OSHA 300 Log for Manufacturers — 2026 Checklist
Quick Answer
All manufacturing establishments with 11 or more employees at any point during the previous calendar year must maintain OSHA 300 Logs. Manufacturing (NAICS codes 31-33) has NO partial exemptions based on industry classification since manufacturing is considered a high-hazard industry. Even establishments with 10 or fewer employees must keep records if OSHA or BLS specifically requests them. Each physical facility maintains its own 300 Log.
Manufacturing is one of OSHA's primary enforcement targets for recordkeeping. Every manufacturing establishment with 11 or more employees must maintain OSHA injury and illness records, and electronic submission requirements have expanded to include detailed case data for larger facilities. This 2026 checklist covers every recording criterion, deadline, posting requirement, and manufacturer-specific scenario you need to know to stay compliant and avoid penalties up to $16,550 per violation.
2026 Key Deadlines for Manufacturers
| Deadline | Task | Duration/Notes |
|---|---|---|
| February 1 | Post Form 300A annual summary in a visible location at each facility | Must remain posted through April 30 |
| March 2 | Submit electronic injury data through OSHA's ITA portal | Covers previous calendar year |
| April 30 | Remove Form 300A from posting (can stay posted longer if desired) | Minimum posting period ends |
| Within 24 hours | Report any fatality to OSHA | From time of death |
| Within 24 hours | Report any amputation, loss of eye, or in-patient hospitalization | From time employer learns of event |
| Within 7 days | Record any new recordable case on Form 300 and complete Form 301 | From date employer learns case is recordable |
Recording Criteria: What Goes on the 300 Log
A work-related injury or illness must be recorded if it results in any of these outcomes:
Manufacturing-Specific Recording Scenarios
Hearing loss (standard threshold shift)
Record on Form 300 if the employee experiences a standard threshold shift (STS) of 10 dB or more averaged at 2000, 3000, and 4000 Hz in either ear, AND the employee's total hearing level is 25 dB or more above audiometric zero averaged at those frequencies. This is common in stamping, metal fabrication, and heavy equipment manufacturing.
Repetitive strain injuries
Record carpal tunnel syndrome, tendonitis, trigger finger, and other musculoskeletal disorders when diagnosed by a physician or LHCP and work-related. These are among the most common recordable cases in assembly manufacturing. Record on the day of diagnosis, not the day of symptom onset.
Chemical exposure illness
Record any illness resulting from exposure to chemicals, fumes, vapors, or particulates (respiratory conditions, dermatitis, chemical burns). Common in painting, coating, welding, and cleaning operations. Some exposures require recording even without an illness if exposure exceeds permissible limits.
Needle-stick injuries (medical device manufacturing)
Record all needle-stick and sharps injuries regardless of whether they result in illness. Maintain a separate sharps injury log with the type and brand of device, department/work area, and explanation of the event.
Pre-existing conditions aggravated by work
If a pre-existing condition (bad back, old injury) is significantly aggravated by work to the point of meeting any recording criterion, it is recordable. A worker whose pre-existing knee condition worsens due to repetitive kneeling to the point of requiring restricted duty is a recordable case.
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Electronic Submission Requirements by Facility Size
250+ employees (at any point during the year)
Must submit Forms 300, 300A, AND 301 data electronically through OSHA's ITA by March 2
20-249 employees in high-hazard industries (all manufacturing)
Must submit Form 300A summary data electronically through OSHA's ITA by March 2
11-19 employees
Must maintain logs but electronic submission not required unless specifically requested by OSHA or BLS
Penalties for Recordkeeping Violations
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Key Takeaways
- All manufacturing establishments with 11+ employees must maintain OSHA 300 Logs with no industry exemptions
- March 2 is the annual electronic submission deadline; missing it triggers penalties and potential SST targeting
- Form 300A must be posted February 1 through April 30 at each facility
- Manufacturing-specific scenarios (hearing loss, repetitive strain, chemical exposure) have distinct recording rules
- Records must be retained for 5 years and updated as cases develop
- FileFlo automates OSHA 300 Log tracking, calculates DART rates, and generates audit-ready reports at $299/month with unlimited facilities
Frequently Asked Questions
All manufacturing establishments with 11 or more employees at any point during the previous calendar year must maintain OSHA 300 Logs. Manufacturing (NAICS codes 31-33) has NO partial exemptions based on industry classification since manufacturing is considered a high-hazard industry. Even establishments with 10 or fewer employees must keep records if OSHA or BLS specifically requests them. Each physical facility maintains its own 300 Log. A manufacturer with 3 plants maintains 3 separate logs.
The submission deadline is March 2 of each year (for the previous calendar year's data). Establishments with 250+ employees at any point during the previous year must submit data from Forms 300, 300A, and 301. Establishments with 20-249 employees in designated high-hazard industries (including all manufacturing) must submit Form 300A data only. Submissions are made through OSHA's Injury Tracking Application (ITA) at osha.gov/injuryreporting. Failure to submit by March 2 can trigger penalties up to $16,550 per form and flag your facility for Site-Specific Targeting (SST) inspections.
Record any work-related injury or illness that results in: death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or diagnosis of a significant injury or illness by a physician or licensed healthcare professional. Manufacturing-specific recording situations include: hearing loss (standard threshold shift of 10 dB or more averaged at 2000, 3000, and 4000 Hz), repetitive strain injuries (carpal tunnel, tendonitis), chemical exposure illnesses, and needle-stick/sharps injuries (if applicable in medical device manufacturing).
OSHA 300 Logs, 301 Incident Reports, and the annual 300A Summary must be retained for 5 years following the end of the calendar year they cover. During the retention period, you must update the logs to reflect newly discovered recordable cases and changes in previously recorded cases (such as additional days away from work). Many manufacturers keep records longer than 5 years for litigation defense and trend analysis. FileFlo's digital recordkeeping automatically retains and updates logs with audit-ready retrieval at $299/month.
DART stands for Days Away, Restricted, or Transferred. It measures the number of recordable cases involving days away from work, restricted work, or job transfer per 100 full-time equivalent workers. The formula is: (number of DART cases x 200,000) / total hours worked. DART rates matter because OSHA uses them for Site-Specific Targeting (SST). If your DART rate exceeds the industry average, your facility may be placed on the SST inspection list. For manufacturing, the average DART rate varies by subsector but typically ranges from 1.5 to 3.5. FileFlo calculates your DART rate automatically from your 300 Log data.
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