Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

July 14, 1993

Mr. Baruch A. Fellner
Gibson, Dunn & Crutcher
1050 Connecticut Avenue, N.W.
Washington, D.C. 20036-5306

Dear Mr. Fellner:

Thank you for your letter dated June 18, requesting an interpretation concerning the location and maintenance of OSHA injury and illness records for employees working at off-site locations. Guidance on location of records can be found in sections B and C on pages 20 through 22 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses.

Assuming that an employee reports to a specific off-site location for more than one year, that off-site location would be considered a fixed establishment for OSHA injury and illness recordkeeping purposes (see Q&A B-4, page 21 of the Guidelines). Records for employees working at fixed locations should be kept at the work location.

It is possible to prepare and maintain the Log at an alternate location if two requirements are met: (1) Sufficient information must be available at the alternate location to complete the Log within 6 workdays after receipt of information that a recordable case has occurred; and (2) a copy of the log updated to within 45 calendar days must be present at all times in the establishment (see section C, page 21 of the Guidelines). Please be aware that the location exception applies only to the Log, and not to the other OSHA records (e.g. Supplementary Record of Occupational Injuries and Illnesses, OSHA 101).

If the establishment maintains the Log on computer on site, and is capable of printing it immediately upon request, it will be considered to be within compliance of 29 CFR 1904.2.

I hope you find this information helpful. If you have any further questions, please contact my staff at Area Code (202) 219-6463.


Stephen A. Newell Director
Office of Statistics