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How should an employer keep records for multiple establishments?
  • Employers must maintain separate OSHA 300 Logs for each establishment, if the business includes multiple establishments.

When an employer has multiple business establishments, it must keep a separate Occupational Safety and Health Administration (OSHA) 300 Log for each one that is expected to be in operation for a year or longer.

An establishment is a single physical location where business is conducted or where services or industrial operations are performed. For activities where employees do not work at a single physical location, such as construction, transportation, communications, electric, gas and sanitary services, and similar operations, the establishment is represented by main or branch offices, terminals, stations, etc. that either supervise such activities or are the base from which personnel carry out these activities.

Normally, one business location is only one establishment. Under limited conditions, the employer may consider two or more separate businesses that share a single location to be separate establishments. An employer may divide one location into two or more establishments only when:

  • Each of the establishments represents a distinctly separate business;
  • Each business is engaged in a different economic activity;
  • No one industry description in the North American Industry Classification System (2007) codes applies to the joint activities of the establishments; and
  • Separate reports are routinely prepared for each establishment on the number of employees, their wages and salaries, sales or receipts, and other business information.

For example, if an employer operates a construction company at the same location as a lumber yard, the employer may consider each business to be a separate establishment.

An establishment can include more than one physical location, but only under certain conditions. An employer may combine two or more physical locations into a single establishment only when:

  • The employer operates the locations as a single business operation under common management;
  • The locations are all located in close proximity to each other; and
  • The employer keeps one set of business records for the locations, such as records on the number of employees, their wages and salaries, sales or receipts, and other kinds of business information.

For example, one manufacturing establishment might include the main plant, a warehouse a few blocks away, and an administrative services building across the street.

For short-term establishments, employers can keep one OSHA 300 Log that covers all the short-term establishments and include the short-term establishments’ recordable injuries and illnesses on an OSHA 300 Log that covers short-term establishments for individual company divisions or geographic regions.

Can records be kept at company headquarters or another central location?

An employer may keep records for an establishment at its headquarters or other central location if the employer can:

  • Transmit information about the injuries and illnesses from the establishment to the central location within seven calendar days of receiving information that a recordable injury or illness has occurred; and
  • Produce and send the records from the central location to the establishment within the time frames required by 1904.35 and 1904.40 when required to provide records to a government representative, employees, former employees, or employee representatives.

How do employers keep records for employees who work at several different locations or do not work at an establishment?

For recording purposes, employees who work at several different locations or do not work in a specific location (like working from home) must be linked to one of the employer’s business locations. This is usually the location from which the remote worker is supervised or receives work instructions. Remote workers and their hours worked get counted on the 300 Log and 300A for the linked location, even if those employees work remotely from a different state.

When an employee from one location is injured or becomes ill while visiting or working at another of the same employer’s locations, the injury or illness should be recorded on the OSHA 300 Log of the location at which the injury or illness occurred. If an employee is injured or becomes ill while working away from any of the employer’s business locations, record the case on the 300 Log at the location where the employee normally works.