The OSHA Recordkeeping Calendar and Deadlines

The OSHA 300 Log doesn't run on the calendar you'd guess from its name. Most of a recordkeeping year's deadlines fall in the first few months of the following year, and two of them don't wait for any date at all. This guide lays out every deadline in one table, each one citing the paragraph it comes from.

The recordkeeping year, one table

The March 2 deadline applies only to the establishments 1904.41 covers — the checker's electronic-submission section sets out the three employee-count and industry thresholds that decide who's in that group; this page states the date but doesn't repeat them.

Two clocks that don't wait for the calendar year

Every other deadline on this page runs from a fixed date. The reporting deadlines in 1904.39 don't: they start running the moment a fatality, hospitalization, amputation or lost eye happens, whatever month that turns out to be. Paragraph (a)(1) sets an 8-hour clock for a fatality, counted from the death itself, and paragraph (a)(2) sets a 24-hour clock for an in-patient hospitalization, an amputation or the loss of an eye, counted from that event. Both clocks report to the same place: OSHA, U.S. Department of Labor.

Both clocks can also start late. If word of the event, or word that it was work-related, doesn't reach the employer right away, the 8 or 24 hours run from when the employer or its agent learns of it, not from the event itself, paragraphs (b)(7) and (b)(8). Either way, the clock is separate from the log: recording a case on the OSHA 300 Log never counts as reporting it under 1904.39, and reporting it never excuses recording it if the establishment is required to keep a log at all. Who has to keep OSHA injury records covers that separate question — an establishment can owe a 1904.39 report even in a year it owes no log.

Certifying and posting run on the same February 1 clock

The annual summary isn't just totaled; it's certified and displayed. Paragraph (b)(6) sets the posting window: "You must post the summary no later than February 1 of the year following the year covered by the records and keep the posting in place until April 30." Certification, under paragraph (b)(3), has to happen before that posting can be accurate: a company executive reviews the OSHA 300 Log and certifies that the summary drawn from it is correct and complete, as paragraph (b)(4) defines who that executive can be. Both steps land inside the same February-to-April window every year, whether or not the establishment ever has to submit anything electronically.

Five years, then the record can go

Retention outlasts the posting window by a wide margin. Paragraph (a) of 1904.33 sets the term: five years following the end of the calendar year the records cover, for the OSHA 300 Log, the privacy case list, the annual summary and the 301 Incident Reports together. During that stretch the log itself isn't frozen — a newly discovered case or a change in an existing case's classification still has to be added or corrected — but the annual summary and the 301 forms, once filed, don't have to be touched again, even though they can be. Run today's totals through the TRIR calculator or the DART rate calculator at any point in that five-year window, and the case counts behind the rate are the same ones the retention rule is holding onto.