Unless exempt, employers are required to maintain certain records that track workplace injury and illness information, including OSHA 300 logs. In general, employers with 10 or fewer employees are exempt, as are certain establishments in specific low-hazard industries.

Under the new rule, employers with ten or fewer employees are still exempt from maintaining injury and illness records. However, OSHA has made changes to the industries that are specifically exempt from maintaining records.

Under the prior rule, numerous low-hazard industries were exempt based on the Standard Industrial Classification, or “SIC,” classification. The new rule uses a classification system based on the North America Industry Classification System, or “NAICS.”

This change is estimated to require approximately 200,000 establishments that were previously except to now keep records. Likewise, the change will also result in approximately 160,000 establishments now being exempt from OSHA’s record-keeping requirements.


Employers should review their NAICS code and determine whether or not they will be required to keep injury and illness records. A list of the industries that will now be required to maintain OSHA records can be found here.

Employers who are now required to keep records should implement new policies and procedures as necessary, and train supervisors on how to properly record an incident.