment

By signing below, the undersigned acknowledge that they have reviewed the OSHA Recordkeeping Policy and Procedure and understand their responsibilities under it.

Executive / Senior Management

Name (print): _______________________________
Title: ______________________________________
Signature: __________________________________
Date: ______________________________________

OSHA Recordkeeping Coordinator

Name (print): _______________________________
Title: ______________________________________
Signature: __________________________________
Date: ______________________________________

[Optional – Additional Signature Blocks for HR, Safety, or Site Managers]