The OSHA 300 Log: A 5-Minute Guide to Recordkeeping for Small Clinics (29 CFR § 1904.29)

Small healthcare clinics are not immune from workplace injuries, and OSHA requires many employers to maintain the OSHA 300 Log of Work-Related Injuries and Illnesses under 29 CFR § 1904.29. Even small practices must know whether they are required to complete, certify, and retain this log. Failing to comply can lead to penalties, data inaccuracies, and reputational damage. This guide provides a straightforward explanation of the 300 Log, outlining when it applies, how to complete it, and simple steps to stay compliant with minimal resources.

For small clinics juggling patient care, billing, and compliance, OSHA record keeping may feel like one more burden. Yet accurate workplace injury and illness records are essential to protecting staff, reducing risks, and demonstrating regulatory compliance. 29 CFR § 1904.29 requires certain employers to maintain the OSHA 300 Log and related forms (300A and 301). While some very small practices are exempt based on size or industry classification, many medical offices fall under OSHA’s requirements. Clinics that fail to maintain proper records may face fines and scrutiny during inspections.

Understanding the OSHA 300 Log Under 29 CFR § 1904.29

The OSHA 300 Log is a standardized form used to record work-related injuries and illnesses. Under § 1904.29, employers required to keep records must:

• Record each work-related injury or illness on the OSHA 300 Log within seven calendar days of receiving information (29 CFR §1904.29(b)(3)).

• Use a separate OSHA 301 Incident Report (or equivalent) to provide details of each case (29 CFR §1904.29(b)(2)).

• Post a completed OSHA 300A Summary annually from February 1 to April 30 in a visible workplace location (29 CFR §1904.32(b)(5)).

• Retain records for five years (29 CFR §1904.33(a)).

This rule ensures that OSHA can monitor workplace safety trends and that employers can identify recurring hazards. For clinics, compliance not only satisfies regulators but also strengthens staff trust.

The OCR’s Authority in OSHA Record keeping

While OSHA enforces injury and illness record keeping, the Office for Civil Rights (OCR) under HHS may become involved when injury records inadvertently contain protected health information (PHI) about patients. For example, including patient names in staff injury narratives could violate HIPAA rules. Thus, small practices must balance accurate OSHA documentation with HIPAA safeguards, ensuring only employee details appear in records.

Step 1: Determine If You Must Keep the Log

• Clinics with more than 10 employees generally must maintain the OSHA 300 Log, unless classified as a partially exempt industry.

• Verify industry classification using OSHA’s exemption list.

Step 2: Set Up the 300 Log and Related Forms

• Download OSHA Forms 300, 300A, and 301 from OSHA’s website.

• Assign a staff member (office manager or compliance officer) to manage entries.

Step 3: Record Injuries and Illnesses Promptly

• Log any work-related incidents involving medical treatment beyond first aid, days away from work, restricted duty, or loss of consciousness.

• Enter cases within seven calendar days.

Step 4: Certify and Post the 300A Summary

• At year-end, complete the OSHA 300A Summary.

• A clinic owner or practice administrator must sign the form certifying its accuracy.

• Post the summary visibly from February 1–April 30 each year.

Step 5: Retain and Update Records

• Keep logs for five years.

• Update logs if cases change (e.g., more days off work than initially recorded).

For certain sensitive cases such as HIV infection, sexual assault, mental illness, or other conditions where employee privacy must be protected, employers must record the case as a ‘privacy case’ without listing the employee’s name. This requirement ensures confidentiality while maintaining compliance (29 CFR §1904.29(b)(6)–(9)).

A primary care clinic with 12 employees experienced two sharps-related injuries in a single year. Because the clinic did not maintain an OSHA 300 Log, inspectors issued a citation and $7,000 fine. Beyond the fine, the lack of record keeping raised concerns about whether staff were properly trained on sharps disposal. By contrast, another clinic of similar size kept up-to-date OSHA 300 and 301 forms, which demonstrated proactive safety management. Their logs helped identify recurring risks, leading to the adoption of safer needle devices and improved compliance.

• Assuming small size means exemption. Clinics with more than 10 employees must usually keep logs unless industry-exempt.

• Incomplete entries. Failing to record all required details on OSHA 301 can trigger citations.

• Late postings. Forgetting to post the 300A Summary each February through April is a common violation.

• Discarding records early. OSHA requires a five-year retention period.

• Mixing patient data with employee data. Including PHI creates dual compliance risks with HIPAA.

Avoiding these mistakes reduces both financial penalties and regulatory scrutiny.

Best Practices for OSHA 300 Log Compliance

• Assign a single compliance lead to oversee record keeping.

• Use OSHA’s electronic submission system if required by size and industry.

• Conduct quarterly reviews of the 300 Log to identify safety trends.

• Train supervisors to recognize which incidents are recordable, versus first aid only.

• Keep digital and paper backups of logs.

Beyond forms and deadlines, compliance depends on staff engagement. Small clinics should:

• Integrate safety reporting into daily routines.

• Encourage staff to immediately report injuries without fear of retaliation.

• Review OSHA logs in staff meetings to highlight lessons learned.

• Emphasize that record keeping is not about blame but about prevention.

Embedding these practices makes compliance routine rather than reactive.

Summary. The OSHA 300 Log under 29 CFR § 1904.29 is a critical compliance requirement for many small clinics. By understanding when the rule applies, recording cases promptly, and posting the 300A Summary annually, clinics can remain compliant and use the data to improve workplace safety.

Advisers (Affordable, Practical Tools).

• Free OSHA consultation programs help clinics verify record keeping requirements without risk of penalty.

• Compliance software or simple spreadsheet tools can simplify entries, reminders, and report generation.

• Government resources such as OSHA’s Recordkeeping Handbook and small business guides provide free templates and explanations. 

Next Steps. Clinics should immediately determine if they are exempt under § 1904.29, set up a binder or digital file for OSHA forms, and assign a compliance lead. Within 30 days, complete a mock review of past incidents to verify compliance.

To further strengthen your compliance posture, consider using a compliance regulatory tool. These platforms help track and manage requirements, provide ongoing risk assessments, and keep you audit-ready by identifying vulnerabilities before they become liabilities, demonstrating a proactive approach to regulators, payers, and patients alike.

• 29 CFR § 1904.29 — Forms, Recording Criteria, and Instructions

• 29 CFR § 1904.32 — Annual Summary Requirements

• 29 CFR § 1904.33 — Retention and Updating

• OSHA Recordkeeping and Reporting Requirements
  

• OSHA Small Business Assistance