NAICS 236220 · Construction
OSHA Recordkeeping for Commercial and Institutional Building Construction
Commercial builders face two log questions most industries don't. A project expected to last a year or more is its own establishment, with its own 300 log and 300A (29 CFR 1904.30(a)). And on a multi-employer site, each employer logs the people it supervises day to day: your own crews and any temporary workers you direct (1904.31(b)(2)), plus a subcontractor's employees only if you supervise their work day to day (1904.31(b)(3)).
Who keeps and files OSHA records
NAICS 236220 is not on OSHA's partially exempt list, so the size rule decides the log (29 CFR 1904.1 (opens in a new tab)) and the filing appendices decide what goes to OSHA (1904.41 (opens in a new tab)).
- OSHA 300, 300A and 301
- Required
- Once the company passes 10 employees at any time in the year.
- 300A e-filing by March 2
- From 20 employees
- Per establishment; appendix A industry.
- 300 and 301 case data
- Not required
- Not in appendix B, at any size.
2024 injury rates for commercial construction
Cases per 100 full-time workers, as published by BLS for NAICS 2362, nonresidential building construction, the closest industry it publishes that includes 236220. The TRIR of 1.9 is below the private-industry rate of 2.3.
- Total recordable (TRIR)
- 1.9
- Columns H, I and J
- Days away, restricted or transferred (DART)
- 1.2
- Columns H and I
- Days away from work
- 0.8
- Column H
| Full-time employees | Hours worked a year | Cases at TRIR 1.9 |
|---|---|---|
| 25 | 50,000 | 0.5 |
| 50 | 100,000 | 0.9 |
| 100 | 200,000 | 1.9 |
Your rate is recordable cases × 200,000 ÷ hours worked; the TRIR calculator works it out from your 300A.
Recordable or not: cases from commercial construction
- A project expected to run a year or more is its own establishment, with its own 300 log and 300A. (29 CFR 1904.30(a))
- A temporary worker your foreman supervises day to day goes on your log, not the staffing agency's. (29 CFR 1904.31(b)(2))
For a case of your own, the recordable checker walks through the same rules.
What 29 CFR 1904 requires
OSHA 300 log
Each recordable case, within 7 calendar days. 1904.29(b)(3) (opens in a new tab)
OSHA 301 report
One per case, same 7 days; an equivalent form works. 1904.29(b)(4) (opens in a new tab)
OSHA 300A summary
Certified by an executive, posted February 1 to April 30. 1904.32 (opens in a new tab)
Privacy cases
Six case types keep the name off the log. 1904.29(b)(7) (opens in a new tab)
Severe injury reports
Fatality in 8 hours; hospitalization, amputation, eye loss in 24. 1904.39 (opens in a new tab)
Retention
All three forms kept five years. 1904.33 (opens in a new tab)
Hazards OSHA addresses for this work
Commercial Construction: recordkeeping questions
Does a general contractor with 11 employees have to keep an OSHA 300 log?
Yes. Building construction isn't partially exempt, so the only way out is having 10 or fewer employees at all times during the last calendar year, counted across the whole company (29 CFR 1904.1). Office staff count toward that number as well as the field crews.
Does a commercial builder have to submit 300A data to OSHA by March 2?
Construction is in appendix A to 29 CFR 1904.41, so each establishment with 20 or more employees at any time last year submits its 300A through the Injury Tracking Application by March 2. Nonresidential building construction, NAICS 2362, isn't in appendix B, so case-level 300 and 301 data is not required at any headcount. A project site that is its own establishment counts its own employees.
How do the 300 log and the 300A work on a long project?
A project expected to run a year or more keeps its own 300 log, with each recordable case entered within 7 calendar days (29 CFR 1904.29(b)(3)). At year end that log's totals become the project's 300A, certified by a company executive and posted where notices to workers go, from February 1 to April 30 (1904.32). Shorter projects can share one log that covers your short-term sites (1904.30(b)(1)).