How to Complete OSHA Form 300A: A Step-by-Step Guide for Healthcare Facilities

If you run occupational health at a hospital or nursing home, learning how to complete OSHA Form 300A matters for one blunt reason: it's the one recordkeeping task with a hard, public deadline attached. Miss the February 1 posting and anyone — including an OSHA inspector — can see the gap on your bulletin board. Once your 300 Log is clean, the 300A itself is mostly transcription and arithmetic. Here's how to do it right, plus the edge cases that trip people up in healthcare settings.

What the 300A is, and whether your facility has to file one

OSHA recordkeeping runs on three forms: the 300 Log (a running list of every recordable case), the 301 Incident Report (the detail behind each case), and the 300A, whose official title is the "Summary of Work-Related Injuries and Illnesses" (OSHA — Recordkeeping Forms). The 300A rolls up a full year of the log into a single posted sheet.

Healthcare is squarely in scope. Hospitals and nursing homes are not on OSHA's list of partially exempt low-hazard industries (29 CFR 1904.2), so any healthcare establishment with more than 10 employees has to keep these records. The only routine off-ramp is the small-employer exemption: 10 or fewer employees at all times during the prior calendar year (29 CFR 1904.1). Even then, every employer — exempt or not — must still report fatalities, in-patient hospitalizations, amputations, and loss of an eye directly to OSHA. Recording and reporting are different obligations.

Step 1: Close out and verify the 300 Log

At the end of each calendar year, 29 CFR 1904.32 requires you to review the 300 Log for completeness and accuracy before you summarize it. This is where the real work is. Check that every needlestick, patient-handling back injury, and workplace-violence case that met the recording criteria actually made it onto the log, and that the case classifications (days away vs. restricted duty) still reflect what happened. The 300A is only as good as the log behind it.

Step 2: What information goes on the 300A

The summary has three blocks.

Establishment info. Facility name and street address (city, state, ZIP), your industry description, and NAICS code.

Employment info. Two figures for the calendar year: the annual average number of employees and the total hours worked by all employees. More on hours below — this is the number people get wrong.

Case totals from the log. You transcribe the column totals from the 300 Log into the "Number of Cases" block:

• Column G — total deaths
• Column H — cases with days away from work
• Column I — cases with job transfer or restriction
• Column J — other recordable cases

You also carry over the "Number of Days" totals — column K (days away from work) and column L (days of job transfer or restriction) — and the injury and illness type breakdown in column M: (1) injuries, (2) skin disorders, (3) respiratory conditions, (4) poisonings, (5) hearing loss, and (6) all other illnesses (OSHA Recordkeeping Forms Package).

One rule that surprises new safety officers: if you had zero recordable cases, you still file. Enter zeros in every column total, certify it, and post it anyway (OSHA FAQ 32-2; 29 CFR 1904.32). A blank clinic year is not a skip year.

Step 3: How to calculate total hours worked

Total hours worked is the sum of the hours actually worked by all covered employees during the year. Per OSHA's own worksheet, include hours worked by salaried, hourly, part-time, and seasonal staff, plus workers under your day-to-day supervision (such as temp-service help) and any overtime. Do not include vacation, sick leave, holidays, or any other non-work time, even if it was paid. If you only track hours paid, or you have staff who aren't paid by the hour, estimate the hours they actually worked (OSHA Recordkeeping Forms Package).

In a hospital this is rarely a single tidy number. Pull it from payroll across all your pay classes — nurses, techs, environmental services, per diem, travelers on your payroll — and be consistent about what counts. This figure does double duty: it feeds your incidence-rate math and it's a required field for the electronic submission.

Step 4: How the incidence rate is calculated

The 300A form itself has no incidence-rate box — but the case counts and hours you just entered are exactly the inputs. The formula is standardized so a 60-bed nursing home and a 900-bed system can be compared on the same scale:

Incidence rate = (number of cases × 200,000) ÷ total hours worked

The 200,000 constant is 100 full-time employees working 40 hours a week, 50 weeks a year (OSHA Standard Interpretation, 2016-08-23; BLS — Compute Your Incidence Rate).

Two rates matter most:

• Total recordable case rate (often called TRIR) — OSHA's worksheet computes the total case count by summing columns H + I + J from the 300A, then applies the formula (OSHA Recordkeeping Forms Package). Deaths (column G) are counted and reported separately on the form; they are rare, and OSHA's published worksheet does not fold them into this rate.
• DART (days away, restricted, or transferred) uses only the more serious cases: (Column H + Column I) × 200,000 ÷ hours worked (OSHA Standard Interpretation, 2016-08-23).

DART is the number your workers' comp carrier and your CNO will ask about, because it isolates injuries serious enough to keep someone off the floor or on light duty.

Step 5: Who must certify the 300A

Not just anyone can sign. Under 29 CFR 1904.32(b)(4), the certifier must be a company executive, defined narrowly as one of four people:

1. An owner (sole proprietorship or partnership only)
2. An officer of the corporation
3. The highest-ranking company official working at the establishment
4. That official's immediate supervisor

For most hospitals that's the facility administrator or CEO — not the safety coordinator who prepared it. By signing, the executive attests they examined the 300 Log and reasonably believe the summary is correct and complete. An electronic signature is acceptable (OSHA Standard Interpretation, 2009-01-29).

Step 6: Post it — and don't touch it

Post the certified 300A no later than February 1 and keep it up through April 30 — a full three months — in a conspicuous spot where you normally put employee notices (29 CFR 1904.32). Don't let it get altered, defaced, or buried under the parking policy. In a multi-site system, each establishment posts its own.

Step 7: Submit electronically through the ITA

Posting isn't the end. Hospitals, nursing and residential care facilities, and other ambulatory health services appear on OSHA's Appendix A list, so establishments with 20–249 employees in those NAICS codes must submit their 300A data electronically (29 CFR 1904.41; OSHA — NAICS for electronic submission). Establishments with 250+ employees in any record-keeping industry also submit the 300A, and those with 100+ employees in the higher-hazard industries on OSHA's Appendix B list must additionally submit their 300 and 301 data — a tier that reaches beyond most healthcare settings. The annual deadline through the Injury Tracking Application (ITA) is March 2 for the prior year's data (OSHA — ITA FAQs).

Step 8: Keep the records for five years

Retain the 300 Log, the privacy case list, the 300A, and the 301 forms for five years after the calendar year they cover (29 CFR 1904.33). During that window, if a case is newly discovered or reclassified, update the 300 Log — not the posted 300A or the 301s.

FAQ

Do we file a 300A if no one got hurt all year? Yes. Complete it with zeros in every total, certify it, and post it (OSHA FAQ 32-2).

Can our safety officer certify the form? Only if they're one of the four executives named in 1904.32(b)(4). They can prepare it, but an owner, corporate officer, the highest-ranking official at the site, or that person's supervisor has to certify.

What does an error cost? For 2026, OSHA is holding at 2025 penalty levels: up to $16,550 per serious or other-than-serious violation and up to $165,514 per willful or repeat violation (OSHA — 2026 Penalty Adjustments).

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Before you finalize, check the current downloadable 300A and its instructions for the year you're filing, and confirm your State Plan rules — state programs must be at least as effective as federal OSHA but can differ in the details. If you're tired of transcribing column totals by hand each January, platforms built for occupational health — carefoundryESC included — can generate the 300 Log and 300A straight from your incident records. Either way, get the log clean first; the summary takes care of itself once it is.