I've been the person building the 300A in the last week of January more times than I'd like to admit. You open the OSHA 300 log, start filling in the summary, and realize that half the year's cases need a second look. A case from the spring was never closed out. The day counts don't match what HR has. Nobody has a full year of hours worked. And the form still has to be signed by an executive and on the wall by February 1.
The form itself takes ten minutes. Everything behind it takes weeks. What I've learned is that February 1 is won or lost in November, while there's still time to chase down answers.
Here's the checklist I work through this time of year.
Who Has to Submit Electronically?
Posting the 300A applies to nearly every employer covered by OSHA recordkeeping. Electronic submission depends on establishment size and industry. In general:
- 250 or more employees at an establishment covered by recordkeeping: submit 300A data.
- 20 to 249 employees in certain designated industries: submit 300A data.
- 100 or more employees in certain designated high-hazard industries: also submit case-level data from the 300 log and 301 forms.
Requirements are based on your establishment's industry code and headcount, and OSHA updates them from time to time. Confirm your obligations on OSHA's Injury Tracking Application page before the deadline.
The Pre-February Checklist
1. Reconcile the log against every other source
Compare the 300 log to your incident reports, workers' comp claims, first aid logs, and nurse or clinic records. In my experience, a case that shows up in a comp claim but never made it to the log is the most common gap, and it's exactly what an inspector will find first.
2. Re-check every recordability decision
For each case, confirm whether it involved medical treatment beyond first aid, days away from work, restricted work, job transfer, or loss of consciousness. Some of those calls were made in a hurry the day of the injury, before the clinic visit or the follow-up. Treatments that look minor can still cross the line, and first aid cases that were logged by mistake should come off.
3. Update and close out day counts
Days away and restricted days often stop being updated once the employee returns. Get final counts from HR or the treating provider. Remember the 180-day cap per case.
4. Handle privacy cases correctly
Certain cases, such as injuries to intimate body parts, sexual assault, mental illness, and some infectious diseases, should be entered as "privacy case" rather than the employee's name. Keep the separate confidential list of names.
5. Get hours worked and average employees now
The 300A needs total hours worked and the annual average number of employees. If you aren't already tracking hours monthly, ask payroll for January through October now and set up a monthly pull going forward. Twelve small monthly entries are far easier than one year-end scramble. Include temporary workers you supervise day to day, since their recordable cases belong on your log too.
6. Line up the executive who will certify it
The 300A must be certified by a company executive: an owner, an officer, the highest-ranking official at the establishment, or that person's immediate supervisor. The safety manager's signature alone doesn't count. I put it on the executive's calendar in early January, because the last week of the month is when they're traveling.
7. Plan where it gets posted
Post it where notices to employees are normally posted, from February 1 through April 30. For employees who don't report to a physical site, plan an electronic posting.
8. Submit, then keep the records
If your establishment must submit, file through the ITA by March 2. Keep the 300, 300A, and 301 records for five years after the end of the calendar year they cover.
The Mistakes I See Most
- Not posting because there were no cases. A year with zero recordables still requires a posted 300A showing zeros.
- Leaving temp workers off the log. If you supervise their daily work, their recordable injuries go on your log, not the staffing agency's.
- Day counts that never got updated. A case logged in March with "5 days away" that actually ran 40 days is a bad look in an inspection.
- Waiting for January. The answers you need (hours worked, final day counts, medical details) take weeks to collect.
Make Next Year's 300A a Non-Event
TruVex walks each incident through the OSHA recordability questions at the time it's reported, tracks day counts as cases develop, records hours worked every month, and builds the 300 log and 300A summary from your records automatically. When February comes, the summary is already done.
Book a DemoThe Bottom Line
The hard part of the 300A is never the form. It's reconciling cases, correcting decisions, and chasing numbers from three different departments. Start that work in November and February becomes a signature and a thumbtack.
That's a big part of why we built TruVex. I got tired of doing this the hard way every January.
If you'd like a second set of eyes on your log before posting season, book a 15-minute call. It's one safety professional talking to another.
This article is general information about OSHA recordkeeping under 29 CFR 1904 and is not legal advice. Confirm requirements for your establishment with OSHA guidance or a qualified professional.