2025 OSHA Year-End Reporting with Amanda Rawls

Today we’re welcoming back Amanda Rawls, Director of EHS Field Services at KPA. Amanda is a seasoned safety professional with over 20 years of experience in the automotive industry and an expert in general industry OSHA compliance. She’s partnered with major national automotive groups and oversees OSHA record keeping and reports for over 1,200 clients each year. Amanda joined us last year to discuss year-end reporting, and we’re thrilled to have her back to talk about what’s changed in 2025 and what companies need to know as they prepare for 2026’s reporting deadlines. Welcome back, Amanda.

Amanda:

Thanks for having me again. Excited to be here.

It’s always great to have you. Let’s jump into those questions. So, last year you walked us through the fundamentals of OSHA record keeping and year-end reporting. For listeners who might be new or need a quick refresher, can you give us sort of a high-level overview of what OSHA year-end reporting entails?

Amanda:

Yeah, I’d love to. And I just love to remind our listeners about the importance of OSHA record keeping requirements. I’m just particularly happy to speak about it now, ahead of the upcoming regulatory deadlines, just so everyone’s feeling a little bit better about accomplishing this task and being sure to set those expectations either for yourself or those you work with.

So, at a high level, OSHA year-end record keeping and reporting does refer to a set of requirements that certain employers must follow to log, summarize, and in some cases, submit work-related injury and illness data for the prior calendar year. There’s going to be three forms we’re going to talk about. I know that sounds a little confusing, but it’s going to be the 301 form, the 300 Log, and the 300A Summary form. So we’ll get into the details of each of those forms, but OSHA year-end record keeping and reporting is generally about five topics.

The first is logging your injuries and illnesses throughout the year using the 301 form and the OSHA 300 Log. We also are going to talk about creating an annual summary of injury and illnesses using the OSHA 300A Summary form. We need to work on posting that 300A form between February 1st to April 30th. The big one that’s going to be coming up is submitting the data electronically, if applicable, which will be due on March 2nd. And lastly, we can’t forget about retaining and updating these record keeping records for five years.

Okay, that’s a great overview. I think that gives a comprehensive look at the things that are required that I know that we’ll jump into more detail later. So, I know that OSHA implemented some significant changes to electronic reporting requirements recently. I’m not entirely sure on the date that they went into effect, so maybe you can update us on that. And can you explain what has changed and who is newly affected by these requirements for electronic reporting?

Amanda:

Sure thing. So this change affected businesses that have 100 or more employees in an industry classification considered a high risk. So OSHA does have these NAICS codes, it’s your National Industry Classification Code, identified in Appendix B. And there’s a lot of those NAICS codes that are identified. So for those businesses, those were the ones that did have a change back in 2024 regarding the amount of record keeping that they were submitting electronically to OSHA.

So for a long time, many industries have been required to submit paperwork, and those businesses that have always been required, at least for the last long while, to at least submit a 300A Summary form are: employers with 250 or more employees in any single establishment, and also employers with between 20 and 249 employees in certain high-risk industries. And they do have those industries listed in Appendix A.

So as of 2024, if your establishment has 100 or more employees and is that high-risk industry listed in Appendix B, then you not only had to submit the 300A form, but also your OSHA 300 Log and your 301 forms as well.

So that sounds like a lot, but if you’re unsure whether you meet those qualifications, you can visit the OSHA website for the ITA Coverage Application. So on that application, if you just enter your state, your employee count, and the NAICS code that pertains to you, it will tell you whether you are required to submit your paperwork electronically to OSHA.

Okay. So that change has been in effect for a little while, at least for some larger companies, and then went into effect for some smaller ones, it sounds like. And I know that I think this is the first full year that these expanded reporting requirements have been in effect. So from your work with these 1,200 clients, what have you observed? How did the first year implementing these things for the companies that now met the requirements? How did it go for them submitting these 300 and 301s electronically?

Amanda:

It went fairly smoothly, to be honest. So those high-risk industries that I mentioned, they were already keeping the details of their OSHA record keeping paperwork. They just weren’t required to submit all of it to OSHA. Now they are. So gathering the data wasn’t new information or a new process for them. They already had it; they had been doing it. The only extra step is that they now had to submit those additional forms through the ITA website. So that change really wasn’t too painful for them.

Now that more detailed injury information is being submitted, what we have seen from OSHA is an increased focus on data-driven inspection. Meaning that OSHA is using the submitted injury data to target its audits and inspections. So this is directly linked to the electronic submission of the 300 logs, the 300A summary form, and those 301 forms, which just allow for a more detailed analysis of trends and risk factors by industry code.

So consequently, employers are seeing higher scrutiny, potential inspections based on injury rates, and increased pressure to ensure both accurate record keeping and proactive safety improvements to avoid penalties and reputational damage.

So it sounds like for the most part, it went smoothly and it’s kind of a good thing for everyone involved. But I know sometimes with things like regulatory requirements, there can be things that are challenging or confusing. So what are some of the most common challenges or mistakes that you’ve seen companies make with these new reporting requirements? Are there any surprises or pain points that have caught these employers off guard?

Amanda:

Yeah, there’s a few. And it’s really common mistakes that almost anyone in industry can make. We’re talking about paperwork, right? So we just need to make sure that the data entry of that paperwork is correct. So before I get to those details, you know, the biggest mistake that anyone can make is just awareness first and foremost. You need to make sure that if you qualify for this regulation or not, and if your industry classification is considered high risk by literally reading through the appendices that would label your industry code. So again, if you’re unsure, if you already know your industry code, if you don’t want to read through that long appendix, all you have to do is again visit that OSHA website for the ITA Coverage Application. It’s just a really easy way to pop in a few bits of information and really feel affirmed whether this regulation is going to apply to you or not.

So if you’ve done that and it’s like, “Yep, I need to do this,” you’ll want to screen for those common mistakes that do come from the paperwork that I mentioned. So a few of the top OSHA record keeping mistakes are:

Number one: Misclassifying cases as recordable or non-recordable. This is the number one mistake that the people filling out this paperwork can make. And it’s really just confusing first aid with medical treatment. You really need to understand the definition of first aid and what’s beyond first aid to recognize whether this is going to be a recordable entry for your 300 Log. Prescription medication is just an easy example of that. If an employee takes even one prescription pill, then that makes that case recordable. So again, just understanding and recognizing that is going to be important to whether that’s a recordable case or not.

Other mistakes that can happen is just incorrectly determining work-relatedness. Employers often fail to record cases that are work-related because symptoms appear off-site or after a shift. Or they could incorrectly record cases that are not work-related. Maybe it’s a purely personal medical condition that happened to manifest at work, but it wasn’t aggravated by the work conditions, it was not work-related. Well, if it’s not work-related, then it doesn’t need to be identified as a case on the 300 Log.

Other examples are just missing or incomplete details on all of this paperwork that I mentioned. You could include vague descriptions like “employee injured hand” and not being more specific: was it the left hand or the right hand? Missing specifics about the part of the body affected, like I just mentioned. Also not recording the time that the employee began work before the injury. That’s important; that way we can recognize fatigue analysis if that happened to contribute to the injury.

One of the other mistakes is just incorrectly calculating the days away from work or restricted duty. So that’s a major source of errors. It’s a little tricky to recognize this, but we just need to make sure that number one, you’re counting the calendar days correctly. Forgetting that weekends and holidays must be counted if the restrictions continued through that time. And also recognizing to stop counting at 180 days. So OSHA does say that you can have days away from work or restricted work does cap at 180 days. So on that form, you shouldn’t have anything longer than 180 days.

Couple more examples: Not updating the 300 Log after new information arrives. OSHA does require updates for a revised diagnosis, final outcomes. And you know, if a later determination that a case wasn’t work-related after all, then you need to remember to go back and update that paperwork as well.

There’s other little things like using your internal terms instead of the OSHA categories. Within your workplace, you might just call it “light duty,” but OSHA does call that “restricted work.” Using company severity ratings rather than OSHA severity categories. And recording incidents only if a workers compensation company has accepted the claim. So we just need to remember that these OSHA rules are separate from workers compensation claims.

Okay. Those are some great examples and I think cover a lot of common mistakes that I’ve heard. So that’s super helpful. And I know that when it comes to those types of things, challenges, mistakes, there’s also lots of critical deadlines that come up that can be missed or maybe misinterpreted. So let’s talk about those deadlines. What are some key dates that safety managers and HR professionals need to have on their calendars right now as we head into 2026?

Amanda:

Two dates you need to be circling are February 1st and March 2nd. But let’s just talk overall timeline before that we get to those two specific. Throughout 2025, this year, someone at your facility should be maintaining your OSHA injury and illness forms. So as injuries have occurred, you’re using that 301 form or its equivalent to log the details of the incident. And looking at those 301 forms, if there are any of those cases that are determined to be work-related and OSHA recordable, we’re adding that to the 300 Log as they occur. So that OSHA 300 Log is a running log of all recordable work-related injuries and illnesses.

And types of those recordable cases can include fatalities, days away from work, restricted work or transfer, medical treatment beyond first aid, loss of consciousness, and significant diagnosed injuries and illnesses. So do yourself a favor, keep up with that paperwork of those injuries and illnesses as they occur.

In early January, you’re going to be able to start completing the OSHA 300A Summary. So after December 31st, the calendar year is closed. Employers must finalize the year’s OSHA 300 Log totals and start to complete that 300A Summary form. So on that form, you’re going to start counting up the total number of injuries and illnesses, the total employee hours worked, average number of employees for the establishment, company information, and we will just need a signature from a company executive as well.

So we’re doing that in January because we need to prepare for posting that 300A form starting February 1st. So between February 1st and April 30th, employers must publicly post that form. And it does need to be posted in a location that’s visible to employees. So that could be like a break room or a bulletin board, just anywhere that the employees are naturally used to looking at other signage or company information. That’s exactly the same place where this form should be posted. And you have to remember, even if no injuries occurred: Congratulations, you still have to post that form. Only your information will have a zero with it. But even if it’s zero, you still need to post that form.

So that’s the February 1st deadline. The last one we got to remember is March 2nd. So on March 2nd, if you are required to do so, that is when the deadline is for submitting your record keeping forms electronically to OSHA using that ITA website. So just a quick reminder about who needs to do that: that’s going to be the employers with more than 250 employees, so just one large single establishment, and also employers with between 20 to 249 employees that are categorized within that high-risk industry.

Okay. So we’re having this conversation in December, about two months before the February 1st posting deadline and three months before that March 2nd electronic submission deadline. What should companies be doing right now to prepare? And when is it too late to start?

Amanda:

Right now you need to be confirming that your company has the injury data that you need. Like, have we been recording this all year or not? Actually lay your eyes on those 301 forms and that OSHA 300 Log. Start reviewing the OSHA 300 Log entries to ensure that each case is accurate and meets the definition of recordable. And in particular, start looking at those days away or restricted job duty days. Have they changed? Is it accurate? Does it need to be updated? Have you hit that cap of 180 days already so you don’t need to worry about it? Those are all the questions that you can start to answer now ahead of the deadline. And if your OSHA 300 Log is accurate, then your 300A Summary form is going to be way easier to fill out once we are approaching that deadline of February 1st.

So if the injury data is correct, then you’re really just counting up the entries, which makes it easy. And then all you have to do is identify the average number of employees, the total hours worked by the employees for that entire year, which you can pretty much pull from your payroll software.

So I know that might sound hard, but it is pretty simple math even if you are calculating it on your own. And if you’re thinking “Yuck, ugh, this sounds like such a headache,” and “Is there an app for that?” The answer is yes. So there is lots of safety software out there, including KPA’s Vera Suite or KPA Flex software, that will allow you to record incident information and then auto-populate the information into the OSHA record keeping paperwork. So if you want to just do that and save yourself some heartburn, highly recommended.

So I know you were asking when is it too late? And the short answer is it’s never too late. Even if it’s March 3rd in 2026 and you forgot to do it on the 2nd, my advice is still do it. OSHA wants your information. They do look kindly to those who still made the effort to deliver it. So even if you are a little bit behind, still do it. Ultimately that’s what OSHA is trying to collect, some information that they can better utilize strategically for their needs in the future.

So it sounds like there’s lots of requirements in terms of when things need to be posted, updated, and sent into OSHA. So thanks for going over those. I think that’s a helpful timeline to have. So for companies that are newly required to submit all three of these forms electronically, can you briefly clarify the difference between the 300, the 301, and the 300A? Maybe just talk about the purpose of each and what common confusion that you see around these forms.

Amanda:

Yeah, I love to clarify this because oftentimes people want to overcomplicate or confuse these forms. They all sound the same right now when I’m talking to you, right? And so they just assume it’s a totally overwhelming process, but it’s actually not. Just like anything, if you do a little bit at a time and keep up with this paperwork throughout the year, you have made your job easier before the record keeping reporting season starts, which is going to start after the first of the year.

So you mentioned the three forms and each one builds into the next one. So the first one is that OSHA 301 form. This is your basic injury and illness incident form. If employees are getting hurt on site, you need to document what that injury was or what that illness was. And you can use that OSHA 301 form to do that. You can also use a form from your workers compensation carrier; it’s usually the equivalent. It’s going to at least have the same amount of information from the 301, so you can be comfortable using either version. But just in case a business doesn’t have forms or access to workers comp forms, the government does need to provide one, which is that 301.

So this piece of paper is recording the basic details of the injury or illness for a specific case. Each injury or illness will have a separate 301 form to document those incident details. And you will use this to identify the details of what happened. So this is going to include information about the employee and any medical care that they may have received, and information about the case or, you know, what led to that incident. So you’re going to need to describe what happened and the details of the injury. This form does contain personal information, so you do need to keep it confidential and should not be publicly posted.

So however many injuries you have is the same number of OSHA 301 forms that you should have on record as well. So if you wanted to identify the trends of all those incidents, you’d have to look at all those individual forms, which is kind of a lot of work, which is where that OSHA 300 Log comes in.

So that 300 Log is a list of all recordable work-related injuries and illnesses that occurred in the calendar year. Its purpose is to classify those injuries and illnesses and track the extent and severity of each case using the information that we garnered from that 301 form. So it’s going to have a line item for each incident, and there’s five steps to make sure that you are filling out that 300 Log form correctly.

So step one, easy enough, we do need to identify the employee information like the employee name and their job title. Step two is describing the case or the incident: what was the date of the injury, where did the event occur, and if there is a very short description of the type of injury or illness. Thirdly, towards the right side of that form, you will need to classify the case as either a fatality, days away from work, a job transfer or restriction, or just as an “other” case. And step four, we’re going to identify the number of days that due to that injury or illness the employee did have time away from work or had a job transfer or just a duty restriction. And then the last thing, step five, is to select if that case was an injury or an illness.

And the definition of illness, just so you know, it is pretty broad. That definition does include things like skin disorders, respiratory conditions, poisoning, hearing loss, and other types of illnesses.

So I know that form sounds like a lot of work, but it really isn’t too tough once you actually look at it. And if you already have the right data recorded on your 301 form, it’s really not that hard to transfer it all over. The toughest part is probably step four, and that’s just ensuring that you are calculating the time away from either work, the days away from work, or that restricted activity correctly. So I mentioned that is a common mistake because how you count up the days does include weekends and holidays, etc. There’s a few tricks to that one. So we want to make sure that we are getting that column correct. Also this form does need to be kept up, like I said, throughout the year; not just at the end of the year, but throughout the year as these injuries are occurring. So at any point, OSHA could come in and they’re going to want to request your 300 Log. It’s one of the first things they ask for whenever they are on site. They like to do this because if they are on site for an investigation, this is going to quickly tell them how many injuries or illnesses have occurred in the calendar year and the associated severity to those.

So I know that was a lengthy description. And this form does take the most amount of work to actually put together, but there’s one more to discuss and that’s that 300A Summary form. And as the name implies, this is a summary form that summarizes the injury data collected from that OSHA 300 Log. So it’s a summary of the total number of injury and illnesses for the entire year. It’s going to provide a high-level overview of the workplace’s safety performance for the year. And like I mentioned, this form does need to be posted in a visible location from February 1st to April 30th every year. And that’s so the employees are aware of the safety record. This form will show the total number of cases, the restricted workdays, the days away from work: just the count of the types of injuries that was applicable. And again, it does require a signature for a company executive that can also affirm that the data that’s shown to employees is accurate.

Okay. That is a lot of information. I can see how people get confused over those, but you’re right, it doesn’t have to be confusing. And I think that was super helpful. So you mentioned OSHA visiting and needing that 300 form immediately. So we know that some of this OSHA record keeping often falls on the safety professionals to update these forms and keep them together throughout the year. But I think that HR departments can play a critical role here too. What advice do you have for ensuring the smooth coordination between Safety, HR, and Leadership teams, especially during year-end reporting?

Amanda:

Yeah, I say communication. And just a clear division of expectation and responsibilities is what has to happen. So I know with Safety and HR, the roles, these two roles are just going to share lots of pieces of this process. But when I talk about accountability, who ultimately is going to be filling out the paperwork? Storing the paperwork? Posting the paperwork? Et cetera. So you don’t want two people thinking that the other one is handling it, right? So today as we’re speaking about this ahead of the deadline, let’s confirm it. Let’s make sure that you know, “Hey, next year you’re doing this” or “Hey, next year I’m doing this.” That way these deadlines don’t sneak up on you. You can plan your office time if you’re the person who’s going to be gathering and reviewing this paperwork. And we also need time to ask for signatures ahead of the February 1st deadline as well. So it gets tough to scramble. It’s the beginning of the year. We have a lot to prepare for. We have a lot just going on in general. So this is one more additional task that you do want to make sure you have the time and attention to make sure is accurate.

And you know, a compliance calendar I know is very helpful. And it’s something that I think could help you not only when it comes to year-end reporting, but like you said, updating that OSHA 300 all year long. I could see how that could be something that would fall to the wayside if it’s not top of mind or if it’s not something that, you know, the safety professionals on the team have time for. So even throwing in those dates of like, hey, you know, every Friday, let’s make sure we’re updating that OSHA 300 Log and keeping it up to date.

So you mentioned last year in our episode on the same topic that this data can provide really valuable insights beyond just meeting these regulatory requirements. Can you talk a little bit about how companies can use their year-end reporting process as more of a strategic tool to actually improve their safety programs in 2025, rather than just it being something they have to do to check a box?

Amanda:

Yes. That’s exactly what I was going to say. Companies can turn the year-end OSHA record keeping process from a compliance chore into a strategic engine that directly improves safety performance in 2026. So the key is we got to shift. We got to shift from filling out the forms, to mining the data for patterns, insights, and priorities.

So there’s a couple of different ways to do that. Number one: use the year-end review to identify leading indicators, not just lagging ones. So on those OSHA logs, that is lagging data, but they do reveal a pattern that could point to a leading indicator that you could act on. So as a company, you should be analyzing the recurring injury types. Is it strains? Is it cuts? Is it slips? Injury locations. Is it, you know, which departments? Is it a shift? What time shifts are these injuries occurring? Is it always in the morning? Is it on the last shift? Et cetera. Is there seasonality or workload patterns that could be associated? Or, you know, hire data is in there as well. Is this a new hire? Or is this someone that has been there a while? So you can kind of shift from just “Hey, we had 18 injuries” to “We need to invest in ergonomic controls and welding and overhauling our new hire onboarding process so that people are more aware.”

Other ways to do this is you can also align your findings with your business goals for 2026. So safety data is going to become strategic when it’s tied to cost reduction goals, productivity or throughput targets, turnover, retention challenges, quality concerns, et cetera. So like an example is musculoskeletal injuries. That’s going to drive lost time. Well, if you’re seeing a whole bunch of musculoskeletal injuries, then you can target an ergonomic improvement plan, which ultimately could save you from losing more lost time from your workers.

You can also build a transparent story for leadership. So you can summarize instead of just having everything as a number, which I know we love numbers, but we can summarize those OSHA trends in a format that your leadership team could understand. What’s driving the incidents? What’s improving or declining? What’s it costing the business either directly or indirectly? What are your hidden risks? And when it comes to year-end reporting, it could become a catalyst for budget conversations, staffing decisions, capital project planning, maybe even some training priorities for the upcoming year.

So you can convert the OSHA log data into a safety roadmap if you really are thinking more strategically. So use your 2025 data to set 2026 improvement goals. Maybe you can just start to reduce restricted duty cases in a specific task line. You could increase your near-miss reporting or just improving root cause quality. There’s a way to look at that OSHA data, develop a strategic safety plan, and then have some action items and accountability that can follow up.

I love that. I think you covered what I was going to jump in and say is that when you analyze the safety data, sure, you can pull a lot of information that may be really pertinent to you as a safety leader or pertinent to your safety team. But if there’s ways that you can tie it back to time lost, ROI, things like that, and you come to your leadership, they will see that as an opportunity to help you not only keep your team safer, but to help the business.

Amanda:

Yeah. Like develop some predictive indicators out of this. Even some of this basic OSHA data that they’re collecting, it can inform those predictive metrics. Things that can include just departments with high near-miss to injury ratios, injury trends tied to production levels, times of day with the highest incident rates. All of that is going to help your company implement preventative controls instead of reacting to just the incidents. So in short, year-end OSHA reporting can be transformed from a compliance obligation into a strategic diagnostic tool that drives operational excellence, budget priorities, and meaningful risk reduction.

And hey, it makes you look good if you take your compliance checklist and make it actionable.

Amanda:

Yes. And like I said, like a number is a number. And you know, when you can go down a list, it’s easy to be like, “Hey, Joe, Tom, Sally, these things happen to…” But it’s like, “Hey, remember Joe when he was out for three weeks? Like this is what happened.” Like these are your employees that are accepting some of this risk and may have been injured as a consequence. So turn the numbers into stories. Of course we need to keep everyone’s privacy in mind when it comes to this, but there’s definitely trends and stories that can be shared with the rest of your team. There’s always something to learn, it’s just how are we going to deliver it?

Right. So I think you’ve done a great job of not only giving an overview of what year-end reporting is, how to best tackle it, some of the intricacies of the forms, but also, you know, ways that you can transform it. So as we wrap up, what would you say that your number one piece of advice is for safety managers who are prepping for this year-end reporting? Especially those who may be navigating these expanded requirements for the first or second time?

Amanda:

Number one is to determine whose responsibility it is to take the ownership of this once these deadlines are coming up, which is quickly after the year starts. So that way you can start to prepare. I mean, 2025 isn’t over yet. We still have five weeks to start lining up what needs to be looked at. So you can start reviewing your 300 Log now to make sure that it’s accurate. Once that 300 Log is accurate, it’s pretty easy to do the 300A Summary form. So you’ll make the beginning of next year a little bit easier. But if you don’t know that you’re in charge of it, you’re not going to be taking the time now to evaluate where we are and what your success will be coming up. So definitely identify whether it’s you or someone else on site that is going to take the ownership of this process.

I love that. That is fabulous advice. Thank you so much again for joining us, Amanda. Your practical insights from working with so many clients across these different industries is so invaluable, especially as companies navigate new requirements for the first or second time. So we really appreciate you taking the time to help our listeners prepare for a successful year-end reporting season.

Amanda:

Yeah, of course. My pleasure. Thanks for listening, guys.