OSHA recordkeeping is the compliance requirement that every contractor knows about and a surprising number get wrong. The mistakes are rarely dramatic. They are subtle classification errors, missed recording deadlines, and log maintenance oversights that compound into citation exposure, ISNetworld findings, and inaccurate TRIR calculations.
Which Contractors Must Keep OSHA Records
OSHA recordkeeping requirements under 29 CFR Part 1904 apply to most employers. Employers with 10 or fewer employees are exempt from routine recordkeeping, but most oil and gas, pipeline, construction, and industrial services contractors exceed the 10-employee threshold. Even if your company qualifies for a partial exemption, operators require OSHA logs as part of their ISNetworld, Avetta, or direct prequalification requirements.
The OSHA 300 Log: What Must Be Recorded
A case is recordable if it results in death, days away from work, restricted work, medical treatment beyond first aid, loss of consciousness, or a significant injury diagnosed by a licensed healthcare professional. The distinction between first aid and medical treatment is where most classification errors occur. Prescription-strength medications, sutures, and physical therapy all constitute medical treatment that makes a case recordable.
Recording Deadlines and Log Maintenance
New cases must be entered on the 300 Log within seven calendar days. OSHA 300 Logs must be kept for five years following the year they cover. The 300A summary must be posted from February 1 through April 30 each year and must be certified by a company executive.
How Recordkeeping Errors Affect Your TRIR and ISNetworld
ISNetworld’s RAVS review process independently evaluates your OSHA logs, and discrepancies between your reported rates and the underlying log data trigger compliance findings. Under-recording creates citation exposure and ISNetworld audit risk. Over-recording inflates your TRIR relative to your actual safety performance.
Frequently Asked Questions
Q: What OSHA forms do contractors need to keep?
A: Most contractors must maintain the OSHA 300 Log, the OSHA 300A Summary, and the OSHA 301 Incident Report for each recordable case. These forms must be kept for five years.
Q: What is the difference between OSHA first aid and medical treatment?
A: First aid is a specific list of minor treatments. Any treatment beyond the first aid list, including prescription medications, sutures, and physical therapy, constitutes medical treatment and makes the case recordable.
Q: When do OSHA 300 Logs need to be updated?
A: New cases must be entered within seven calendar days. Electronic submission through the ITA system is due by March 2 for qualifying employers.
Need help ensuring your OSHA recordkeeping is audit-ready? Contact Drake Group for a compliance review.
