Does Your Medical Practice Actually Have to Keep an OSHA 300 Log?

A great deal of compliance content assumes every employer keeps an OSHA 300 log. Many small medical and dental practices do not have to — and a smaller number have concluded from that they are exempt from OSHA generally, which is a considerably more expensive mistake.

Both halves are worth getting right.

Two independent partial exemptions

Part 1904 contains two separate routes out of routine recordkeeping. They are independent — qualifying under either is enough.

By size

29 CFR 1904.1 partially exempts an employer who had ten or fewer employees at all times during the previous calendar year.

Three details decide this more often than practices expect:

• “At all times” means peak, not average. One week at eleven employees during the previous calendar year removes the exemption for the current year. A practice averaging eight but staffing up over a busy stretch does not qualify.
• The count is company-wide, not per location. A practice with several sites counts everyone across the business, not the people at the largest office.
• It includes all employees — full-time, part-time, temporary, and seasonal. Whether specific staffing-agency personnel count toward your total depends on who supervises their day-to-day work.

By industry

29 CFR 1904.2, together with Appendix A to Subpart B of Part 1904, partially exempts establishments in listed low-hazard industries, identified by NAICS code — regardless of headcount.

Offices of physicians and offices of dentists appear on that list, along with several other ambulatory settings. This is why a twenty-person physician practice may still have no routine 300 log obligation while a five-person business in another industry does.

Not every healthcare setting is listed, and the exemption attaches to the establishment’s classification. If you are unsure how your practice is classified — or if you operate something alongside the practice that is classified differently — confirm it rather than assume, because the answer changes what you owe.

Partially exempt is not exempt

This is the part that matters. The exemption is narrow, it is specific to routine recordkeeping, and several obligations survive it intact.

Severe incidents must still be reported — on a clock

29 CFR 1904.39 applies to every employer, including partially exempt ones. You must report:

• A work-related fatality within eight hours of learning of it
• A work-related in-patient hospitalization, amputation, or loss of an eye within twenty-four hours of learning of it

Note that in-patient hospitalization means formal admission, not an emergency department visit for observation. These are short windows, and a practice that believes itself exempt from recordkeeping will not have thought about who makes that call at nine on a Saturday night.

You may be asked for records in writing

A partially exempt employer must still keep records if the Bureau of Labor Statistics or OSHA informs them in writing that they must do so for a survey or data collection. The exemption is from routine recordkeeping, not from a specific written request.

Every other OSHA standard applies in full

This is the misreading that causes real harm. Part 1904 governs injury and illness recordkeeping. It has nothing to do with the substantive safety standards, and none of them contain a comparable exemption.

A partially exempt medical practice still owes, in full:

• Bloodborne pathogens (29 CFR 1910.1030) — written exposure control plan, annual review including the safer-device evaluation and documented frontline input, training at assignment and annually, hepatitis B vaccination offered at no cost, post-exposure evaluation and follow-up, labels and containers
• Hazard communication (29 CFR 1910.1200) — written program, chemical inventory, safety data sheets, labeling, training
• Personal protective equipment (29 CFR 1910.132) — written hazard assessment, provision at no cost, training
• Emergency action plans, exit routes, electrical safety, and the rest of the general industry standards that apply to your operations
• The General Duty Clause, which reaches recognized serious hazards that no specific standard addresses

An inspector arriving at a partially exempt practice will not ask for a 300 log. They will ask for the exposure control plan.

The sharps log wrinkle

There is one place the exemption does reach beyond Part 1904, and it is worth knowing precisely.

The separate sharps injury log required by the bloodborne pathogens standard is written for employers who are required to maintain Part 1904 records. A practice that is partially exempt may therefore not owe that specific standalone log.

It still owes everything else in that standard — the exposure control plan, its annual review, the documented evaluation of safer devices, the solicitation of frontline employee input, training, and post-exposure follow-up. Many practices keep a sharps log regardless, because the device and work-area detail it captures is what makes the annual safer-device evaluation evidence-based rather than assertion-based.

Reasons to keep a log anyway

Exemption is permission, not instruction. Practices that keep records voluntarily tend to cite the same reasons: it makes the annual exposure control plan review defensible; it surfaces patterns — a device, a room, a time of day — long before anyone would notice them anecdotally; it means the exemption lapsing after one busy year does not catch you starting from nothing in January; and it puts a real number on why a safer device is worth its price when someone asks.

Frequently Asked Questions

How GuardWell handles this

GuardWell generates OSHA Forms 300, 300A, and 301 from incident records for practices that need them, and keeps the substantive obligations — exposure control plan review, hazard assessment, training assignments and renewals — on their own schedules regardless of whether a practice is partially exempt from recordkeeping. The two questions are tracked separately, because the answers are different.

Related reading: what actually goes on Forms 300, 300A, and 301, and the complete guide to OSHA requirements for medical offices.