Amended OSHA 300A Summary: When a Year-End Change Matters
OSHA does not require an amended 300A after year-end changes, but you must update the stored 300 Log; amending the summary is optional.
The short answer
OSHA does not require an amended 300A after year-end changes, but you must update the stored 300 Log; amending the summary is optional. If you do amend it, keep both versions and note why the numbers changed.
Late case updates can make teams wonder whether the annual summary must be changed.
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).
How it plays out on site
Update stored OSHA 300 Logs when required and decide whether an amended summary is useful for internal accuracy. 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.
EHS managers usually run the monthly review, which is the best point to catch the late medical updates that change a case.
The common mistake
Teams change the summary but forget to update the supporting log.
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.
Edge cases
- OSHA retention rules treat log updates differently from annual summary updates.
- If a site closes, its records still have to be kept and produced on request for the full five years.
Worked example
After a late case update, a site's corrected totals are 7 recordable cases instead of 6. The log is updated. The site chooses to keep the certified 300A with 6 as posted, and records the difference in a note; the internal dashboard shows 7.
Checklist
- Review the new facts.
- Update the 300 Log.
- Decide whether to amend the summary.
- Align internal dashboards and records.
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.
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Frequently asked questions
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.
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.
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 1904.32: Annual summary certification and postingOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [3]29 CFR 1904.7: General recording criteriaOccupational 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.