Closed Establishments and OSHA Record Retention
Closing a site does not end its recordkeeping: keep its logs, privacy list, summaries, and 301s for the full five years and be able to produce them on request.
The answer up front
Closing a site does not end its recordkeeping: keep its logs, privacy list, summaries, and 301s for the full five years and be able to produce them on request. Former employees keep their access rights, so the records need a retrievable home.
Closing a location does not erase the recordkeeping history.
The rule in plain English
Keep the 300 Log, the privacy case list, the 300A, and the 301 reports for five years following the end of the calendar year they cover (29 CFR 1904.33); 2026 records are kept through the end of 2031. During those five years you must keep the 300 Log current: add newly discovered recordable cases and update entries whose classification or outcome changes, lining out the original. Updating the 300A and the 301s is optional. If the business is sold, the seller transfers the records and the buyer keeps them for the rest of the period (29 CFR 1904.34).
Applying it to real cases
Retain OSHA records for the required period and keep them retrievable after closure. The log keeps changing after the 300A comes down, and a year-end PDF that never gets updated drifts away from the facts. The fix is to treat stored logs as live records: every late fact updates the right year's log, with the original lined out and the change dated.
Compliance managers are judged on whether the records hold up later, so focus on the basis for each decision and a clean history of changes.
Where teams go wrong
Teams lose site records during office moves or system cleanup.
Updates to stored logs change the rates you report internally and can affect what you would resubmit to the ITA, even though the posted 300A does not have to be redone.
Situations that change the answer
- Access requests can arrive after a location is gone.
- Access rights last as long as the records: former employees can request stored logs for establishments where they worked.
A worked example
A retailer closes its Toledo store in June 2026. The store's logs, 300As, 301s, and privacy lists for 2022 to 2026 go to the regional office in a labeled archive with an index by year. In 2027, when a former Toledo cashier asks for the 2024 log, the regional HR partner finds it in minutes and sends it the next business day.
A checklist you can reuse
- Archive the logs, summaries, 301s, and privacy lists.
- Include the support calculations.
- Name an owner for requests.
- Keep the archive until the five years end.
What to keep in the case file:
- The 300 Log with line-outs or a change history showing original and new entries
- The privacy case list for the same years
- Certified 300A summaries and the worksheets behind them
- The date and reason for each post-year-end change
Where 300log helps
300log keeps each establishment's log by year, so a late update goes on the log for the year the case occurred and that year's totals are recalculated.
For a quick answer without an account, use the free deadline calendar.
Frequently asked questions
Do we have to update old logs?
Yes. During the five years, update the 300 Log for newly discovered cases and for changes in classification or outcome.
Do we have to update the 300A after changes?
No. Updating the annual summary is optional.
Which records are included?
The 300 Log, the privacy case list if you have one, the 300A, and the 301 Incident Reports or their equivalents.
How long must OSHA 300 logs be kept?
Five years following the end of the calendar year they cover. 2026 records are kept through the end of 2031.
Sources
Primary regulation and agency guidance this article relies on.
- [1]29 CFR 1904.33: Retention and updatingOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [2]29 CFR 1904.30: Multiple business establishmentsOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [3]29 CFR 1904.35: Employee involvement and access to injury recordsOccupational Safety and Health Administration · osha.gov(opens in a new tab)
Written and reviewed by the 300log Editorial Team. Guidance, not legal advice: confirm edge cases with OSHA or counsel.