Small Fleet OSHA Compliance Checklist: Complete Guide for Delivery and Logistics Businesses

2026-01-13

Running a delivery fleet, trucking company, or logistics operation means managing OSHA compliance alongside daily operations. Unlike large companies with dedicated safety departments, small fleet owners handle compliance themselves while also managing routes, hiring drivers, and keeping vehicles on the road.

This guide provides a complete OSHA compliance checklist specifically for small fleet operations (10-200 employees). Follow this checklist to avoid penalties, pass inspections, and protect your team.

Why OSHA Compliance Matters for Small Fleets

Legal requirement: Most employers with 10+ employees must comply with OSHA recordkeeping rules.

Financial risk: OSHA penalties can exceed $16,000 per violation. Missing the February 1 annual posting deadline or failing to maintain accurate logs can result in citations during inspections.

Operational impact: Poor safety records increase workers compensation premiums, make hiring harder, and can disqualify you from contracts with major clients (Amazon, FedEx contractors, etc. often require clean OSHA records).

Real benefit: Accurate recordkeeping helps you identify trends (repeated injuries in specific locations, specific tasks causing injuries) so you can fix problems before they escalate.

Quick Reference: OSHA Compliance at a Glance

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Part 1: OSHA Recordkeeping Requirements

Form 300: Log of Work-Related Injuries and Illnesses

What it is: A running log of ALL work-related injuries and illnesses that meet OSHA's recordability criteria.

What you must record:

- Employee name (or case number/privacy case if sensitive)

- Job title

- Date of injury or illness

- Where the event occurred

- Description of injury or illness

- Body part affected

- Classification (injury, skin disorder, respiratory condition, poisoning, hearing loss, other illness)

- Number of days away from work

- Number of days of job transfer or restriction

- Whether the case resulted in death

When to record: Within 7 calendar days of learning about a recordable injury or illness.

How to maintain: You can use OSHA's official Form 300 (paper or electronic) or equivalent software that captures the same information.

Common mistakes:

- Waiting until the end of the year to update the log (you must update within 7 days)

- Failing to record injuries that seemed minor initially but later required medical treatment

- Not recording injuries that occur in parking lots or during travel between job sites

✅ Checklist:

- [ ] Downloaded current Form 300 from OSHA website or set up equivalent tracking system

- [ ] Designated person responsible for maintaining Form 300

- [ ] Established process for employees/supervisors to report injuries within 24 hours

- [ ] Set calendar reminder to update Form 300 within 7 days of each reported injury

- [ ] Stored Form 300 securely (required to keep for 5 years)

Form 300A: Annual Summary

What it is: A one-page summary of your Form 300 data for the previous calendar year.

When to complete: By February 1 each year.

Posting requirement: Must be posted in a common area from February 1 through April 30.

Where to post: Break room, near time clock, dispatch area, main office - anywhere employees regularly pass by.

Who must sign: A company executive (owner, highest-ranking official, or their immediate supervisor). Administrative staff cannot sign.

Electronic submission:* If you have 250+ employees OR 20-249 employees in a high-hazard industry (including transportation/warehousing NAICS 48-49), you must also submit Form 300A electronically via OSHA's Injury Tracking Application by *March 2.

✅ Checklist:

- [ ] Reviewed Form 300 for accuracy before creating annual summary

- [ ] Calculated total hours worked by all employees in previous year

- [ ] Calculated annual average number of employees

- [ ] Calculated Total Case Incident Rate (TCIR)

- [ ] Calculated Days Away, Restricted, or Transferred (DART) rate

- [ ] Had company executive sign and date Form 300A

- [ ] Posted Form 300A by February 1 in visible common area

- [ ] Kept Form 300A posted through April 30

- [ ] Submitted electronically via ITA (if required)

- [ ] Set calendar reminder for next year's February 1 deadline

Form 301: Injury and Illness Incident Report

What it is: A detailed report of each recordable injury or illness.

When to complete: Within 7 calendar days of learning about a recordable injury.

What it includes:

- Employee information (name, address, date of birth, date hired)

- Details about the physician or healthcare professional who treated the injury

- Detailed description of how the injury occurred

- What the employee was doing just before the incident

- What happened

- What object or substance directly harmed the employee

Can you use substitutes? Yes - workers compensation first report of injury, insurance claim form, or other reports are acceptable IF they contain all the same information required by Form 301.

✅ Checklist:

- [ ] Downloaded current Form 301 or confirmed workers comp forms include all required data

- [ ] Established process to complete Form 301 (or equivalent) within 7 days of recordable injury

- [ ] Designated person responsible for completing Form 301

- [ ] Stored Form 301 securely alongside Form 300 (required to keep for 5 years)

- [ ] Ensured privacy: separated personally identifiable information if case involves sensitive injury/illness

Part 2: OSHA Posting Requirements

OSHA "Job Safety and Health" Poster

What it is: Official OSHA poster informing employees of their rights and how to file complaints.

Posting requirement: Must be posted continuously in a prominent location where employees can easily read it.

Where to get it: Download free from https://www.osha.gov/publications or request a free printed copy from OSHA.

Good posting locations:

- Break rooms

- Near time clocks

- Main office entrance

- Driver check-in areas

- Shop/maintenance areas

✅ Checklist:

- [ ] Downloaded and printed OSHA poster (or requested free copy)

- [ ] Posted in visible location accessible to all employees

- [ ] Posted at EACH establishment if you have multiple locations

- [ ] Verified poster is current version (OSHA updates periodically)

Form 300A Annual Summary (February 1 - April 30)

Covered in Part 1 above, but worth repeating:

- [ ] Posted Form 300A by February 1

- [ ] Kept posted through April 30

- [ ] Posted in common area where employees typically gather

- [ ] Posted at EACH establishment if you have multiple locations

Part 3: Reporting Requirements

8-Hour Reporting: Work-Related Fatalities

If an employee dies as a result of a work-related incident, you must report it to OSHA within 8 hours.

How to report:

- Call 1-800-321-OSHA (6742)

- Report online at https://www.osha.gov/report

- Call your local OSHA area office

What to report:

- Business name

- Location of incident

- Time of incident

- Number of fatalities

- Names of employees who died

- Contact person and phone number

- Brief description of incident

✅ Checklist:

- [ ] Saved OSHA reporting phone number (1-800-321-6742) in emergency contacts

- [ ] Designated backup person to report if primary contact unavailable

- [ ] Briefed all managers/supervisors on 8-hour fatality reporting requirement

24-Hour Reporting: Hospitalizations, Amputations, Eye Loss

If an employee experiences any of the following as a result of a work-related incident, you must report it to OSHA within 24 hours:

- Hospitalization: Admitted to hospital as an inpatient for treatment (not just emergency room visit and release)

- Amputation: Loss of any body part (finger, toe, limb, etc.)

- Eye loss: Physical removal of the eye or permanent loss of sight in one eye

How to report: Same methods as fatality reporting (call 1-800-321-OSHA, report online, or call local OSHA office).

✅ Checklist:

- [ ] Saved OSHA reporting phone number in emergency contacts

- [ ] Briefed all managers/supervisors on 24-hour reporting requirements

- [ ] Established process to determine if injury meets reporting criteria

- [ ] Created template/script for making OSHA reports to ensure all required information is communicated

Part 4: Employee Access to Records

Employees have the right to access OSHA injury and illness records. You must provide access within specific timeframes.

Employee Access to Form 300 (Log)

Timeframe: By the end of the next business day after the request.

What to provide: Copy of Form 300 for the current year and the past 5 years.

Privacy note: If the request is from an employee who wants to see the entire log, you can remove employee names (use case numbers instead) EXCEPT for the requesting employee's own cases.

Employee Access to Form 301 (Incident Report)

Timeframe: By the end of the next business day after the request.

What to provide: Copy of Form 301 for the employee's OWN incidents only. Employees can only see their own Form 301, not those of other employees (privacy protection).

Former Employee Access

Former employees have the same rights as current employees to access their own records.

✅ Checklist:

- [ ] Established process for employees to request records

- [ ] Designated person responsible for responding to records requests

- [ ] Ensured forms are accessible and can be provided within required timeframe

- [ ] Created redacted versions of Form 300 (with names removed) for employee access

Part 5: Recordkeeping Exemptions

Not all employers are required to maintain OSHA injury and illness records.

Exempt Based on Size

Exempt: Employers with 10 or fewer employees at ALL times during the previous calendar year.

Important: If you had 11+ employees at any point during the year, you're NOT exempt even if you dropped below 10 later.

Exempt Based on Industry

Certain low-hazard industries are exempt if they have 10 or fewer employees. However, transportation and warehousing (NAICS 48-49) is NOT on the exempt list.

If you run a delivery fleet, trucking company, or logistics operation, you are NOT exempt based on industry classification, even if you have fewer than 10 employees.

Note: Even if you're exempt from routine recordkeeping, you still must:

- Report work-related fatalities within 8 hours

- Report hospitalizations, amputations, eye loss within 24 hours

- Provide records to OSHA or NIOSH if requested

- Post the OSHA "Job Safety and Health" poster

✅ Checklist:

- [ ] Confirmed whether your establishment is exempt from routine recordkeeping

- [ ] If exempt, documented basis for exemption (size or industry)

- [ ] If exempt, still prepared to report fatalities and severe injuries

Part 6: Determining Recordability

The most challenging part of OSHA compliance is determining which injuries and illnesses are recordable. An incident is recordable only if it meets ALL three criteria:

Criterion 1: Work-Related

The injury or illness must have occurred in the work environment and been caused by work activities or conditions.

Work environment includes:

- Company facilities (office, warehouse, shop, yard)

- Customer locations during deliveries

- Vehicles during work hours

- Parking lots when arriving for or leaving work

- Hotels during work travel

Common work-related injuries for fleets:

- Driver slips on ice in customer parking lot during delivery

- Mechanic cuts hand repairing vehicle

- Warehouse worker injured operating forklift

- Driver rear-ended while stopped at red light during delivery route

- Dispatcher develops carpal tunnel from computer work

NOT work-related:

- Commuting accidents (unless in company vehicle performing work duties)

- Injuries during lunch break off-premises

- Pre-existing conditions that don't worsen at work

- Injuries from horseplay or intoxication (unless work conditions contributed)

Criterion 2: New Case

This is the first time recording this specific injury, OR it's a significant re-injury after full recovery.

New case if:

- Employee has never experienced a recordable injury to the same body part, OR

- Employee fully recovered from previous injury to same body part, OR

- Previous injury to same body part was first aid only, but now requires medical treatment

Example: Driver injured right knee in 2024 (recordable). Fully recovered. Driver re-injures same right knee in 2025. This is a NEW case and must be recorded on 2025 Form 300.

Criterion 3: Meets Severity Criteria

The injury or illness must result in one or more of the following:

- Death

- Days away from work

- Restricted work or job transfer

- Medical treatment beyond first aid

- Loss of consciousness

- Significant injury or illness diagnosed by physician or licensed healthcare professional (fracture, torn ligament, punctured eardrum, etc.)

Medical treatment vs. First aid:

Medical treatment (recordable):

- Prescription medications at prescription strength

- Stitches (sutures)

- Physical therapy

- Chiropractic treatment

- Treatment of fractures, lacerations, puncture wounds

- Removal of foreign objects embedded in the eye

- Treatment of second- or third-degree burns

First aid (NOT recordable):

- Bandages and wound dressings

- Hot or cold therapy (ice packs, heating pads)

- Non-prescription medications at non-prescription strength

- Drinking fluids for heat stress

- Eye wash or flushing

- Removing splinters or foreign material from areas other than the eye without incision

- Finger guards, elastic bandages

- Massages

- Vaccines (tetanus, hepatitis B, flu)

✅ Checklist:

- [ ] Created decision tree or flowchart to determine recordability

- [ ] Trained supervisors/managers on three recordability criteria

- [ ] Established process to gather injury details (what happened, treatment received, work restrictions)

- [ ] When uncertain, defaulted to recording (conservative approach protects you during inspections)

Part 7: Multi-Establishment Employers

If you operate multiple locations (multiple dispatch centers, warehouses, terminals, etc.), OSHA recordkeeping requirements apply per establishment, not per company.

What Is an "Establishment"?

An establishment is a single physical location where business is conducted or services are performed.

For fleet operators:

- Your main terminal/dispatch center = one establishment

- Your satellite terminal 50 miles away = separate establishment

- Your warehouse = separate establishment (if different physical location)

Remote workers (drivers): Drivers based at home are NOT a separate establishment - their injuries are recorded at the establishment to which they report or from which they're supervised.

Recordkeeping for Multiple Establishments

You must:

- Maintain separate Form 300 for each establishment

- Post separate Form 300A at each establishment

- Submit separate electronic Form 300A for each establishment (if required)

✅ Checklist:

- [ ] Identified all establishments (separate physical locations)

- [ ] Set up separate Form 300 for each establishment

- [ ] Designated person at each establishment responsible for recordkeeping

- [ ] Ensured each establishment posts required notices (OSHA poster, Form 300A)

Part 8: Retention Requirements

You must keep OSHA injury and illness records for 5 years following the end of the year to which they pertain.

Example: Your 2025 records (Form 300, Form 300A, Form 301) must be kept until December 31, 2030.

What to retain:

- Form 300 (Log)

- Form 300A (Annual Summary)

- Form 301 (Incident Reports) for each recordable case

- Privacy case list (if applicable)

You do NOT need to update old logs: If you discover an injury from 2024 should have been recorded, you don't update the 2024 Form 300 (it's "closed"). But you should review your process to avoid missing future injuries.

✅ Checklist:

- [ ] Created secure storage system for OSHA records (physical or electronic)

- [ ] Labeled records by year for easy retrieval

- [ ] Set calendar reminder to dispose of records after 5-year retention period expires

- [ ] Ensured records are accessible for inspections, employee requests, or audits

Part 9: Training and Communication

While OSHA doesn't explicitly require injury reporting training for general industry, effective training reduces compliance risks.

Train Supervisors and Managers

Your supervisors and managers should understand:

- Three criteria for recordability (work-related + new case + severity)

- Difference between medical treatment and first aid

- Importance of reporting injuries promptly (within 24 hours of occurrence)

- How to complete Form 301 or equivalent incident report

- 8-hour and 24-hour OSHA reporting requirements

✅ Checklist:

- [ ] Conducted initial training for all supervisors/managers on OSHA recordkeeping

- [ ] Provided reference materials (decision tree, first aid list, OSHA contact info)

- [ ] Scheduled annual refresher training

- [ ] Documented training (who attended, when, topics covered)

Communicate Injury Reporting Process to Employees

Employees need a clear, simple process to report injuries:

Example process:

1. Seek immediate medical attention if needed

2. Report injury to supervisor or manager within 24 hours (provide phone number, email, or reporting form)

3. Complete incident report with supervisor

4. Keep copy of medical treatment records for workers comp and OSHA recordkeeping

✅ Checklist:

- [ ] Created written injury reporting procedure

- [ ] Communicated procedure to all employees (handbook, posting, orientation)

- [ ] Provided multiple ways to report (phone, email, in-person, anonymous hotline)

- [ ] Prohibited retaliation against employees who report injuries

Part 10: Common OSHA Violations for Small Fleets

Based on OSHA enforcement data, here are the most common recordkeeping violations for small businesses:

Violation 1: Failure to Record Recordable Injuries

What it is: Not recording injuries that meet the three recordability criteria.

Why it happens: Employer assumes minor injuries don't need to be recorded, or doesn't understand first aid vs. medical treatment distinction.

How to avoid:

- Default to recording when uncertain

- Train supervisors on recordability criteria

- Review all workers comp claims to ensure they're evaluated for OSHA recordability

Violation 2: Failure to Post Form 300A

What it is: Not posting the annual summary from February 1 - April 30, or posting it in an area employees can't access.

Why it happens: Employer forgets deadline or posts in back office instead of common area.

How to avoid:

- Set calendar reminder for January 15 to prepare Form 300A

- Post in break room, near time clock, or other high-traffic area

- Take photo of posted Form 300A as evidence of compliance

Violation 3: Inaccurate or Incomplete Records

What it is: Form 300 missing required information (employee name, injury description, days away, etc.).

Why it happens: Employer delays recording and later can't remember details, or uses shorthand instead of complete descriptions.

How to avoid:

- Record within 7 days while details are fresh

- Use complete sentences in description field (not just "back injury" - explain what happened)

- Review Form 300 quarterly for completeness

Violation 4: Failure to Report Fatalities or Severe Injuries

What it is: Not reporting work-related fatality within 8 hours or hospitalization/amputation/eye loss within 24 hours.

Why it happens: Employer doesn't understand reporting requirements or assumes workers comp notification is sufficient.

How to avoid:

- Post OSHA reporting phone number (1-800-321-6742) in emergency contacts

- Train all managers on 8-hour and 24-hour reporting requirements

- Create checklist for severe injury response (call 911, notify family, report to OSHA, document incident)

Violation 5: Refusing Employee Access to Records

What it is: Not providing employee access to Form 300 or Form 301 within required timeframe.

Why it happens: Employer doesn't know employees have a legal right to access records, or delays response.

How to avoid:

- Establish written process for employees to request records

- Respond by end of next business day

- Designate backup person if primary contact is unavailable

Part 11: Annual Compliance Calendar

Use this calendar to stay on top of OSHA requirements throughout the year:

January:

- [ ] Review Form 300 for completeness and accuracy

- [ ] Calculate total hours worked and annual average employees for previous year

- [ ] Complete Form 300A (Annual Summary)

- [ ] Have company executive sign Form 300A

February 1:

- [ ] Post Form 300A in common area (must remain posted through April 30)

- [ ] Submit Form 300A electronically via ITA (if required)

- [ ] Store previous year's records securely (5-year retention)

Ongoing (Throughout the Year):

- [ ] Update Form 300 within 7 days of learning about recordable injury

- [ ] Complete Form 301 (or equivalent) within 7 days of recordable injury

- [ ] Report work-related fatality to OSHA within 8 hours

- [ ] Report hospitalization, amputation, or eye loss to OSHA within 24 hours

- [ ] Respond to employee records requests within 1 business day

April 30:

- [ ] Remove Form 300A from posting (no longer required to be posted)

- [ ] Store Form 300A with other records (still required to retain for 5 years)

December:

- [ ] Review current year Form 300 to identify safety trends

- [ ] Set calendar reminders for January tasks

Part 12: Resources and Tools

Official OSHA Resources

- OSHA Recordkeeping Handbook: https://www.osha.gov/recordkeeping/handbook

- Current Forms (300, 300A, 301): https://www.osha.gov/recordkeeping/forms

- Injury Tracking Application (ITA): https://www.osha.gov/injuryreporting/ita/

- OSHA Recordkeeping FAQs: https://www.osha.gov/recordkeeping/faq

Compliance Tools

- OSHA 300 Log Software: Many vendors offer electronic recordkeeping systems (search "OSHA 300 software")

- Workers Comp Integration: Some workers comp providers offer OSHA recordkeeping as part of their service

- Automated Recordkeeping: Tools that extract injury data from unstructured documents (emails, texts, comp claims) and generate OSHA forms

Getting Help

- OSHA On-Site Consultation Program: Free and confidential help for small businesses (no citations issued) - https://www.osha.gov/consultation

- Workers Comp Provider: Contact your insurance provider - many offer OSHA compliance assistance

- Safety Consultant: Hire a certified safety professional for annual audit

Key Takeaways

OSHA compliance for small fleets comes down to four core requirements:

1. Record injuries and illnesses on Form 300 within 7 days (work-related + new case + severity criteria)

2. Post Form 300A annually from February 1 - April 30 (and submit electronically by March 2 if required)

3. Report fatalities within 8 hours and hospitalizations/amputations/eye loss within 24 hours

4. Provide employee access to records within 1 business day

Start with this checklist, set calendar reminders for key deadlines, and establish clear processes for injury reporting. Compliance doesn't have to be complicated - it just needs to be consistent.

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