2.2 The 301, equivalent forms and multiple establishments
The 300 Log says a case happened. The OSHA 301 Injury and Illness Incident Report says what happened. One 301 is completed for every recordable case on the log, within the same seven calendar days — and most employers never fill one in, because they use an insurance form instead. That is allowed, and 1904.29(b)(4) sets the conditions.
1 Eighteen fields, in three groups
The 301 is a one-page form and its structure is worth knowing even if you never use the OSHA version, because an equivalent form has to carry the same information.
| Group | Fields |
|---|---|
| Information about the employee | Full name; street, city, state, ZIP; date of birth; date hired; sex |
| Information about the physician or other health care professional | Name; where treatment was given if away from the worksite; whether the employee was treated in an emergency room; whether the employee was hospitalized overnight as an in-patient |
| Information about the case | Case number from the log; date of injury or illness; time the employee began work; time of the event; what the employee was doing just before it; what happened; what the injury or illness was; what object or substance directly harmed the employee; and, if the employee died, the date of death |
Two of those fields are quietly useful. Time employee began work and time of event, taken together across a year, tell you whether your injuries cluster in the first hour of a shift or the tenth — which is a fatigue and a scheduling question, not a safety-awareness one. Very few employers ever look.
2 Write fields 14 to 17 the way the form asks
The four narrative fields carry the value, and the form gives examples that set the standard:
- 14 — What was the employee doing just before the incident? Describe the activity and the tools, equipment or material in use. Be specific. The form's examples: “climbing a ladder while carrying roofing materials”; “spraying chlorine from hand sprayer”.
- 15 — What happened? How the injury occurred. “When ladder slipped on wet floor, worker fell 20 feet”; “Worker developed soreness in wrist over time”.
- 16 — What was the injury or illness? The part of the body and how it was affected. “strained back”; “chemical burn, hand”; “carpal tunnel syndrome”.
- 17 — What object or substance directly harmed the employee? “concrete floor”; “chlorine”; “radial arm saw”. Leave it blank if nothing applies.
The current form adds a note against those four fields: do not include personally identifiable information about the workers involved — no names, phone numbers or Social Security numbers. That is there because those fields are the ones an authorized employee representative is entitled to see, and the ones that travel when the data is submitted electronically.
3 Equivalent forms: what actually qualifies
1904.29(b)(4) defines an equivalent form as one that “has the same information, is as readable and understandable, and is completed using the same instructions as the OSHA form it replaces”. Many employers use a workers' compensation first report of injury and supplement it with the fields OSHA asks for that the insurance form omits.
Three things go wrong with that in practice. The insurance form often has no field for the time the employee began work. It often asks what body part was injured but not what object caused it. And it is frequently completed by someone in HR from a phone call, using the claim system's own instructions rather than OSHA's. Any of the three breaks the equivalence.
| Test | What to look for |
|---|---|
| Same information | All eighteen fields present, including time began work, time of event, and the object or substance that directly harmed |
| As readable and understandable | A person who has never seen the form can follow it; no internal claim codes standing in for narrative |
| Same instructions | Completed to OSHA's definitions of work-related, recordable and medical treatment — not to the insurer's |
4 Keeping the 301 for five years, and not updating it
1904.33(a) keeps the 301 for five years following the end of the calendar year it covers — the same period as the log, the summary and the privacy case list. But unlike the log, 1904.33(b)(3) says you are not required to update the 301 Incident Reports, though you may.
That asymmetry makes sense once you see what each form is for. The log is a live classification of cases and has to stay accurate; the 301 is a snapshot of what was known when the case was reported. If your investigation later shows the object that caused the injury was something else, updating the 301 is good practice — and lining out the log entry is a duty.
5 The case number is the thread
- 1Give the case a number when it goes on the log — column A.
- 2Put the same number on the 301, in field 10.
- 3Put the same number on the investigation report, the near miss report it came from, and the corrective action.
- 4For a privacy concern case, the number is also what links the anonymous log line to the confidential list of names.
A consistent case number is the cheapest thing in this whole system and the one that makes an audit take an hour instead of a week.
6 Multiple establishments, one company
Each establishment keeps its own log, its own summary and its own 301s, under 1904.30(a). What a company does on top of that — a consolidated view for management, a group rate, a trend across sites — is entirely up to it and is not regulated. Just do not confuse the two.
The confusion has a cost at benchmark time: the 300A is an establishment document, BLS publishes establishment-level rates, and a company-wide rate compared against an establishment benchmark compares two different things. Part 3 comes back to this, because it is the single most common error in contractor prequalification paperwork.
- One 301 Incident Report for every recordable case on the log, within the same seven calendar days
- The narrative fields 14 to 17 describe the activity, the event, the injury and the object that caused it
- The current form asks you to keep personally identifiable information out of those four fields
- An equivalent form must carry the same information, be as readable, and be completed on OSHA instructions
- The 301 is kept five years and need not be updated; the log must be
- One case number ties the log, the 301, the investigation and the privacy list together
Free educational content — not OSHA-authorized training, no certificate or card issued. Follow your employer's program and the standards cited.