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OSHA AND PERRP RECORDKEEPING

  • DRMA
  • Jan 16
  • 3 min read

Submitted By Paul Feck, Sedgewick on Friday, 1/16/2026


As we enter 2026, it’s time to prepare your OSHA (for private employers) and PERRP (for public employers) recordkeeping logs, summaries, and online reports. These records should be updated throughout the year as injuries occur. OSHA and PERRP both require employers to review each injury and determine whether it must be recorded within 7 days of notification.  Below is a reminder of the key recordkeeping deadlines:

  1. OSHA and PERRP Summary forms must be completed and posted by February 1st.

  2. The PERRP online reporting is due February 1st.

  3. The OSHA online reporting is due March 2nd.


First determine if you are exempt from keeping records.


EXEMPTIONS


OSHA - There are two exemptions from keeping the OSHA 300 Log.

  1. Companies with 10 or fewer employees at all times during the calendar year.  The only exception to this is if you are specifically requested by OSHA, the Bureau of Labor Statistics (BLS) or another agency to keep a log.  If you receive a request, do not ignore it.

  2. The other exemption is for establishments classified in certain low-hazard industries.  You will need your NAICS number and check it against the list of “Partially Exempt Industries” here


PERRP - There are no exemptions for public employers for keeping and maintaining the PERRP Log.  All public employers are required to keep the Log.


RECORDKEEPING LOGS AND SUMMARY FORM


OSHA - If you are required to keep the log, download the Recordkeeping Forms and instructions by clicking here.  


PERRP – Download the recordkeeping instructions by clicking here. The logs in Excel format can be downloaded here  under “Forms and Instructions” on the right side of the page.


When you complete your PERRP or OSHA log, be sure to have the summary form signed and posted in a conspicuous place for employees to see.  Summaries must be posted from February 1st through April 30th.


Remember only post the OSHA 300A Summary OR THE PERRP 300AP Summary and not the injury LOG.


ONLINE SUBMISSION


The final step in the process is to determine if you must file online. 


OSHA - To determine if your organization is required to do so, enter the following information for your facility here

  1. “State” in which your facility is located,

  2. “Peak Employment from the previous year” – be sure include temporary and seasonal workers,

  3. “Is the establishment a government facility” and

  4. Your “NAICS Code”.


Once the information is entered, click the “Submit” button and it will identify what, if any, information your facility needs to submit online.  There will be one of four replies:

  1. You are exempt from completing the OSHA Log and not required to submit online.

  2. You will not be required to submit anything online.

  3. You will be required to submit information from your OSHA 300A form. 

  4. You will be required to submit information from your OSHA 300, 300A and 301 Forms.


If your establishment is required to submit information online, new users must first create a secure account through OSHA’s Injury Tracking Application here.  After setting up your account, you can submit your OSHA Log, OSHA 300A Summary or OSHA 301 Injury Information.  For those only required to submit the OSHA 300A Summary, the process is straightforward—just ensure your NAICS code, average number of employees and total work hours are accurately entered on the OSHA 300A Summary report.


If you are required to submit your OSHA 300 and OSHA 301 information you have two options.  You can either choose to input each recordable injury individually or perform a batch upload.  The batch upload can save time for establishments with numerous recordable injuries.


PERRP – All public employers are required to submit to the BWC except those with five or fewer employees and have had no recordable injuries in the calendar year.  PERRP 300AP Summary form information is submitted through Ohio BWC.


One final note, even if you have not completed your logs or online reporting in past years, it is still a good idea to get these completed as soon as possible.  Both OSHA and PERRP recommend creating your logs and submitting your data, if possible, even if you are past the due date – remember better late than never! 

 

If you have any questions regarding your PERRP or OSHA Log or online submission, please contact Andy Sawan, Risk Services Specialist at Sedgwick at andrew.sawan@sedgwick.com or 330-819-4728.


Interested in submitting an article? Email info@daytonrma.org for more information.


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34 Comments


Muhammad Umair
Muhammad Umair
19 hours ago

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lee white
lee white
Jun 22

The legal and regulatory framework underlying this practical compliance guide deserves explicit acknowledgment: OSHA recordkeeping requirements derive from Section 8(c)(2) of the OSH Act, which authorizes OSHA to require employers to maintain accurate records of work-related injuries and illnesses, and the annual submission requirements reflect a data collection function that feeds the Bureau of Labor Statistics' Survey of Occupational Injuries and Illnesses — the primary national dataset for tracking workplace safety trends. PERRP's parallel framework for Ohio public employers reflects the state's decision to extend equivalent protections to public sector workers who are not covered by federal OSHA. Understanding this regulatory architecture helps employers see recordkeeping not as a bureaucratic burden but as participation in a national safety data system…

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lee white
lee white
Jun 22

School districts and other public educational employers are among the most frequently confused by the OSHA/PERRP distinction, and this guide's clear statement that public employers use PERRP rather than OSHA — with no exemptions and a February 1st online submission deadline — is exactly the kind of direct clarification that prevents the common error of school safety coordinators filing with OSHA when they should be filing with BWC. The reminder to post the summary in a conspicuous place for employees to see from February 1st through April 30th is also relevant for school employers, where the "conspicuous place" requirement means the staff break room or main office rather than a location accessible only to administrators. In my school safety work…

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lee white
lee white
Jun 22

The batch upload option for OSHA 300 and 301 submissions is a detail that makes a significant practical difference for construction companies and other high-injury-rate industries where the number of recordable incidents in a year can make individual entry genuinely burdensome. The guide correctly identifies this as a time-saving option without overstating its complexity — it is available, it can help, and establishments with numerous recordable injuries should investigate it. The peak employment figure requirement — including temporary and seasonal workers — is also critically important for construction employers whose workforce fluctuates significantly across the year and who might otherwise undercount their peak employment and incorrectly determine their submission requirements. In my construction safety work I use a squarefootagecalculator for site…

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lee white
lee white
Jun 22

The PERRP-specific guidance in this article is particularly valuable for public sector HR professionals who often receive OSHA-focused compliance information that doesn't fully address their distinct obligations. The key differences are clearly stated: no exemptions for public employers on log maintenance, the February 1st online submission deadline versus OSHA's March 2nd deadline, and the BWC portal as the submission destination rather than OSHA's ITA. The note about the five-or-fewer employee exception for PERRP online submission — available only if there were also no recordable injuries in the calendar year — is a narrow exception that applies to very few public employers but is worth knowing. In my HR compliance work I use a how many days until calculator for regulatory deadline…

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