An OSHA compliance officer arrives for a programmed inspection and asks to see the Form 300 injury log for the past five years. The cleaning contractor has 18 employees, operates in a state without a state-plan exception, and has never maintained the log. Under 29 CFR 1904, that is a Serious citation for each year of missing records, with a penalty ceiling of $16,550 per violation in 2026. For five years of missing logs, the initial citation package can approach $82,750 before settlement negotiations begin.
The OSHA recordkeeping standard requires covered employers to record work-related injuries and illnesses on Form 300 (the Log of Work-Related Injuries and Illnesses), complete a Form 301 incident report (or equivalent) within 7 days of each recordable incident, and post the Form 300A annual summary from February 1 through April 30 each year. The 2026 Willful or Repeat ceiling is $165,514 per violation for employers who deliberately falsify records or fail to maintain them after receiving a prior citation.
What the Standard Requires
The recordkeeping requirements apply by employer, not by worksite. A BSC with a single administrative location and employees working at 20 client sites maintains one set of records that covers all employees. The records must be maintained for five years following the year the log was created.
| Form | Purpose | Deadline | CFR Reference |
|---|---|---|---|
| Form 300 | Log of Work-Related Injuries and Illnesses; one entry per recordable incident | Within 7 calendar days of receiving information about recordable incident | 1904.29(b)(1) |
| Form 301 | Injury and Illness Incident Report; more detailed information per incident; workers' comp equivalent accepted | Within 7 calendar days | 1904.29(b)(2) |
| Form 300A | Annual Summary; totals from the Form 300 log for the calendar year | Certified and posted Feb 1 through Apr 30 of following year | 1904.32 |
| Severe injury reporting | Fatality: report to OSHA within 8 hours; inpatient hospitalization, amputation, or loss of eye: report within 24 hours | 8 or 24 hours depending on type | 1904.39 |
| Record retention | Maintain Forms 300, 301, and 300A for 5 years following the year they cover | 5 years | 1904.33 |
A work-related injury or illness is recordable if it results in: days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, diagnosis of a significant injury by a healthcare professional, or any of the specific conditions listed at 1904.7(a)(1). First aid cases, as defined at 1904.7(b)(5), are not recordable. The first aid vs. recordable determination is a source of frequent misclassification by small employers.
Who It Applies To
Employers with 10 or fewer employees are partially exempt from routine recordkeeping (they must still report severe injuries under 1904.39). Employers in industries classified as low-hazard under OSHA's industry exemption table are also partially exempt. Janitorial services (NAICS 561720) is not on the exemption list, so BSCs with more than 10 employees are fully covered. The exemption list is at OSHA's industry exemption table.
State-plan states may have equivalent or more stringent recordkeeping requirements. California's Cal/OSHA recordkeeping program under Title 8 CCR Section 14300 mirrors the federal standard and adds requirements for the OIID report form.
What the Inspector Looks At
A programmed OSHA inspection always includes a Form 300 review. The inspector will request the current-year log and logs for the prior four years, verify that recordable incidents in the workers' compensation records match the Form 300 entries, check the Form 300A posting for the current year, and verify that severe injuries were reported within the required timeframes.
| Inspector Check | Common Deficiency | Citation Risk |
|---|---|---|
| Form 300 log | Log not maintained; cases that should be recorded are missing; workers' comp claims not cross-checked | Serious, $16,550 per year |
| Form 301 incident reports | No Form 301 or equivalent for recorded incidents; reports not completed within 7 days | Serious |
| Form 300A posting | Summary not posted from Feb 1 to Apr 30; posted summary not signed by a company executive | Serious |
| Severe injury reporting | Amputation or hospitalization not reported to OSHA within 24 hours; fatality not reported within 8 hours | Serious to Willful |
| Employee access | Employees denied access to Form 300 log covering their establishment upon request | Serious |
| Falsification | Records show cases were deliberately excluded to suppress the DART rate | Willful, $165,514 |
Common Citations and What They Cost
The most frequent recordkeeping citation for cleaning contractors is 1904.29(a): failure to maintain Forms 300 and 301. This is Serious at up to $16,550 per year of missing records. The second most common is 1904.32(b)(3): failure to post the Form 300A annual summary. Where an employer has suppressed recordable cases to maintain a low reported DART rate, OSHA assesses Willful violations at up to $165,514. OSHA cross-checks workers' compensation records against OSHA logs during inspection, and discrepancies between the two are a primary signal of under-recording.
Tradeoffs and Operator Reality
The most common recordkeeping failure pattern in the BSC sector is not intentional falsification but honest confusion about the first aid versus recordable threshold. A cleaning worker who tweaks their back, goes to urgent care for an X-ray and prescription ibuprofen, and returns to work the next day at full duty: recordable or not? The prescription medication makes it recordable under 1904.7(a)(1). A worker who is treated with over-the-counter ibuprofen and a heating pad at the clinic: not recordable under the first aid definition at 1904.7(b)(5)(ii)(A). The distinction is not obvious to a BSC owner who has never studied the standard. The tradeoff: investing in a one-hour annual training on recordkeeping criteria for whoever manages the Form 300 log reduces misclassification errors far more reliably than reacting after an inspection finds five years of missing records.
What to Put in the SOW and Training Matrix
Recordkeeping compliance does not go in the service SOW, but it absolutely belongs in the internal operations manual and training matrix. Every supervisor who receives injury reports from cleaning workers should be trained annually on the recordable criteria at 1904.7 and the Form 300 entry process at 1904.29. The person who certifies the Form 300A must be a company executive as defined in 1904.32(b)(1): an owner, officer, principal, or supervisory employee who has relevant knowledge of the records. The annual certification signature on the Form 300A creates accountability.
Cross-check your Form 300 log against workers' comp claims quarterly. If a claim is filed and the injury is not on the Form 300, investigate the recordability determination before the next inspection. The account profitability auditor can help model the workers' comp experience modification impact of recordable incidents, which provides a financial incentive framework for safety investment beyond just OSHA compliance.
For the underlying safety programs that prevent the incidents generating Form 300 entries, see OSHA PPE 1910.132 for Cleaning Crews and OSHA Walking-Working Surfaces 1910.22. Full compliance reference at Opora Compliance Library.
The OSHA recordkeeping forms page provides downloadable Forms 300, 301, and 300A. The eCFR Part 1904 is the authoritative regulatory source. The DOL OSHA recordkeeping page includes FAQs and injury recording guidance. For industrial cleaning programs where recordkeeping complexity is highest, see the industrial cleaning vertical hub.
By the Opora Editorial Team · Last updated: 2026