OSHA 300 Log vs. Workers' Comp Claim: Which Injuries Go Where

10/11/2026

A forklift operator strains her back, sees the company clinic, gets a prescription muscle relaxant and two days of restricted duty. Is that an OSHA recordable case? Is it a workers' comp claim? The answer to both is probably yes, but for different reasons, and the two answers will not always match.

HR and safety teams regularly treat the OSHA 300 Log and the workers' comp claim file as one record. They are not. One is a federal recordkeeping system that measures workplace injury and illness. The other is a state insurance system that pays benefits. They use different definitions, run on different deadlines and answer to different agencies. This guide explains where each injury goes, the OSHA 300 log requirements you must meet, and how to keep the two systems consistent without merging them. For background on how the two regimes relate in general, see our article on OSHA and workers' comp.

Two Different Systems With Two Different Definitions

	OSHA injury and illness records	Workers' comp claim
Governing law	29 CFR Part 1904 (federal; some states run their own OSHA-approved plans)	State workers' comp statute
Purpose	Track and measure work-related injuries and illnesses	Pay medical and wage-replacement benefits
Core question	Is the case work-related, new, and does it meet a recording criterion?	Did the injury arise out of and in the course of employment, under that state's law?
Decided by	The employer, applying OSHA's rules	The insurer or claims administrator, and ultimately the state agency or courts
Covered workers	Employees on your payroll, plus workers you supervise day to day, such as many temporary workers	Employees covered by your policy (temporary workers are often covered by the staffing agency)
Key forms	OSHA 300, 300A, 301	First report of injury and state forms

 

Because the questions differ, the answers can differ. Recording a case on the 300 Log is not an admission that it is compensable, and accepting a comp claim does not make a case recordable. OSHA's own forms say as much: recording a case does not mean the employer or worker was at fault or that an OSHA rule was violated.

OSHA Recordability Criteria vs. Workers' Comp Compensability

What makes a case recordable

Under 29 CFR 1904.7, a work-related, new case is recordable if it results in any of the following:

• Death
• Days away from work
• Restricted work or transfer to another job
• Medical treatment beyond first aid
• Loss of consciousness
• A significant injury or illness diagnosed by a physician or other licensed health care professional, even without the outcomes above

Two definitions do most of the work:

• First aid is a closed list in the regulation, including non-prescription medication at non-prescription strength, tetanus shots, cleaning and bandaging wounds, hot or cold therapy, non-rigid supports such as elastic bandages, and drinking fluids for heat stress. Anything on the list is first aid no matter who provides it. Anything not on the list is generally medical treatment.
• Work-relatedness is presumed for events or exposures in the work environment, subject to specific exceptions in 29 CFR 1904.5 (for example, injuries from eating and drinking for personal consumption, or from voluntary participation in a wellness program).

What makes a claim compensable

Compensability is a matter of state law, and the details vary. Most statutes require an injury "arising out of and in the course of employment," and many add defenses, such as intoxication or willful misconduct, along with notice and filing deadlines. Our article on what makes an injury compensable covers the common tests.

Cases That Are Recordable but Not Compensable, and the Reverse

Recordable, but the comp claim is denied:

• An injury in the work environment that OSHA presumes work-related, where the state statute bars benefits because of a defense such as intoxication or a missed notice deadline. The OSHA entry stays.
• A significant aggravation of a pre-existing condition that meets OSHA's criteria, where the insurer concludes the condition was not caused by work under state standards.
• A temporary worker you supervise day to day: you record the case on your log, while the staffing agency's insurer handles the claim.

Compensable, but not recordable:

• Medical-only claims for first-aid-level care. The comp insurer pays for a clinic visit, but the treatment was a bandage and an over-the-counter dose.
• Diagnostic visits only. Visits to a health care professional solely for observation or counseling, and diagnostic procedures such as X-rays, are not medical treatment under OSHA's rule. The insurer still pays for them.
• Employers partially exempt from OSHA recordkeeping. A small or low-hazard employer has no 300 Log, but its workers' comp obligations are unchanged.

Recordable and compensable, but counted differently:

• OSHA counts calendar days away from work, starting the day after the injury, and lets you cap the count at 180 days. Workers' comp counts lost time under the state's waiting period and benefit rules. The numbers on the log and in the claim file will not match, and they are not supposed to.

Forms 300, 300A and 301: Who Keeps Them and for How Long

Who must keep them

Most employers with more than 10 employees must keep OSHA injury and illness records. Two partial exemptions apply:

• Size: a company that had 10 or fewer employees at all times during the last calendar year is exempt from routine recordkeeping (29 CFR 1904.1). The count is company-wide, not per location.
• Industry: establishments classified in an industry listed in Appendix A to Subpart B of Part 1904, mainly lower-hazard retail, service, finance and similar industries, are partially exempt (29 CFR 1904.2). This is decided per establishment.

Partially exempt employers must still report severe injuries to OSHA, and must keep records if OSHA or the Bureau of Labor Statistics tells them in writing to do so.

The three forms

• Form 300, Log of Work-Related Injuries and Illnesses: one line per recordable case, per establishment.
• Form 301, Injury and Illness Incident Report: the detailed report for each recordable case. An equivalent form, such as a workers' comp first report, can be used if it contains the same information, supplemented where needed.
• Form 300A, Summary of Work-Related Injuries and Illnesses: the annual totals, posted and, for some employers, submitted electronically.

Each recordable case must be entered on the 300 Log and 301 within seven calendar days of receiving information that a recordable case occurred (29 CFR 1904.29(b)(3)).

Retention

Keep the 300 Log, the 300A summary and the 301 forms for five years following the end of the calendar year the records cover (29 CFR 1904.33). During that period, update the 300 Log when you learn of new information about a case, such as a change in classification or additional days away.

Workers' comp claim files follow state rules and your insurer's requirements, which are separate. Do not destroy one set on the other's schedule.

Electronic submission

Under 29 CFR 1904.41, establishments with 250 or more employees that must keep records, and establishments with 20 to 249 employees in industries listed in Appendix A to Subpart E, submit Form 300A data electronically each year. Establishments with 100 or more employees in industries listed in Appendix B to Subpart E must also submit Form 300 and 301 data. Submissions are due by March 2 of the year after the year the forms cover.

Severe injury reports

Separately, report a work-related fatality to OSHA within eight hours, and an in-patient hospitalization, amputation or loss of an eye within 24 hours (29 CFR 1904.39). Reporting to your workers' comp carrier does not satisfy this duty.

Posting the 300A Summary (February 1 to April 30)

At the end of each calendar year:

1. Review the 300 Log for completeness and accuracy, and correct any deficiencies.
2. Total the columns on Form 300A. If you had no recordable cases, you still complete and post the summary showing zeros.
3. Have a company executive certify the summary, attesting that they examined the log and reasonably believe the summary is correct and complete.
4. Post it by February 1 in each establishment, where employee notices are customarily posted, and leave it up until April 30.

Workers' comp has its own posting requirements, set by each state, typically a notice telling employees how to report injuries and who the insurer is. Our guide to posting and reporting requirements covers those notices. The two postings are different documents and both may be required.

Keeping the Two Records Consistent Without Merging Them

The goal is consistency of facts, not a single record. Practical steps:

Use one incident intake. Collect the date, time, location, description, body part, treatment and lost-time information once. Use it to complete both the workers' comp first report and the OSHA 301.

Make two separate decisions. Decide OSHA recordability using Part 1904 criteria. Let the claims administrator decide compensability. Document each decision with its reasoning.

Reconcile monthly. Compare the 300 Log with the carrier's loss run. Every lost-time comp claim should have a matching log entry or a documented reason why not (for example, the employee is a temp on another employer's log, or the establishment is partially exempt). Every log entry with days away should have a corresponding claim or a reason why not.

Update both when facts change. A case that started as first aid can turn into medical treatment or days away. Update the log within the retention period, and update the carrier.

Protect privacy. OSHA requires you to withhold names on the log for certain privacy concern cases, such as sexual assault or mental illness, and to give the injured employee and their representatives access to the records under 29 CFR 1904.35. Keep medical details in the claim file confidential as well.

Don't discourage reporting. OSHA's rule prohibits discharging or discriminating against an employee for reporting a work-related injury or illness (29 CFR 1904.35(b)(1)(iv)). Incentive programs or post-injury policies that deter reports can violate it, and they undermine both records.

For definitions of terms like "days away," "restricted work" and "first aid," see our glossary of OSHA and safety terms.

Build Confidence in Both Systems

Recordkeeping errors and claim delays usually trace back to the same cause: someone treating OSHA and workers' comp as one process. Our workers' comp training for HR covers the basics. The Workers' Compensation Training & Certification program goes deeper on identifying and reporting injuries and occupational illnesses, the claims process, safety and injury prevention, and injury and employment records, in a self-paced online course with an optional exam for the Certified Workers' Compensation Administrator credential.

Frequently Asked Questions

What are the OSHA 300 log requirements?

Employers covered by OSHA recordkeeping must record each work-related, new injury or illness that meets the criteria in 29 CFR 1904.7 on the Form 300 Log within seven calendar days, complete a Form 301 or equivalent for each case, total the year on Form 300A, have a company executive certify it, post it from February 1 to April 30, and keep all three forms for five years after the end of the year they cover.

Does every workers' comp claim go on the OSHA 300 log?

No. A comp claim for first-aid-level care or a diagnostic-only visit is usually not recordable. A claim for a temporary worker may belong on the log of the employer that supervises them day to day. Partially exempt employers keep no routine log at all. Conversely, some recordable cases are denied by the comp insurer. Make each decision on its own criteria.

Who is exempt from keeping an OSHA 300 log?

Two groups are partially exempt. Companies with 10 or fewer employees at all times during the last calendar year, counted company-wide, and establishments in lower-hazard industries listed in Appendix A to Subpart B of 29 CFR Part 1904. Exempt employers must still report fatalities, in-patient hospitalizations, amputations and eye losses to OSHA, and must keep records if OSHA or BLS asks them in writing.

When must the OSHA 300A be posted?

By February 1 of the year after the year the records cover, and it must stay up until April 30. Post it in each establishment where employee notices are usually posted. A company executive must certify the summary before posting. If you had no recordable cases, post the 300A anyway, showing zeros.

Can a workers' comp form replace the OSHA 301?

Yes, if it is equivalent: it must contain the same information as the 301, be as readable and understandable, and be completed using the same instructions. Many employers use their workers' comp first report and add a short supplement for any OSHA fields it lacks. The 301 or equivalent must be completed within seven calendar days.

How long must OSHA 300 logs be kept?

Five years following the end of the calendar year the records cover. The 300 Log, the 300A summary and the 301 forms all fall under this rule. During the retention period, update the 300 Log if you learn new information about a case. Workers' comp claim files have separate retention rules set by state law and your insurer.

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