Whether a veterinary practice has to keep an OSHA 300 log comes down to one headcount test: if your company had more than 10 employees at any time during the last calendar year, you keep the log — because veterinary services is not on OSHA's list of partially exempt industries.
Only a practice that stayed at 10 or fewer employees all year is exempt, and even then severe injuries must still be reported to OSHA.
Rules vary by state and change
This guide explains federal rules and the state rules it names, as of the date above.
Employment law and veterinary practice rules differ by state and are revised often, so confirm current requirements with your state veterinary board, labor agency or employment counsel before you act on them.
It is general information, not legal advice.
Who has to keep OSHA logs: the 10-employee and industry exemptions
Federal recordkeeping has two doors out of the requirement — size and industry — and you keep the log when neither applies.
The size door comes first.
Under 29 CFR 1904.1, a company with 10 or fewer employees at all times during the last calendar year does not have to keep OSHA injury and illness records, unless OSHA or the Bureau of Labor Statistics informs you in writing that you must.
If your company had more than 10 employees at any time during the year, the size exemption is gone, and the duty attaches unless your establishment is in a partially exempt industry.
The count that matters is company-wide, not per location.
The size test looks at peak employment across the entire company during the last calendar year, so a two-location practice with 6 staff at each site is a 12-employee company — and a multi-clinic group cannot use the small-employer exemption even when every individual clinic stays under 10.
Neither is this a paperwork formality for a quiet industry.
The Bureau of Labor Statistics put veterinary services at 10.6 nonfatal injuries and illnesses per 100 full-time workers in 2023, against 2.4 for all workers — more than four times the all-worker rate.
Cases are being generated either way; the log is where they are supposed to land.
One boundary applies before any of it: all employers covered by the OSH Act must report work-related fatalities, in-patient hospitalizations, amputations and losses of an eye to OSHA, even when they are exempt from keeping the records themselves.
The exemptions thin the paperwork; they never remove the phone call.
Recordkeeping is also only one slice of OSHA compliance.
The program side — written safety programs, training, and the protections around X-ray — is its own subject, and the radiation and OSHA safety guide for practice managers covers it.
Is veterinary services on OSHA's partially exempt industry list?
No. OSHA's partially exempt industries are listed by NAICS code in Appendix A to Subpart B of 29 CFR 1904, and veterinary services is not among them.
Veterinary practices are classified under NAICS 541940, inside 5419 — "Other Professional, Scientific, and Technical Services" — and the appendix skips right over it: the last professional-services entry before the jump is 5418, Advertising and Related Services, and the next line is 5511.
5419 sits between them, absent from the list.
That detail matters because the exemption invites a misreading.
The assumption runs that a clinic is a professional office, not a worksite, so the log rules must not apply.
Under the federal rule the opposite is true: because 5419 is not partially exempt, the industry test never removes the duty for a veterinary practice, and recordkeeping turns entirely on the size test above.
A practice whose company exceeded 10 employees at any point last year keeps the OSHA 300 log, keeps the OSHA 301 incident reports that go with it, and posts the annual summary — the same as any other non-exempt employer.
What makes an injury recordable: bites, needlesticks and first aid
An injury or illness is recordable if it results in any of the following: death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness.
A significant diagnosed injury or illness is recordable even without those outcomes.
In a practice, the case to think through is the bite, and the test that decides whether it goes on the log is the line between first aid and medical treatment.
OSHA draws that line as a first-aid list, and the list is complete: any treatment not on it is medical treatment, regardless of who provides it.
On the list are cleaning or soaking wounds on the skin surface and wound coverings such as bandages, gauze, butterfly bandages or Steri-Strips.
Not on the list are sutures and staples — those are medical treatment, and they make the case recordable.
So a cat bite washed at the sink and dressed with a bandage is first aid; the same bite closed with sutures is a recordable case.
Immunizations split the same way, and the split is unusually sharp for veterinary teams: a tetanus shot is first aid, but other immunizations — rabies vaccine among them — count as medical treatment.
A bite that looked minor at the sink becomes a recordable case if post-exposure rabies shots start later.
Needlesticks carry a rule of their own: work-related needlestick injuries and cuts from sharps contaminated with another person's blood or other potentially infectious material must be recorded, with the employee's name kept off the log.
That automatic rule is about human blood — a stick from a needle used only on an animal is judged under the general criteria instead, recordable if it needs treatment beyond first aid.
Two boundaries keep this section honest.
Recording a case on the log and filing a workers' compensation claim are two separate steps; the log entry is not the claim.
And in California, Cal/OSHA's guidance says an attack on an employee by an aggressive animal at a veterinary clinic is normally not workplace violence under Labor Code 6401.9 unless a person directed it; qualifying injuries go on the 300 log as ordinary injuries.
Posting the 300A summary — and how long to keep the records
The recordkeeping year ends with a form on the wall.
The OSHA 300A annual summary must be posted no later than February 1 of the year after the year covered by the records, and it stays up until April 30.
In a practice, the practical spot is wherever employees already pass — the break room wall, the staff bulletin board — somewhere visible without anyone having to ask for it.
Before it goes up, the summary must be certified by a company executive.
The rule names who qualifies: an owner, in a sole proprietorship or partnership; a corporate officer; the highest-ranking official at the establishment; or that official's immediate supervisor.
In an owner-led practice the certification lands on the owner; in a corporate group it reaches an officer or the establishment's senior official.
The paperwork then sits on a shelf for a while.
The 300 log, the annual summary, the privacy case list if one exists, and the OSHA 301 incident reports must be kept for five years following the end of the calendar year they cover.
Those five years of records are also the raw material for your own review of which roles and tasks keep generating cases — the practical case for filing them somewhere retrievable rather than in a departed manager's inbox.
Electronic submission of Form 300A: when a vet practice has to file
A separate question is who has to send the summary data to OSHA electronically.
Under 29 CFR 1904.41, establishments with 250 or more employees that are required to keep records must submit their Form 300A information electronically each year.
Establishments with 20 to 249 employees file electronically only if their industry is designated in the subpart's appendix — and veterinary services, NAICS 5419/541940, is not designated there, nor on the list of industries with 100 or more employees that submit their log and incident-report data.
For a veterinary establishment, the electronic duty arrives at 250 or more employees, or when OSHA asks for the data in writing.
Two details matter here.
Electronic submissions are due by March 2 of the year after the calendar year covered.
And the headcount is everyone: each individual employed in the establishment at any time during the calendar year counts as one employee — full-time, part-time, seasonal and temporary workers alike.
A practice that stacks summer kennel help or temp coverage on top of its year-round staff should count honestly before assuming it sits under the threshold.
Reporting severe injuries to OSHA within 8 or 24 hours
The deadlines with real teeth are the reporting ones, and they reach every covered employer at any size — including the ones exempt from keeping logs.
A work-related employee death must be reported to OSHA within 8 hours.
An in-patient hospitalization, an amputation or a loss of an eye must be reported within 24 hours.
Reporting goes by phone to the area office, by phone to 1-800-321-OSHA, or online.
In a veterinary setting, a restraint accident, a kick, a fall in a wet run — whatever puts an employee into the hospital as an in-patient — starts a 24-hour clock that runs whether or not you keep a 300 log.
These are the federal deadlines.
States that run their own OSHA-approved plans can layer requirements of their own on top, so confirm the rule your state enforces rather than assuming the federal timeline is the whole of it.
Everything else on this page — the log, the summary on the wall, the five-year shelf — is what lets you spot patterns and fix them while injuries are still small.
The veterinary hiring hub collects the employer-side guides that cover the rest of running a safely staffed practice.
Your OSHA recordkeeping calendar
- All year: test each injury against the recording criteria the day it happens — death, days away, restricted work or transfer, treatment beyond first aid, loss of consciousness
- Hold the two first-aid lines in mind: bandages and a tetanus shot are first aid; sutures, staples and rabies post-exposure shots are medical treatment, which makes the case recordable
- By February 1: post the 300A summary, certified by a company executive, and leave it up through April 30
- By March 2: file Form 300A electronically — but only if your establishment had 250 or more employees, or OSHA asked you in writing
- After a severe event: report a death to OSHA within 8 hours; an in-patient hospitalization, amputation or loss of an eye within 24 hours
- At year end: shelve the log, the summary, the privacy case list and the 301 reports for five years after the calendar year they cover