OSHA Form 301: Recordable Incidents, Deadline, and ITA Filing

OSHA Form 301, the Injury and Illness Incident Report, is the federal form an employer completes each time a worker suffers a recordable on-the-job injury or illness. You have seven calendar days from learning about a qualifying incident to fill it out, and you must keep the completed record for five years. Missing or incomplete forms are treated as other-than-serious violations carrying fines of up to $16,550 each.1Occupational Safety and Health Administration. OSHA Penalties

Who Has to Keep These Records

Two exemptions decide whether Form 301 applies to your business at all.

The first is size. If your company had ten or fewer employees at every point during the previous calendar year, you are generally excused from routine OSHA recordkeeping, including Form 301. The count covers all employees across the entire company, not just one location.2Occupational Safety and Health Administration. 29 CFR 1904.1 – Partial Exemption for Employers With 10 or Fewer Employees

The second is industry. Certain lower-hazard industries listed in an appendix to the regulations are also excused. This one applies establishment by establishment, so a company with locations in different industries could owe records at some sites but not others.3eCFR. 29 CFR 1904.2 – Partial Exemption for Establishments in Certain Industries

Both exemptions disappear if OSHA or the Bureau of Labor Statistics asks you to keep records. And no exemption removes the duty to report any workplace fatality, in-patient hospitalization, amputation, or loss of an eye directly to OSHA.2Occupational Safety and Health Administration. 29 CFR 1904.1 – Partial Exemption for Employers With 10 or Fewer Employees

What Counts as a Recordable Incident

You only complete a Form 301 when an injury or illness meets specific thresholds. Any one of these triggers is enough:

  • Death from a work-related event.
  • One or more days away from work.
  • Restricted duty or a job transfer because of the condition.
  • Medical treatment beyond first aid.
  • Loss of consciousness from a workplace exposure or event.
  • A significant injury or illness diagnosed by a physician, even without any of the above.

All six come from the same regulation.4Occupational Safety and Health Administration. 29 CFR 1904.7 – General Recording Criteria

The first aid line is where employers most often go wrong. Bandaging a cut, applying a non-prescription ointment, or wrapping an elastic bandage counts as first aid. Prescription-strength medication, sutures, or removal of a foreign body from the eye with specialized instruments crosses into recordable medical treatment.4Occupational Safety and Health Administration. 29 CFR 1904.7 – General Recording Criteria When you’re unsure, check the specific first-aid list in 29 CFR 1904.7 before deciding an incident falls below the line.

What the Form Asks For

Form 301 runs two pages and gathers information in four groupings.

Employee Information

Full name, home address, date of birth, date of hire, sex, and the time the employee started their shift on the day of the incident.5Occupational Safety and Health Administration. OSHA Forms for Recording Work-Related Injuries and Illnesses

Physician or Health Care Professional

The name of the treating physician or health care professional, the facility name and address where treatment occurred, and whether the employee went to an emergency room or was hospitalized overnight.5Occupational Safety and Health Administration. OSHA Forms for Recording Work-Related Injuries and Illnesses

Incident Details

Four open-ended questions form the narrative core. You describe what the employee was doing just before the incident, explain how the injury happened, identify the body part affected and the nature of the harm (a strained back, a chemical burn), and name the object or substance that directly caused it. OSHA’s instructions specifically warn against including personally identifiable information about other workers in this section.5Occupational Safety and Health Administration. OSHA Forms for Recording Work-Related Injuries and Illnesses

Case and Administrative Details

The date and time of the event, the case number that links the report back to the OSHA 300 Log, and the date of death if the employee died. An administrator signs and dates the bottom.

The Seven-Day Deadline

Both the Form 301 and the matching entry on the OSHA 300 Log must be completed within seven calendar days of learning that a recordable injury or illness occurred.6Occupational Safety and Health Administration. 29 CFR 1904.29 – Forms The clock starts when you receive information about the incident, not the date it happened. An employee who develops symptoms over time may not report a condition until days or weeks after onset; your seven days start when that report reaches you.

A missed deadline does not excuse you from filing. Late is better than never, but a pattern of late filings is exactly what OSHA inspectors look for.

Using a Substitute Form

You are not locked into OSHA’s official Form 301. A state workers’ compensation report, an insurance claim form, or any other document can serve as a substitute as long as it captures the same information the 301 asks for.5Occupational Safety and Health Administration. OSHA Forms for Recording Work-Related Injuries and Illnesses Many employers use their workers’ comp first-report-of-injury form because the fields overlap heavily and it cuts duplicate paperwork. Before relying on a substitute, compare it field by field against the 301 so nothing is missing.

How Form 301 Connects to the 300 Log and 300A

Form 301 does not stand alone. It feeds two other records, and all three must stay consistent.

The OSHA 300 Log is a running yearly register of every recordable incident at an establishment. Each completed Form 301 becomes a single line item on the 300 Log, capturing the case type, the body part affected, and outcomes like days away from work or restricted duty.6Occupational Safety and Health Administration. 29 CFR 1904.29 – Forms

At year-end, you total the columns on the 300 Log and transfer the numbers to the OSHA 300A annual summary. A company executive must certify the summary, and the signed 300A must be posted where employees can see it from February 1 through April 30 of the following year.7eCFR. 29 CFR 1904.32 – Annual Summary

Electronic Submission Through the Injury Tracking Application

Some employers also submit their data electronically through OSHA’s Injury Tracking Application. Requirements break into tiers by size and industry:

  • Establishments with 20 to 249 employees in designated high-hazard industries submit Form 300A data each year.
  • Establishments with 250 or more employees in any industry required to keep records submit Form 300A data each year.
  • Establishments with 100 or more employees in certain designated industries submit Form 300A, 300 Log, and Form 301 data each year.

Employee count is based on peak employment at any point during the previous calendar year, and the industry designations are listed in appendices to the regulation.8eCFR. 29 CFR 1904.41 – Electronic Submission of Injury and Illness Records to OSHA The submission window typically opens in January and closes in early March. If your establishment is in the third tier, individual Form 301 records become part of a federal database, which raises the stakes on getting each one right.

Record Retention and Who Can Request Copies

Keep completed Form 301 records, along with the 300 Log and 300A summary, for five years after the end of the calendar year they cover.9Occupational Safety and Health Administration. 29 CFR 1904.33 – Retention and Updating A 2024 incident report stays in your files through the end of 2029.

Employees and their personal representatives can request a copy of any Form 301 describing that employee’s own injury or illness. You must provide the copy by the end of the next business day after the request.10eCFR. 29 CFR 1904.35 – Employee Involvement

Authorized collective bargaining representatives can also request copies, but with tighter limits. You have seven calendar days to respond, and you only share the section titled “Tell us about the case.” All other information, including the injured worker’s personal details, must be removed before the copies go to the union.10eCFR. 29 CFR 1904.35 – Employee Involvement Most access disputes turn on that distinction between an employee asking for their own record and a representative asking for someone else’s.

Penalties for Getting It Wrong

OSHA classifies recordkeeping failures as other-than-serious violations, with fines of up to $16,550 per violation. Each missing or incomplete Form 301 can count separately, so paperwork gaps across multiple incidents stack up. Willful or repeated violations run as high as $165,514 each.1Occupational Safety and Health Administration. OSHA Penalties Penalty amounts are adjusted for inflation annually and can be reduced based on the employer’s size, cooperation, and history.