Employer Guide

OSHA Recordkeeping for Oilfield Employers: The 300 Log and the Forms Around It

OSHA injury and illness recordkeeping under 29 CFR 1904 applies to most oilfield employers, from small service companies to larger operators. The rules decide which work injuries and illnesses must be logged, which forms must be kept, and what must be reported to OSHA when something serious happens. The system is not optional paperwork; it is the official record of how the company handles worker safety.

Who must keep records

An employer with 11 or more employees at any time during the calendar year must keep OSHA injury and illness records. The count includes everyone on the payroll, including field crews, mechanics, and office staff. If the crew passes 10 employees for even part of the year, the requirement applies for that year.

Some low-hazard industries are partially exempt from keeping the records, and OSHA publishes the current exemption list. The list changes over time, so the owner should check the current version rather than assume. Even a partially exempt employer still has to report severe cases. Every employer covered by the Occupational Safety and Health Act must report a work-related fatality or a serious hospitalization to OSHA, no matter how small the company.

The three forms

Recordkeeping rests on three forms defined in the regulation:

• Form 300, the Log of Work-Related Injuries and Illnesses, a running list of every recordable case with the employee's job, the injury, and the outcome.
• Form 301, the Injury and Illness Incident Report, one per case, with the details of how the incident happened.
• Form 300A, the Summary of Work-Related Injuries and Illnesses, a year-end total drawn from the log.

The forms work as a set. The log tracks the case, the incident report holds the detail, and the summary shows employees the year's totals at a glance.

What makes a case recordable

A work-related injury or illness is recordable when it meets one of the general criteria in 29 CFR 1904.7:

• Death.
• Days away from work.
• Restricted work activity or a transfer to another job.
• Medical treatment beyond first aid.
• Loss of consciousness.
• A significant injury or illness diagnosed by a physician or another licensed health care professional.

First aid is the line that matters most in the field. OSHA defines first aid as a specific list of actions: cleaning minor cuts or scrapes, applying bandages, using cold compresses, removing splinters, and similar minor care. First aid does not make a case recordable, even when a clinic provides it. Medical treatment does. The distinction is about what the care is, not where it happens.

Posting the summary and keeping records

Form 300A must be posted in a visible workplace location every year from February 1 through April 30. The posted copy covers the previous calendar year, carries the company information, and includes a management signature. The records themselves must be kept for five years after the end of the year they cover.

Some cases get privacy handling. When a case involves an intimate body part or a sexual assault, the employee's name is withheld from the log and the case is described in general terms. The special rules are set out in 29 CFR 1904.29, and a privacy case is still a recordable case, just documented differently.

Reporting severe cases and handling field incidents

Reporting to OSHA is separate from recordkeeping and applies to every covered employer, whatever the size. A work-related fatality must be reported within 8 hours. A work-related in-patient hospitalization, amputation, or loss of an eye must be reported within 24 hours. The clock starts when the employer learns of the event, not when it happened.

Remote locations make this harder for oilfield employers. A lease or a rig is often hours from a clinic, and the office may not learn until the next shift that an employee was hospitalized overnight. The duty still applies. Procedures should make sure the report goes in on time and that field crews know what counts as a reportable event, because the person who spots the problem is usually in the field, not in the office.

Contractor rules decide who records what. Each employer keeps records for its own employees. When an operator and a service company work the same location, each keeps its own log for its own crew, and the case belongs to the employer whose employee was hurt. A contractor's injury is recorded by the contractor, not by the company that hired it.

Field documentation decides how well this works in practice. If the crew cannot capture what happened at the time, the office learns about a recordable case late, when the details have gone cold. New hires should know how to report an injury from day one, which is one more reason to cover incident reporting in the new hire onboarding process, and safety training programs should drill the same message: report early, report in writing, and let the office decide whether the case is recordable.

Keeping the records organized is part of the job. An employer can store the log, the incident reports, and the supporting documents with the job records in software for field tickets, dispatch, approvals, timesheets and documents such as OpsFlo, so the paperwork stays with the job it belongs to and the office can find it when OSHA asks.

Sources and further reading

• OSHA recordkeeping
• 29 CFR 1904.7: General recording criteria
• 29 CFR 1904.29: Forms