NAICS 238220 · Construction
OSHA Recordkeeping for Plumbing, Heating, and Air-Conditioning Contractors
Plumbing and HVAC technicians work from a truck, in buildings that belong to someone else. Each technician is tied to the branch or shop they report to (29 CFR 1904.46), and a case at a customer's site goes on the log of the establishment where the technician normally works (1904.30(b)(4)). The 2024 rate for these contractors, 3.0 recordable cases per 100 full-time workers, was above the private-industry 2.3.
Who keeps and files OSHA records
NAICS 238220 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 plumbing & hvac contractors
Cases per 100 full-time workers, as published by BLS for NAICS 23822, plumbing, heating, and air-conditioning contractors. The TRIR of 3.0 is above the private-industry rate of 2.3.
- Total recordable (TRIR)
- 3.0
- Columns H, I and J
- Days away, restricted or transferred (DART)
- 1.7
- Columns H and I
- Days away from work
- 1.1
- Column H
| Full-time employees | Hours worked a year | Cases at TRIR 3.0 |
|---|---|---|
| 25 | 50,000 | 0.8 |
| 50 | 100,000 | 1.5 |
| 100 | 200,000 | 3.0 |
Your rate is recordable cases × 200,000 ÷ hours worked; the TRIR calculator works it out from your 300A.
Recordable or not: cases from plumbing & hvac contractors
- Technicians who work out of a truck are logged at the establishment they report to, so every case lands on one site's log. (29 CFR 1904.30(b))
- A prescription painkiller for a strained back makes the case recordable, even if the worker never misses a shift. (29 CFR 1904.7(b)(5)(ii)(A))
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
Plumbing & HVAC Contractors: recordkeeping questions
Does a plumbing or HVAC company with 14 employees keep an OSHA 300 log?
Yes. The line is 11 employees: the size exemption covers only companies with 10 or fewer at all times during the last calendar year (29 CFR 1904.1), and building equipment contractors have no industry exemption. Dispatchers, estimators and apprentices count along with the technicians, and a busy cooling season that pushes you to 11 for a few weeks is enough.
Does a plumbing or HVAC contractor file with OSHA by March 2?
Only a branch that had 20 or more employees at some point last year files, and what it files is the 300A alone, through OSHA's Injury Tracking Application by March 2 (29 CFR 1904.41). The 20-employee line comes from construction being in appendix A. Building equipment contractors, NAICS 2382, are not in appendix B, so no 300 or 301 case data goes to OSHA, even from a branch of 150.
What is the difference between the 300 log and the 300A for a service company?
The 300 log is the case list, kept per branch: a burn, a fall from a ladder or a back strain goes on it within 7 calendar days (29 CFR 1904.29(b)(3)). The 300A is that branch's year-end summary, certified by a company executive and posted from February 1 to April 30 where notices to employees are posted (1904.32), usually the shop technicians start from.