A recent standard interpretation letter dated April 29, 2025, addressed whether employers may use software-generated documents in place of the OSHA-required injury and illness recordkeeping forms, specifically Forms 300 (injury log) and 300A (annual summary).
OSHA reaffirmed its long-standing principle that employers may use “equivalent forms” to meet the record keeping requirements under the applicable regulations. However, these forms must contain the same information, must be equally readable and understandable, and also provide similar instructions as the official OHSA forms. Thus, software-generated documents that meet these requirements may serve as valid substitutes.
OSHA also opined that employers have some flexibility in maintaining electronic injury and illness logs, provided they can be printed and made available to government representatives, employees, and their representatives upon request. The interpretation also clarifies that if the requesting party agrees to receive the forms electronically, employers can deliver them digitally.
OSHA also reminded employers that the annal summary must be certified by a company executive and physically posted in the workplace from February 1 through April 30 of the following year covered by the summary and that any substituted form used must also include the employee access to records and employer penalty statement found on the 300A annual summary.
Finally, OSHA restated another long-standing principle that it does not “approve, endorse, recommend, or certify any product or process.” While OSHA supports the use of digital platforms to modernize record-keeping, it stresses that this convenience should not interfere with regulatory compliance. Employers utilizing any digital solution remain responsible for adhering to the strict requirements in appearance, content, usability, and accessibility to ensure it fully aligns with OSHA’s recording and reporting requirements.
The OSHA Chronicle gratefully acknowledges the help of Samantha Schilling, a college intern at Cozen O’Connor, for her assistance in preparing this blog.
