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    OSHA Recordkeeping

    OSHA Injury Recordkeeping Rules for Auto Repair Shops & Garages (NAICS 8111 Guide)

    OSHA Injury Recordkeeping Rules for Auto Repair Shops & Garages (NAICS 8111 Guide)

    OSHA Injury Recordkeeping Rules for Auto Repair Shops & Garages (NAICS 8111 Guide)

    Imagine your busiest bay on a Friday afternoon. The lift hums as your top tech slides under a Ford F-150 for an oil change. Grease slicks the floor. Suddenly, a pinched hydraulic line catches his finger. Blood pools. He wraps it in a rag and heads to urgent care for stitches and antibiotics. Days later, the question hits: Is this a recordable injury? And does your auto repair shop even need to maintain an OSHA 300 log?

    For independent garage owners, managers, and office staff tasked with safety logs, OSHA recordkeeping starts with a coverage question, not a software purchase. The rules hinge on two gates: your shop's size and industry code. Get this wrong, and you're either overcomplying or exposed.

    Step 1: Check If Your Garage Is Covered by OSHA Recordkeeping

    OSHA's recordkeeping rules (29 CFR 1904) exempt many small businesses. First gate: employee count. If your entire company had 10 or fewer employees at all times last year, you generally skip the logs unless OSHA or the Bureau of Labor Statistics requests them in writing. Count everyone company-wide, peak headcount, even part-time techs.

    Clear the size hurdle? Second gate: your NAICS code. Automotive repair and maintenance (NAICS 8111) is not on OSHA's partially exempt list in Appendix A to Subpart B. Covered 8111 shops must keep records.

    Compare nearby codes:

    • NAICS 8111 (Automotive Repair): Generally recordkeep if over 10 employees.
    • NAICS 4471 (Gasoline Stations): Partially exempt; lube bays inside stations may differ.
    • NAICS 8112 (Electronic/Precision Repair): Partially exempt.
    • NAICS 8114 (Personal/Household Goods Repair): Partially exempt.
    • NAICS 8113 (Commercial Machinery Repair): Not exempt, but different electronic rules.

    Verify your NAICS via your business filings or OSHA's site. A standalone garage is typically 8111. Confirm company-wide headcount and current guidance before logging a single entry.

    Exempt or not, report severe events: fatalities within 8 hours, in-patient hospitalizations, amputations, or eye losses within 24 hours. That Tahoe lift collapse sending a tech to the ER? Report it, log or no log. See OSHA severe injury reporting.

    If Covered: Your OSHA 300 Log Garage Requirements

    Covered auto shops keep three items for each establishment: OSHA Form 300 (log of work-related injuries/illnesses), Form 301 (incident report) or equivalent for each recordable case, and Form 300A (annual summary). Record within 7 days of learning about the case. Use paper, computer, or equivalent if it matches 1904.29 specs.

    Typical Auto Shop Cases

    Grinding sparks to the eye. Chemical splash needing beyond first aid. Back strain from wrestling a transmission. Crushed fingers on lifts. Slips on oil puddles. Fractures beyond splints. These often cross into recordable territory. Review first aid vs. medical treatment and fractured bone rules. Workers' comp first reports? Not automatic 301 substitutes; check equivalence.

    Privacy cases (e.g., needlestick) omit names on the 300 log. In tight-knit shops, this protects everyone. Details at privacy rules.

    Year-End Duties: Posting, Certification, and Zero-Case Years

    Every covered shop certifies and posts Form 300A February 1 to April 30, even zero cases. Company executives sign it. Retain records 5 years. Learn posting and zero-case rules, plus who signs.

    Electronic Submission for NAICS 8111 Shops

    Most independent auto repair shops dodge this. NAICS 8111 isn't on Appendices A or B to Subpart E, so typical garages under 250 employees skip Injury Tracking Application (ITA) uploads. Larger ones or 8113 shops may need 300A electronic submission. Always check current lists and who must submit.

    Practical Recordkeeping Options for Your Shop

    Tiny, exempt shops? A notebook suffices; no software needed. Covered? A shared office spreadsheet works for solo owners. But handoffs to managers, privacy on 301s, or audit-ready backups shine with dedicated tools. FORM 300 LOGBOOK offers a connected recordkeeping workspace at $79/month or $708/year, with populated review copies, CSV backups, and ITA-format files for your team to review and upload if needed. Not OSHA-affiliated; no submissions. See the FORM 300 LOGBOOK plan. Start your OSHA recordkeeping workspace. See how it works. Full guidance at OSHA guidance.

    Bottom line: Confirm coverage first. Size under 11 and exempt NAICS? Breathe easy. Otherwise, lock in your OSHA recordkeeping auto repair shop process. One slipped finger could trigger an inspection. Stay compliant, keep wrenching.