OSHA 300 Log: Does Your Crew Count, and What Is Due February 1?

If your company had more than ten employees at any point in 2025, you should be keeping an OSHA 300 log of injuries and illnesses for 2026 right now. Construction trades, janitorial crews and landscapers get no industry exemption. In January you close the log, a company executive signs the annual summary, and the summary goes up on the wall by February 1, 2027. Many companies with 20 or more people at one location also have to send it to OSHA online by March 2.

Here is how to tell whether your company is covered, what belongs on the log, and how to fill in the summary.

What the OSHA 300 log is

The OSHA 300 log is the form a covered employer uses to list every work-related injury and illness that meets OSHA’s recording rules. Its official name is Form 300, the Log of Work-Related Injuries and Illnesses. Two forms go with it: Form 301, the incident report you fill in for each case, and Form 300A, the annual summary you post. The requirement comes from 29 CFR Part 1904, the recordkeeping rule the Occupational Safety and Health Administration issued under the Occupational Safety and Health Act of 1970. For a covered employer it’s a legal duty, not a best practice, and an inspector can ask to see the records.

Does your company have to keep one?

Two questions decide it.

First, count your peak headcount for last year, company-wide. Under 29 CFR 1904.1, you keep records if your company had “more than ten (10) employees at any time during the last calendar year.” The count covers the entire company, not one office or one crew. It’s your peak, so a summer when you had 13 people on payroll puts you over the line even if you’re back to eight now. If you run a sole proprietorship or a partnership, the owners or partners don’t count as employees.

Second, check whether your industry is partially exempt. OSHA keeps a list of low-hazard industries, by NAICS code, that don’t have to keep the log. Construction (NAICS 23) isn’t on it. Neither is Services to Buildings and Dwellings (5617), which covers janitorial, landscaping, pest control and carpet cleaning. A few nearby businesses are exempt, such as appliance repair shops (8114). The exemption follows each establishment’s own code, so an appliance repair shop may be exempt while an HVAC installer down the street isn’t.

If you clear neither test, you keep the log. If you’re exempt on either one, you still have to report the most serious injuries, as explained further down.

What counts as recordable on a job

A case goes on the log if it’s work-related, it’s a new case, and it leads to at least one of these: death, days away from work, restricted work or a transfer to another job, medical treatment beyond first aid, or loss of consciousness. A significant injury or illness diagnosed by a doctor or other licensed health care professional counts too. A fractured or cracked bone or a punctured eardrum is always recordable once it’s diagnosed.

First aid or medical treatment?

The line most trades have to judge is first aid. OSHA’s first-aid list in 29 CFR 1904.7 is complete, so anything not on it is medical treatment. A few pairs show where the line falls on a job site:

• Steri-Strips or butterfly bandages on a cut are first aid. Stitches or staples are medical treatment.
• An elastic wrap on a sprained wrist is first aid. A rigid splint the worker keeps wearing after the trip to the clinic is treatment.
• Flushing grit out of an eye, or lifting it out with a cotton swab, is first aid. Removing a metal sliver any other way is treatment.
• Over-the-counter ibuprofen at the normal dose is first aid. The same drug recommended at prescription strength by a clinician is treatment.
• An X-ray alone isn’t treatment. But if it shows a fracture, the case is recordable.

When a case has to be entered

Days away are counted in calendar days, starting the day after the injury, whether or not the worker was scheduled to work. You have seven calendar days from learning about a recordable case to enter it on the 300 log and complete the 301 report. Many employers use their workers’ comp first report of injury instead of the 301, which is allowed if it carries the same information. Our guide to workers’ comp requirements by state covers the claim side.

Which OSHA 300 log a job site injury goes on

A crew that moves from house to house doesn’t keep a log at each address. For construction and similar work, OSHA treats the office or yard that supervises the crew, or that it works out of, as the “establishment”. The injury goes on that office’s log. A project expected to run for a year or more is its own establishment and needs its own log, while short jobs can all share one.

Temporary workers from a staffing agency go on your log if you supervise them day to day. The same applies to a subcontractor’s worker you direct yourself. A subcontractor who runs their own crew records their own injuries. Self-employed people aren’t covered by the rule at all.

Closing out the 2026 OSHA 300 log and posting Form 300A

The annual summary rule is in 29 CFR 1904.32. In January, for each log you keep, work through the Form 300A from top to bottom:

1. Review the log. Check each 2026 entry is complete and correct. A case that’s still running into 2027 stays on the 2026 log. Estimate its days away for the summary and update the log later.
2. Total the columns. Count the cases by outcome (death, days away, restricted or transfer, other recordable) and by type. If you had no recordable cases, you still fill in the form with zeros.
3. Fill in the establishment details. Add the year, company and establishment name and address, the annual average number of employees, and the total hours everyone covered by that log worked. Payroll records give you both numbers.
4. Get it certified. A company executive signs to confirm they have examined the log and believe the summary is correct and complete. That means the owner of a sole proprietorship or partnership, an officer of a corporation, the highest-ranking company official at the establishment, or that person’s immediate supervisor. An office manager can prepare the form, but the signature has to come from one of those people.
5. Post it. Put it up by February 1, 2027, wherever you usually post notices to employees, and leave it there until April 30.

The dates for the 2026 log

Keep the 300 log, the 300A and every 301 for five years after the end of the year they cover, and update the stored 300 log if a case changes. If an OSHA inspector asks for copies, you have four business hours to produce them.

Electronic submission by March 2

Some establishments also have to send their data to OSHA through its online Injury Tracking Application. The deadline in the rule is March 2, so the 2026 data is due by Tuesday, March 2, 2027. OSHA hadn’t posted the opening date for 2026 data when we checked in October 2026.

These thresholds count people per establishment, not company-wide. Every person who worked there at any time during 2026 counts, including part-time, seasonal and temporary workers.

• 20 to 249 people at the establishment, in a designated industry: submit the Form 300A data. Construction (23) and Services to Buildings and Dwellings (5617) are both designated.
• 250 or more people: submit the Form 300A data, in any industry that keeps records.
• 100 or more people, in a higher-hazard industry: also submit the 300 log and the 301 reports. In construction, that list includes only foundation, structure and building exterior contractors (NAICS 2381): concrete, steel, framing, masonry, glazing, roofing and siding. Electrical, plumbing, HVAC, finishing trades, janitorial and landscaping firms aren’t on it.

The submission needs your EIN and your legal company name. So a 30-person HVAC company with one shop keeps the log and submits the 300A online. The same company split across two branches of 15 still keeps a log at each branch, but neither one has to submit.

Serious injuries: report them even if you keep no log

Every employer covered by OSHA, including exempt and small ones, must report a work-related death within 8 hours. An in-patient hospitalization, an amputation (a fingertip counts) or the loss of an eye must be reported within 24 hours. You report by phone to the nearest OSHA area office, on 1-800-321-OSHA (1-800-321-6742), or online. California sets a stricter clock: Cal/OSHA’s Title 8, section 342 requires serious injuries to be reported within 8 hours.

Recordkeeping failures can draw a penalty of up to $16,550 per violation. That is the 2025 maximum, which OSHA kept for 2026 because there was no inflation adjustment this year. Our OSHA compliance overview covers the site citations inspectors write most often, and our article on the 2024 hazard communication changes covers another written program a cleaning or trades crew needs.

Crossed ten employees this year?

The test always looks back one year. If your 2025 peak was ten or fewer, you don’t owe a 2026 log, even if you’ve grown since. But if your headcount went past ten at any point in 2026, start a 2027 log on January 1, with Form 301 ready for the first case. Our guide to hiring your first employee lists the other duties that switch on as a crew grows. In a year’s time, the January routine above is yours too.