If your business has ever scrambled in late January to find last year’s injury log, you already know that OSHA recordkeeping requirements for Houston employers are easy to underestimate until an inspector or an insurance auditor asks for proof. Recordkeeping isn’t just paperwork. It’s how the Occupational Safety and Health Administration tracks work-related injuries and illnesses across every covered industry, and it’s one of the most commonly cited compliance gaps among Houston construction, manufacturing, and industrial employers.
This guide walks through what OSHA recordkeeping actually requires under 29 CFR 1904, which forms you need, the 2026 filing deadlines for 2025 data, and the mistakes that most often turn a routine audit into a costly citation.
Key Takeaways
- Most employers with more than 10 employees need to maintain OSHA injury and illness records, unless their NAICS code shows up on OSHA’s exempt industries list.
- Three forms drive OSHA recordkeeping: the OSHA 300 Log (your ongoing record), Form 301 (incident detail), and Form 300A (the certified annual summary).
- Recordable cases need to be logged within 7 calendar days. The Form 300A must be posted February 1 through April 30, 2026. Electronic ITA submission, where it applies, is due March 2, 2026.
- Electronic submission thresholds depend on establishment size and NAICS code: 250+ employees, 20 to 249 employees in Appendix A industries, or 100+ employees in Appendix B high-hazard industries.
- Severe injury reporting is a separate requirement from recordkeeping. Fatalities must be reported within 8 hours, and hospitalizations, amputations, or eye loss within 24 hours, no matter your ITA status.
- Employees and union representatives have a right to request the 300 log and their own 301 Incident Report, subject to privacy protections.
- The most common recordkeeping mistakes are missed 300A postings, incomplete 301 reports, and misjudged NAICS exemption status, all of which are preventable with a periodic recordkeeping review.
What OSHA Recordkeeping Actually Covers
The Occupational Safety and Health Act established OSHA to protect workers, and recordkeeping regulations, codified at 29 CFR Part 1904, are how the Federal Government measures whether that protection is working in practice. Under these regulations, covered employers must track work-related injuries and illnesses, keep a running injury and illness data log throughout the year, and report certain severe events on a strict timeline.
The Bureau of Labor Statistics and OSHA both rely on this injury and illness data to spot hazard trends across industries, target inspections through programs like OSHCon, and gauge whether a workplace’s safety program is actually reducing risk. For Houston employers in oil and gas, petrochemical, construction, and manufacturing, industries with historically higher recordable injury rates, accurate recordkeeping is often the first thing a compliance officer reviews during a Houston North or Houston South Area Office inspection.
Who Must Keep OSHA Injury and Illness Records
Most employers with more than 10 employees are covered by OSHA’s recordkeeping regulations. There’s a partial exemption for a revised list of low-hazard industries identified by their NAICS System classification (Appendix A to Subpart B), but even partially exempt employers aren’t entirely off the hook. The Bureau of Labor Statistics can still require participation in its annual survey, and OSHA’s General Duty Clause applies to every workplace regardless of recordkeeping status.
It’s worth confirming your exemption status before assuming records aren’t required. The exempt list is narrower than a lot of business owners expect, and misclassifying your NAICS code is a common, and avoidable, recordkeeping mistake.
The Three Core OSHA Recordkeeping Forms
OSHA’s recordkeeping system is built around three linked forms. Getting familiar with all three, and how they connect to each other, is really the foundation of staying compliant.
OSHA Form 300: Log of Work-Related Injuries and Illnesses
The OSHA 300 Log is the running record every covered establishment has to maintain throughout the calendar year. Each recordable injury and illness case gets logged with the employee’s job title, the date and location of the event, and the nature of the injury or illness. Unlike the 300A, the OSHA 300 log isn’t posted publicly, largely because of privacy protections for the employees involved.
Cases need to be entered on the OSHA 300 log within seven calendar days of the employer learning about a work-related injury or illness.
OSHA Form 301: Incident Report
The Form 301 Incident Report fills in the details behind each entry on the 300 log: how the incident happened, what the employee was doing, what medical treatment was provided, and which body part was affected. Where the 300 log gives you a quick snapshot, the 301 tells the full story of each case, and that matters if OSHA or a workers’ compensation carrier ever asks for documentation.
OSHA Form 300A: Annual Summary
At year-end, the data from the 300 log gets totaled and transferred to the Form 300A Annual Summary, including total recordable cases, days away from work, restricted work or job transfer cases, and any work-related fatalities. A company executive has to certify the Annual Summary, even in years with zero recordable incidents.
What Counts as a Recordable Injury or Illness
Not every workplace incident belongs on the OSHA 300 log. A case is recordable if it results in:
- Death
- Days away from work
- Restricted work activity or job transfer
- Medical treatment beyond first aid
- Loss of consciousness
- A “significant” injury or illness diagnosed by a physician or licensed health care professional, even without any of the outcomes above (think a fractured bone, a punctured eardrum, or work-related cancer)
Certain conditions come with their own recording rules. Hearing loss is recordable once a Standard Threshold Shift is confirmed and the employee’s total hearing loss relative to their baseline meets OSHA’s criteria. A diagnosed respiratory condition tied to workplace exposure is generally recordable regardless of whether it caused missed work. Employee Exposure and Medical Records related to hazardous materials exposure also have to be kept separately, with additional privacy protections under 29 CFR 1910.1020.
2026 Recordkeeping and Reporting Deadlines Houston Employers Need to Know
Recordkeeping deadlines run on a predictable annual cycle, but missing any one of them creates real exposure:
March 2 is the deadline for electronic submission of injury and illness data through OSHA’s Injury Tracking Application (ITA), for establishments that meet the electronic reporting thresholds.
Within 7 calendar days of learning about a recordable injury or illness, record it on the OSHA 300 log and complete the corresponding Form 301 Incident Report.
February 1 through April 30, post the certified OSHA Form 300A Annual Summary in a visible, common area at each covered establishment, even if there were zero recordable cases.
Who Has to Submit Electronically Through the ITA
Electronic submission requirements come down to establishment size and NAICS code, not total company headcount:
- Establishments with 250 or more employees (and not in an Appendix A exempt industry) must submit Form 300A data.
- Establishments with 20 to 249 employees in an industry listed in Appendix A to Subpart E of 29 CFR 1904 also have to submit Form 300A data.
- Establishments with 100 or more employees in a high-hazard industry listed in Appendix B to Subpart E must submit detailed Forms 300 and 301 data on top of the 300A.
A lot of Houston construction and industrial employers fall into these designated high-hazard categories, so it’s worth confirming your establishment’s status through OSHA’s ITA Coverage Application rather than assuming electronic submission doesn’t apply to you.
Severe Injury and Fatality Reporting Is a Separate Requirement
Recordkeeping isn’t the same thing as OSHA’s severe event reporting requirement, and mixing the two up is one of the fastest ways to miss a deadline. Employers have to report the following directly to OSHA, not just log them internally:
- Any work-related fatality, within 8 hours
- Any in-patient hospitalization, amputation, or loss of an eye, within 24 hours
Reports go to the nearest OSHA Area Office (in Texas, that includes Houston North, Houston South, Dallas, Austin, San Antonio, Fort Worth, Corpus Christi, or Lubbock) or through the 24-hour OSHA hotline. This obligation applies no matter your establishment’s size or ITA electronic submission status.
Employee Access and Union Representative Rights
Current and former employees, along with their designated union representatives, have the right to request copies of the OSHA 300 log and their own Form 301 Incident Report, subject to privacy protections for “privacy concern cases.” It helps to have a clear internal process for handling these requests, since both improperly withholding and improperly disclosing records covered by privacy protections create compliance risk.
Common OSHA Recordkeeping Mistakes Houston Employers Make
- Assuming a low headcount automatically exempts the business, without checking the NAICS exempt industries list
- Recording an incident on the OSHA 300 log but never completing the corresponding Form 301 Incident Report
- Mixing up the recordkeeping timeline (7 days) with the severe injury reporting timeline (8 to 24 hours)
- Failing to certify or post the Form 300A between February 1 and April 30
- Not rechecking ITA electronic submission requirements after employee headcount or NAICS classification changes
- Storing Employee Exposure and Medical Records improperly, which creates privacy protection violations
- Treating recordkeeping as a year-end scramble instead of a running log updated as incidents occur
Recordkeeping violations are among the more common citations issued during OSHA inspections in Texas, and repeat or willful violations carry much higher penalties than first-time paperwork errors. Even a first-time citation can affect your OSHA inspection history and your standing with insurers like Texas Mutual or the Texas Department of Insurance, Division of Workers’ Compensation.
How Aggie Safety Helps Houston Employers Stay Compliant
Recordkeeping is only one piece of a functioning safety program, but it’s the piece OSHA checks first. Aggie Safety works with Houston construction, manufacturing, and industrial employers to review existing OSHA 300, 300A, and 301 documentation, confirm ITA electronic submission obligations, and build recordkeeping practices that actually hold up under inspection, not just on paper, but in daily practice on the floor.
If you’re not confident your current documentation would pass an OSHA compliance officer’s review, that’s exactly the kind of gap a safety audit is designed to catch before it becomes a citation.
Request a free safety consultation with Aggie Safety to review your recordkeeping practices and identify gaps before your next inspection.
