OSHA Record-Keeping Best Practices for Public Entities

At the recent Public Risk Management Association (PRIMA) Institute meeting, public entity risk managers, HR leaders and safety professionals gathered in an intimate, classroom-style setting to review OSHA record keeping and regulatory reporting. 

Julie Waller, Alliant Public Entity, led a session titled “OSHA Record Keeping and Regulatory Reporting: A Roadmap for Success,” walking attendees through the rules, forms and real-world scenarios that shape compliance for public entities of every size.

Julie opened the discussion by reinforcing that accurate OSHA record keeping goes beyond compliance—it is a core tool for understanding risk, protecting employees and avoiding costly downstream impacts on premiums, inspections and public perception. Explore the key takeaways from Julie’s session below.

Understanding Record Keeping for OSHA-approved State Plans versus Federal OSHA

For public entities, the first step in record keeping is determining who regulates you. Employers fall under either:

• Federal OSHA
• An OSHA-approved state plan, which must be “at least as effective” as the federal program but can add its own requirements.

Federal OSHA covers most private sector employers and certain federal agencies. In states without an approved plan, public employers—cities, counties, towns, school districts and special districts—are often not covered by OSHA and may instead follow state or local workplace safety rules.

State plan OSHA programs shift this landscape. In the 26 states and territories with approved plans, coverage typically extends to both private and public employers, including:

• State agencies and departments
• Cities and counties
• School districts and utilities
• Transit authorities and special districts

While aligned with federal OSHA, state plans may:

• Adopt different reporting thresholds or exemptions
• Add state-specific forms, deadlines or posting requirements
• Place additional focus on sectors such as public safety or education

Understanding whether your entity is in a federal or state-plan state will impact OSHA record keeping, including what must be recorded, who must be included, and how and when Forms 300 and 300A must be completed, posted and electronically submitted (where required).

3 OSHA Record Keeping Challenges Facing Public Entities

For many organizations, OSHA record keeping is challenging because the work is highly detailed and often delegated to someone without formal training. Common issues include:

• Recording first aid cases that should not appear on the log
• Misunderstanding the difference between a compensable workers’ compensation claim and a recordable OSHA injury
• Confusion around prescriptions, hospitalizations, volunteers and temporary employees
  When records are incorrect, the result can be artificially high incident rates that draw OSHA’s attention and push insurance premiums higher.

Best Practices in OSHA Record Keeping

Strengthening OSHA record keeping starts with building a knowledgeable foundation. Public entities can improve accuracy and consistency by:

• Investing in training: OSHA’s record keeping site and structured learning opportunities provide essential guidance.
• Using real-world examples: Scenario-based learning helps determine what is and isn’t recordable.
• Automating where possible: Digital systems offer prompts, consistency and support for new staff learning the process.
• Respecting the seven-day requirement: Employers have seven days to determine recordability and place the case on the log.

Adhering to these guidelines will help public entities stay compliant and enhance safety measures for their employees.

Understanding OSHA Forms 300 and 300A

To ensure accurate reporting and avoid confusion when record keeping, it is critical that public entities understand the difference between OSHA Forms 300 and 300A.  Form 300 is the detailed log of each recordable case, including days away and restricted duty, while Form 300A is the annual summary posted from February 1 through April 30, without employee names.
When filling out OSHA Forms 300 and 300A, keep the following in mind:

• All OSHA record keeping is based on calendar year, not fiscal year.
• Days away and restricted duty are counted as calendar days, capped at 180.
• The highest-ranking official—not the risk manager—should sign Form 300A to ensure executive visibility of workplace safety trends.

Using the information logged in Forms 300 and 300A, public entities can identify injury and illness trends and implement measures to enhance workplace safety, therefore protecting their employees’ well-being and strengthening the organization’s ability to meet its mission. 

Navigating the OSHA Electronic Injury Tracking Application

In addition to properly logging work-related injuries and illnesses in Forms 300 and 300A, it is essential that public entities understand how to navigate the OSHA Electronic Injury Tracking Application (ITA). Introduced in 2017, the ITA requires eligible employers to electronically submit injury and illness data each year. This adds additional responsibilities for public entities, including:

• Updating logs consistently
• Posting and submitting the 300A summary
• Meeting the March 2 electronic filing deadline
• Responding to OSHA and BLS surveys

For many risk managers, January through July is already the busiest period of the year—making clarity, consistency and planning essential. 

How to turn OSHA Compliance into Culture

Accurate OSHA records do more than satisfy regulators—they support a stronger safety culture. By pairing OSHA logs with loss runs and trend analysis, risk managers can:

• Identify recurring causes of injury
• Target specific departments for training
• Evaluate PPE usage and program effectiveness
• Build better business cases for safety resources

Over time, consistent data use can help reduce frequency and severity of incidents, lower total cost of risk and promote a culture where employees feel protected and informed. Developing a culture around safety can take time, but it starts with accurate data. 

Failing to produce accurate OSHA record keeping can trigger a chain reaction, including:

• Inspections prompted by elevated incident rates
• Citations, fines and budget impacts
• Media attention that damages public trust
• Increased premiums
• Loss of eligibility for state safety award programs

These consequences reinforce the importance of accurate reporting and building a workplace culture that focuses on OSHA compliance and prioritizing everyone’s collective safety. OSHA’s consultative branch remains a valuable, no-penalty resource for entities looking to evaluate areas of concern before issues escalate.

How Alliant Public Entity Helps Ensure OSHA Compliance

OSHA record keeping often involves complex judgment calls and real-time decision making, especially when dealing with hospitalizations, cardiac events, volunteers or temporary workers. However, risk managers don’t need to navigate these situations alone.

At Alliant Public Entity, our team of insurance specialists understand OSHA regulations and how public entities can stay compliant and advance their safety goals. Drawing from decades of industry expertise, we help organizations navigate compliance, reduce costs and build a stronger safety culture that mitigates risk.

Reach out to a specialist from Alliant Public Entity today to strengthen your OSHA record keeping practices and maximize safety outcomes.