OSHA recordkeeping citations are not dramatic. There is no collapsed trench or unguarded machine. An inspector simply asks to see your OSHA 300 log, flips through a few pages, and finds that a case was recorded late, a classification is wrong, or the 300A was never posted. These are classified as other-than-serious violations, and they carry fines of up to $16,550 per violation.
That per-violation number matters. A single missing entry is one violation. Five missing entries are five violations. A staffing agency in Austin was recently cited for four recordkeeping violations totaling $38,760 — and the case triggered a broader inspection that uncovered additional serious hazards and $62,400 in further penalties. Recordkeeping errors are often the thread that unravels a larger enforcement action.
Here are the five mistakes that lead to the most citations, and what to do instead.
Mistake 1: Recording Cases After the 7-Day Window
Under 29 CFR 1904.29, employers must record a new injury or illness on the OSHA 300 log within seven calendar days of learning that a recordable case has occurred. Not seven business days — seven calendar days. If an incident happens on a Monday and you find out about it the same day, it must be on the log by the following Monday.
This is one of the most common violations because it is one of the easiest to verify. An inspector compares the date of injury on the 300 log to the date it was entered. If the gap exceeds seven days, it is a citable violation. In practice, many employers do not enter cases until the end of the month, the end of the quarter, or — worst case — when they realize the 300A summary is due in February.
How to Avoid It
Build a process for immediate notification. When a supervisor learns of an injury, they should report it to whoever maintains the OSHA log the same day. The recordability determination and log entry should happen within the seven-day window, even if not all details are available yet. You can always update a log entry later — but the initial entry must be timely.
Mistake 2: Choosing the Wrong Case Classification
Every recordable case on the 300 log must be classified into exactly one of four categories: death, days away from work, job transfer or restriction, or other recordable cases. You check the column that reflects the most serious outcome of the case.
The most frequent classification error is checking "other recordable case" when the employee actually had restricted duty or days away from work. This happens when the person filling out the log does not follow up on the case after the initial entry. An employee goes to the doctor, gets stitches, and is logged as an "other recordable" case. Two days later, the doctor puts the employee on light duty for a week. If the log is not updated, the classification is wrong — and the DART rate calculation is also wrong.
The reverse error also happens: classifying a first-aid-only case as recordable. This inflates your TRIR unnecessarily and can cost you money on insurance premiums and contract bids.
How to Avoid It
Follow each case to its conclusion. A log entry is not final until the employee has fully returned to normal duties. If the outcome changes — restricted duty turns into days away, or an employee initially sent home returns the next day — update the classification. OSHA requires you to cross out the original classification and check the correct column.
Mistake 3: Failing to Post the 300A Summary
The OSHA 300A Annual Summary must be posted in the workplace from February 1 through April 30 every year. It must be displayed in a conspicuous location where notices to employees are customarily posted. And it must be certified — signed by a company executive, not just a safety manager or HR director.
This requirement applies even if you had zero recordable cases during the year. An empty 300A with zeros in every field still needs to be completed, certified, and posted. Failing to post is a separate violation from failing to complete the form, and OSHA inspectors check for both.
The posting requirement is especially easy to miss for employers with multiple establishments. Each physical location needs its own 300A posted on-site. Your corporate headquarters cannot post a single summary for all locations.
How to Avoid It
Set a calendar reminder for January 15 to begin preparing your 300A, and another for February 1 to verify it is posted. Make sure the signer meets OSHA's definition of a company executive: an owner, corporate officer, or the highest-ranking official at the establishment.
Mistake 4: Miscounting Days Away or Restricted Duty Days
When an employee has days away from work or days on restricted duty, you must record the count in columns K and L of the 300 log. The counting rules trip up a lot of employers.
First, do not count the day of the injury. Day counting starts the day after the incident. Second, count calendar days, not work days. If an employee is told to stay home on a Friday and returns the following Monday, that is two days away (Saturday and Sunday), not zero. Third, cap the count at 180 days per case. If a case extends beyond 180 days, you enter 180 and stop counting.
Employers also make errors when an employee is on restricted duty but would not have been scheduled to work anyway. If the employee's normal schedule is Monday through Friday and the restriction applies over the weekend, you still count the weekend days as restricted duty days because the restriction was in effect.
How to Avoid It
Count every calendar day from the day after the injury until the employee returns to full, unrestricted duty — including weekends, holidays, and days the employee was not scheduled to work. Stop at 180.
Mistake 5: Not Retaining Records for Five Years
Under 29 CFR 1904.33, employers must retain OSHA 300 logs, 300A summaries, and 301 incident reports for five years following the end of the calendar year they cover. Your 2025 records, for example, must be kept on file until December 31, 2030.
During that retention period, the 300 log must be updated to reflect any changes — new cases that were reported late, classification changes, or cases that were later determined not to be recordable. The log is a living document for the full five-year window.
This is where paper-based systems fail most often. Binders get lost, pages get misfiled, and when an inspector asks for the 2022 log at an inspection in 2026, nobody can find it. The inability to produce records upon request is itself a citable violation.
How to Avoid It
Store records digitally with reliable backups. Whether you use a dedicated recordkeeping tool or a well-organized shared drive, the key is that any authorized person can retrieve any year's records within minutes. If you use paper, keep copies in a locked, fire-safe location and maintain a digital scan as backup.
A Note on Penalty Reductions for Small Employers
In July 2025, OSHA expanded the penalty reductions available to small businesses. Employers with 25 or fewer employees — previously the threshold was 10 — now qualify for a 70 percent penalty reduction. Employers with 26 to 100 workers qualify for a 30 percent reduction. There is also a new 15 percent reduction for employers that immediately correct a hazard, and a 20 percent reduction for employers with a clean inspection history over the past five years.
These reductions are meaningful, but they only apply if you have a good-faith compliance posture. If OSHA finds numerous recordkeeping violations alongside a high injury rate, or if you have been cited before for the same issues, the reductions disappear. The best penalty reduction strategy is not getting cited in the first place — and that starts with keeping accurate, timely, and complete records.