Software used to generate Equivalent OSHA Forms 300 and 300A

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

April 29, 2025

Lauren Mink, CEM
Veoci, Inc.
195 Church Street, 14th Floor
New Haven, CT 06510

Dear Ms. Mink:

Thank you for your letter to the Occupational Safety and Health Administration (OSHA) regarding the recordkeeping regulation contained in 29 CFR Part 1904 – Recording and Reporting Occupational Injuries and Illnesses. Specifically, you request clarification concerning the acceptability of documents generated by software to be used as a substitute for the OSHA recordkeeping forms.

May I use a different form as an acceptable substitute for the OSHA Form 300-A Annual Summary?

Frequently Asked Questions

Question: May I use a different form as an acceptable substitute for the OSHA Form 300-A Annual Summary?

Answer:

You may only use a different form if it is an equivalent form. Under paragraph 1904.29(b)(4), an equivalent form is one that has the same information, is as readable and understandable, and is completed using the same instructions as the OSHA form it replaces. Under paragraph 1904.32(b)(2)(iii), if you use an equivalent form to replace the OSHA 300-A Annual Summary, it must also include the employee access and employer penalty statements found on the OSHA 300–A Summary form. Equivalent forms can be maintained in any file format (e.g., Excel, CSV) provided that these requirements are met. However, equivalent forms used as a substitute for the OSHA Form 300-A Annual Summary must also be certified and posted annually as required under paragraph 1904.32.

Massachusetts State Plan for State and Local Government Employers; Initial Approval Determination

  • Publication Date:
  • Publication Type:
  • Fed Register #:
    87:50766-50776
  • Title:
[Federal Register Volume 87, Number 159 (Thursday, August 18, 2022)]
[Rules and Regulations]
[Pages 50766-50776]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2022-17803]


=======================================================================
-----------------------------------------------------------------------

DEPARTMENT OF LABOR

Occupational Safety and Health Administration

29 CFR Part 1956

[Docket No.

If employers electronically post the OSHA 300-A Summary of Work-related Injuries and Illnesses, are they in compliance with the posting requirements of 1904.32 (b) (5)?

Frequently Asked Questions

Question: If employers electronically post the OSHA 300-A Summary of Work-related Injuries and Illnesses, are they in compliance with the posting requirements of 1904.32 (b) (5)?

Answer:

No. The recordkeeping rule allows all forms to be kept on computer equipment or at an alternate location, as long as the employer can produce the data when needed. Section 1904.32 (b) (5), requires employers to post a copy of the Annual Summary in each establishment, where notices are normally posted [see 1904.32(a)], no later than February 1 of the year following the year covered by the records and kept in place until April 30. Only the OSHA 300-A Summary form should be posted.

If an employer has no recordable cases for the year, is an OSHA 300-A, Annual Summary, still required to be completed, certified and posted?

Frequently Asked Questions

Question: If an employer has no recordable cases for the year, is an OSHA 300-A, Annual Summary, still required to be completed, certified and posted?

Answer:

Yes. After the end of the year, employers must review the Log to verify its accuracy, summarize the 300 Log information on the 300A summary form, and certify the summary (a company executive must sign the certification). This information must then be posted for three months, from February 1 to April 30.

How do I calculate the "total hours worked" on my annual summary when I have both hourly and temporary workers?

Frequently Asked Questions

Question: How do I calculate the "total hours worked" on my annual summary when I have both hourly and temporary workers?

Answer:

To calculate the total hours worked by all employees, include the hours worked by salaried, hourly, part-time and seasonal workers, as well as hours worked by other workers you supervise (e.g., workers supplied by a temporary help service). Do not include vacation, sick leave, holidays, or any other non-work time even if employees were paid for it. If your establishment keeps records of only the hours paid or if you have employees who are not paid by the hour, you must estimate the hours that the employees actually worked.

OSHA Standards and Regulations; Corrections

  • Publication Date:
  • Publication Type:
  • Fed Register #:
    85:8726-8746
  • Title:
    OSHA Standards and Regulations; Corrections
[Federal Register Volume 85, Number 32 (Tuesday, February 18, 2020)]
[Rules and Regulations]
[Pages 8726-8746]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-00207]


=======================================================================
-----------------------------------------------------------------------

DEPARTMENT OF LABOR

Occupational Safety and Health Administration

29 CFR Parts 1904, 1910, 1915, 1918, and 1926

[Docket No.

Posting requirements for the OSHA 300 Log and OSHA 300-A Summary Form.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

December 18, 2003

Ms. Alana Greer
American Civil Liberties Union of Florida
4500 Biscayne Boulevard, Suite 340
Miami, FL   33137-3227
Dear Ms. Greer: