OSHA Form 301: The incident report behind the log

Most occupational health teams are fluent in the OSHA 300 Log and the 300A Summary. The third form gets less attention, is asked for more often than people expect, and is the one most likely to be incomplete when it is.

The short answer

One 301 per case on your log, due within seven calendar days of learning that a recordable work-related injury or illness occurred, the same window as the log entry itself. Four narrative fields carry it: what the employee was doing just before, what happened, the injury and the body part, and the object or substance that caused the harm. An equivalent form is acceptable provided it captures the same information.

Form 301 is the Injury and Illness Incident Report: one form for every case that appears on your log.

What it is for

The 300 Log is a register. Each recordable case gets one line, enough to see the shape of a year, not enough to understand any individual case. Form 301 is the detail behind that line: what happened, what the employee was doing, what object or exposure caused the harm.

When a regulator, an insurer or an attorney asks about a specific case, this is the document they are asking for.

When is Form 301 due?

Within seven calendar days of learning that a recordable work-related injury or illness has occurred. That is the same window as entering the case on the log, and it is short enough that "we will complete it properly later" is usually how a form ends up permanently thin.

What has to be on it

Beyond the identifying details, four narrative fields do the real work, and they are the ones most often left vague:

• What was the employee doing just before the incident? The activity, not the job title.
• What happened? The sequence of events.
• What was the injury or illness? The specific part of the body and the nature of the harm.
• What object or substance directly harmed the employee? The proximate cause.

"Employee injured back" answers none of these. "Employee was transferring a patient from bed to chair without the lift, felt sudden lower back pain while taking the patient's weight" answers all four, and takes the same thirty seconds to write if you write it at the time.

Can we use our own form instead?

Yes. An equivalent form is acceptable provided it captures the same information. Many organizations use a workers' compensation first report of injury, which typically satisfies the requirement because it collects at least as much detail.

Two cautions. Check that your substitute actually covers all four narrative fields, some carrier forms are lighter on the sequence of events than OSHA expects. And make sure the substitute is retained for the OSHA period, not the carrier's, which may be shorter.

How long must it be kept?

Five years following the end of the calendar year the record covers, the same retention as the log and the annual summary.

Note this is much shorter than the retention for employee exposure and medical records under 1910.1020, which runs to thirty years for exposure records. The two are different regimes and conflating them is a common and expensive filing error in both directions.

Privacy cases

For a privacy concern case, the employee's name is left off the log and replaced with a case number. The 301 still exists and still identifies the person; it is the log that is anonymized, and a separate confidential list links the case numbers to names.

People sometimes anonymize the 301 as well, which defeats its purpose. The form is the record; the log is the register.

A whole year at once

If a regulator asks for a year of incident reports, they mean every recordable case, each on its own form, in a form they can read. Producing that from a system that stores the underlying records is a query. Producing it from a filing cabinet in February is somebody's week.

The practical test

Take any line on last year's log at random and try to answer, from the 301 alone, what the person was doing and what harmed them. If you cannot, the form is thin, and it is thin in the way that only becomes visible when it matters.