Total Hours Worked on OSHA 300A: What to Include and What to Exclude
Enter the hours actually worked by all employees covered by the log, including overtime, and leave out paid vacation, holidays, sick leave, and other time off.
The short version
Enter the hours actually worked by all employees covered by the log, including overtime, and leave out paid vacation, holidays, sick leave, and other time off. If you cannot get actual hours for some staff, such as salaried employees, estimate them and document how.
Hours worked is where recordkeeping meets payroll reality.
What you need before you start
Gather these first, and keep them with the record afterward:
- The payroll report used for hours worked, with the date it was pulled
- Adjustments: paid leave removed, supervised temporary workers added
- The pay periods and headcounts behind the annual average employees figure
- The rate calculation with the case counts it used
The rule behind the steps
OSHA incidence rates scale case counts to 200,000 hours, which is 100 full-time workers at 40 hours a week for 50 weeks. TRIR (also called TCIR) = total recordable cases (300A columns G + H + I + J) × 200,000 ÷ total hours worked. DART = (cases in columns H + I) × 200,000 ÷ total hours worked. The 300A itself asks for the annual average number of employees and the total hours worked by all employees covered by the log (29 CFR 1904.32(b)(2)). For comparison, the BLS private-industry averages for 2024 were a TRIR of 2.3 and a DART rate of 1.4.
Step by step
- Pull hours from payroll for the full calendar year.
- Remove paid time off that was not worked.
- Add supervised workers who are not on your payroll.
- Document assumptions and estimates.
- Use the same total for the 300A, the rates, and the ITA.
Tip: Use hours worked by employees covered by the OSHA 300 Log and keep the calculation source.
Where this usually goes wrong
Teams sometimes include vacation, holiday, or other non-work hours because payroll reports are not filtered.
The denominator does as much work as the numerator. One wrong hours figure moves every rate, and the same hours also go on the 300A and into the ITA submission. The fix is to document the method once (which payroll report, which exclusions, which estimates) and use the same hours for the 300A, the ITA, and every rate.
Payroll owns the hours and headcount that go on the 300A and into every rate, so the method matters as much as the total.
Special situations
- Temporary staffing and overtime can change the calculation depending on who is supervised day to day.
- Temporary workers you supervise day to day belong in your case counts and your hours worked.
Example
Payroll reports 212,400 paid hours. Of those, 14,800 are vacation, holiday, and sick pay; 3,600 hours were worked by agency temps the site supervises (billed, not on payroll); and 12 salaried staff are estimated at 45 hours a week for 48 weeks, adding 25,920 hours that payroll does not track. Hours worked = 212,400 − 14,800 + 3,600 + 25,920 = 227,120.
How it affects the rest of your records
Hours worked and average employees appear on the posted 300A and in the ITA submission, so a figure that is wrong for the rate is also wrong on two regulatory documents.
Where 300log helps
300log totals each establishment's columns as cases are recorded and keeps average employees and hours worked with the 300A, so the rate, the posted summary, and the ITA submission all use the same numbers.
For a quick answer without an account, use the free rate calculator.
Frequently asked questions
What is the formula for TRIR?
TRIR = total recordable cases × 200,000 ÷ total hours worked. The case count is the sum of 300A columns G, H, I, and J.
What counts toward DART?
Cases with days away from work (column H) plus cases with job transfer or restriction (column I). It counts cases, not days.
Is there an official severity rate?
No. OSHA and BLS publish no official severity rate. Some teams track a day count rate, (days away + days restricted) × 200,000 ÷ hours, from an archived OSHA worksheet, but it has no BLS benchmark.
Does hours worked include salaried staff?
Yes, if they are covered by the log. Use actual hours where you have them and a reasonable, documented estimate for exempt staff.
Sources
Primary regulation and agency guidance this article relies on.
- [1]29 CFR 1904.32: Annual summary certification and postingOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [2]29 CFR 1904.31: Covered employeesOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [3]OSHA ITA CSV documentationOccupational 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.