- Standard Number:
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.
November 13, 1992
Ms. Joan L. Davis, RN, MS
716 Westshore Drive
Shorewood, Illinois 60436
Dear Ms. Davis:
Thank you for your letter dated October 21 requesting an interpretation of the OSHA injury and illness recordkeeping requirements. For employees who normally report to one location but are injured or become ill at another of the employer's establishments where they are temporarily working, a recordable case would be entered on the Log of the establishment in which they were injured or became ill. For the example in your letter, the case should be recorded on the California Log. This guidance can be found in Q&A A-10 on page 20 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses. The reasoning behind this interpretation lies with the purpose of the OSHA Log 200, to present an accurate picture of the injury and illness history of the establishment to which it pertains.
Length of time and type of training are immaterial in deciding on which log to enter a recordable case. However, it is necessary that the establishment in question be in the same corporate structure as the employee's home establishment. The above concept only applies to multiple establishments of the same company. An "employee's" recordable injury or illness is not to be entered on the Log of another employer.
I hope you find this information useful. If you have any further questions, please contact my staff at Area Code (202) 219-6463.
Stephen A. Newell
Director Office of Statistics
October 21, 1992
Steve Newell, Dir.
Office of Statistics
Division of Recordkeeping Requirements
Frances Perkins Building
200 Constitution Drive
Washington, DC 20210
Dear Mr. Newell:
As an Occupational Health Nurse I frequently speak on OSHA recordkeeping both within my professional community and in my role as co-instructor, OSHA Training Institute for the course "OSHA-Overview for the Occupational Health Nurse."
Because a specific question frequently surfaces, I am requesting a written clarification. The question involves an employee who becomes injured while attending a meeting or short term training located at another one of his company's facilities. I am requesting clarification on what log the injury should be recorded--the place of employment to which the employee normally reports or the log of the facility where the injury actually occur? While I have always believed the case should be recorded on the home facility log, others have questioned this, which prompts my present request.
To clarify, let me give an example. A computer operator who works for Company A located in Wisconsin goes to his corporate headquarters in California. Unfortunately, during a 2-week training session, a clumsy instructor drops a keyboard on the employee's foot, and the employee suffers a recordable injury. Please advise where the injury should be recorded on the OSHA log in Wisconsin or California?
I would appreciate the reasoning used to arrive at the answer to this question, with citation, if possible, or relevant comments in the Recordkeeping Guidelines... Also, what effect if any would the length of time the employee is in training or the fact that the student employee was involved in actual hazardous operation of training?
I appreciate your time and effort in responding to these questions and will share this clarification with others.
Joan L. Davis, RN, MS