2025 Updates You Should Know About Recordkeeping and documentation for OSHA compliance

Staying compliant with OSHA regulations is a moving target—especially when it comes to recordkeeping and documentation. In 2025, new rules and clarifications have been introduced that directly impact how businesses, including those in the building materials sector, are expected to report, log, and store workplace safety data.

Whether you run a warehouse, distribution center, or job site, understanding these changes can help you avoid costly penalties and improve overall safety management. Here’s what you need to know.

As of January 2025, OSHA has expanded its electronic reporting mandate to include more establishments and more detailed data:

Businesses with 100+ employees in certain high-risk industries—including building materials, construction, and manufacturing—must now electronically submit Forms 300 and 301 in addition to the previously required Form 300A.

The submission deadline remains March 2 of each year for the prior calendar year’s data.

OSHA is also requiring employers to use their Injury Tracking Application (ITA) portal for submissions and may publish some data publicly to promote transparency.

What You Should Do: Ensure your injury and illness logs are accurate, timely, and ready for digital submission. Review who in your organization is responsible for compliance, and audit your 2024 records to catch any errors before submission.

OSHA has refined guidance on what qualifies as a recordable work-related incident, especially for temporary or contract workers. This includes:

Injuries occurring at off-site storage areas, delivery locations, or distribution centers where your company directs the work

Illnesses or injuries aggravated by workplace conditions (e.g., heat stress, dust exposure)

What You Should Do: Update your internal incident-reporting process to clearly document where and under what conditions injuries occur—especially in mobile operations or split-shift warehouse environments.

While not legally required, OSHA is now strongly encouraging employers to document near-misses as part of proactive safety programs. This documentation is increasingly considered during inspections and can influence how OSHA assesses your safety culture.

What You Should Do: Create a process for employees to report near-miss events anonymously or without fear of discipline. Use these reports in safety meetings to identify trends and make procedural changes.

OSHA inspectors are placing more emphasis on how documentation is stored and retrieved. In 2025, they’ve clarified that digital records:

Must be readily accessible during an inspection (no delays or disorganized storage)

Must be kept for at least 5 years following the end of the calendar year they cover

Should include date and time stamps and digital signatures, when applicable

What You Should Do: Invest in a document management system or safety software that organizes OSHA-related records in a searchable, secure, and shareable format.

For distribution hubs, shared warehouses, or job sites with multiple contractors, OSHA has updated its guidance on documentation responsibilities:

The controlling employer (typically the host or general contractor) is responsible for ensuring that proper documentation is maintained for all workers on site.

Each employer must still keep their own logs but must coordinate data sharing in case of incidents affecting multiple parties.

What You Should Do: Clarify agreements with subcontractors and vendors regarding safety recordkeeping. Document communication, roles, and responsibilities before work begins.

While not new, written safety programs are being scrutinized more heavily in 2025—especially those related to high-risk activities like:

Fall protection in elevated storage areas

Hazard communication for chemical handling

Lockout/tagout procedures for powered equipment

Inspectors may ask to see written policies and training logs to verify that the programs are active and enforced.

What You Should Do: Review and update written safety programs annually. Keep records of employee training, safety meetings, and corrective actions as part of your compliance documentation.

Final Thoughts

2025 brings a renewed push for transparency, accountability, and digital readiness in OSHA recordkeeping. For companies in the building materials space, this means tightening up your documentation processes, using technology to your advantage, and making compliance a routine part of operations—not a scramble during inspections.

The good news? Proactive recordkeeping not only keeps you compliant—it also builds a safer, more efficient workplace for everyone on your team.

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