Clarifying OSHA Recordkeeping Regulations for Multiple Businesses

Author
Stephanie McCauley

300-Log-For-Multiple-Establishments-Clarification-blog-photo-4.14

Contractor Earl Has Several Ongoing Jobs, What Should He Do?

The OSHA Recordkeeping regulation requires employers keep a record of serious injuries and illnesses using the OSHA 300 Log. And although it sounds simple enough, the particulars of which employees are covered, how many separate logs need to be used, and what types of injuries are serious enough to be reported can get complicated enough that OSHA updates their Frequently Asked Questions (FAQ) and Letters of Interpretation (LOI) websites. Contractor Earl has several ongoing jobs, what should he do?

In February 2014, OSHA answered several questions from a business asking for more details about the requirement to keep a separate OSHA 300 Log for multiple business establishments, 1904.30.

1904.30 Multiple Business Establishments

The basic requirements start with the idea that each establishment expected to be working for at least one year must have its own separate OSHA 300 Log. One OSHA 300 Log can be kept for all shorter-term establishments. The records can be kept at headquarters if information of an injury can be logged within seven days, and the records can be quickly sent to the establishment.

Every employee must be linked to an establishment. Also, if an employee is injured while at a different establishment, the record must be logged where the injury occurred. If an employee is injured away from a company establishment, the case must be logged where the employee normally works.

FAQs

Question: For a company that has employees working at many locations controlled and operated by clients, does that company need to have a separate OSHA 300 log for each client site?

OSHA Response: If the company has a continuous presence at a client’s site, like an office at the job site for at least one year they need to maintain an OSHA 300 log.

Question: When the company has to keep OSHA 300 logs, can they keep them at headquarters?

OSHA Response: Yes, Section 1904.30(b)(2) allows that if the company can produce copies of injury and illness forms when permitted access is requested.

Question: Where should the company record employee injuries at a remote location not associated with a company building or a client’s site?

OSHA Response: To make sure all employees are included in a company’s records, injuries at remote locations must be recorded at the home establishment that employee is linked to. If an employee works at several locations, making one establishment impractical, they should be linked to a general OSHA 300 log for short-term establishments.

Question: Does posting the OSHA 300-A Summary Form electronically for all employers to review satisfy OSHA’s posting requirements?

OSHA Response: A hard copy of that form must be posted conspicuously at each establishment where notices are normally posted.

Question: Where does the company with several locations post the annual summary?

OSHA Response: Post the annual summary at the employee’s home establishment.

Interpretations

In addition to creating new and updating current regulations, OSHA publishes interpretations and answers to questions about existing rules.

  • Construction’s Electrical Power Regulations Final Rule
  • Cranes and Derricks Near Power Lines
  • Recordkeeping for Multiple Business Establishments
  • How to Decide It’s a Workplace Injury
  • Safety Data Sheet (SDS) Reporting of Petroleum Streams
  • Combustible Dust Labeling Requirements in Hazard Communication Standard (HCS)
  • OSHA Definition of A HNOC Clarified for the HCS
  • General Duty Clause Covers All Impalement Hazards
  • Employer Responsible for Determining Qualified Rigger Status

We have complete OSHA compliant safety solutions for all your needs. Call (877) 959-8373 today to speak with one of our highly skilled safety experts.

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