As we welcome 2026, we recognize the 25th anniversary of OSHA’s Recordkeeping and Reporting standard, 29 CFR 1904. This important standard clarified recordkeeping requirements, added categories of injuries including privacy cases and hearing loss, and increased the involvement of employees themselves. There have been a few additional revisions over the years and overall, the standard has improved transparency and raised awareness of hazards– a crucial factor in creating safe workplaces.

Prior to 2001, employers tracked and documented workplace illness and injury cases on an OSHA 200 log, but the new requirements introduced 3 revised documents. The OSHA 300 log is used to document all recordable injuries and illness. The accompanying 300A is a year-end summary while the 301 Injury and Illness Report identifies the causes and circumstances of recordable injuries.

It should be noted that some states operate their own OSHA plans and may require different forms. However, state documentation must be at least equivalent to federal OSHA requirements. Because many states use different numbering systems, employers should take care to confirm which forms apply to their operations.

OSHA’s 29 CFR 1904 is unique in several ways. 

An uncommon strategy is the use of appendices within the regulations’ subparts. These initially identified partially exempt businesses with lower hazards and have expanded to identify the types and sizes of companies required to electronically submit records through the Injury Tracking Application (ITA).

Unlike most OSHA regulations, this standard is presented in a question-and-answer format. This approach, used only a few times in other regulations, makes the content easier to understand and helps reduce the confusion that often comes with legal jargon.

A few of the most frequently asked questions and their answers are listed below:

1) What is the "work environment"? 

OSHA defines the work environment as "the establishment and other locations where one or more employees are working or are present as a condition of their employment. The work environment includes not only physical locations, but also the equipment or materials used by the employee during the course of his or her work." (https://www.osha.gov/laws-regs/interlinking/standards/1904.5(b)(1))

2) How do I handle a case if it is not obvious whether the precipitating event or exposure occurred in the work environment or occurred away from work? 

In these situations, you must evaluate the employee's work duties and environment to decide whether or not one or more events or exposures in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing condition. (https://www.osha.gov/laws-regs/interlinking/standards/1904.5(b)(3))

3) How do I count weekends, holidays, or other days the employee would not have worked anyway?

You must count the number of calendar days the employee was unable to work as a result of the injury or illness, regardless of whether or not the employee was scheduled to work on those day(s). Weekend days, holidays, vacation days or other days off are included in the total number of days recorded if the employee would not have been able to work on those days because of a work-related injury or illness. (https://www.osha.gov/laws-regs/interlinking/standards/1904.7(b)(3)) 

Even after 25 years, OSHA’s Recordkeeping and Reporting standard remains a vital tool for ensuring accurate documentation, promoting greater transparency, and helping employers identify hazards and prevent injuries to create safer, healthier workplaces.

MEMIC policyholders who have questions about required forms or wishing to learn more about the basics of OSHA Recordkeeping and Reporting can register for our free webinar on January 14, 2026:  Master the Basics: OSHA Recordkeeping and Reporting Requirements. 

Related MEMIC resources: 

Blogs: 

• OSHA Recordkeeping Part 1: Who, How, What, When and Why? Oh My!
• OSHA Recordkeeping Part 2: New Year, New OSHA Log
• OSHA Recordkeeping Part 3: Timing is Everything

MEMIC Webinars on Demand found on our New Safety Director: 

• OSHA’s Recordkeeping Changes for 2024
• OSHA Reporting & Recordkeeping: A Deep Dive into OSHA 300 logs