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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

April 14, 1998

Michael Stevens
Safety Coordinator
Moore Response Marketing Services
2660 South Broadway
P.O. Box 19050
Green Bay, Wisconsin 54307-9050

Dear Mr. Stevens:

Thank you for your letter of January 29 to John Miles asking for a clarification of OSHA's injury and illness recording and reporting regulations (Part 1904 of Title 29 of the Code of Federal Regulations) for a shared warehouse. Your letter was forwarded to OSHA's Office of Statistics, which is responsible for interpreting the 1904 regulations.

Your question involves a warehouse facility being used by two separate manufacturing establishments. The warehouse is staffed by employees from the two manufacturing facilities who work at the warehouse on a intermittent basis depending on the workload. At any given time there may be zero to four employees working at the facility, but there are no employees assigned permanently to the warehouse location.

The recordkeeping regulations, at 1904.2(a) require a separate OSHA 200 Log for each establishment. The warehouse you have described is a separate establishment from each of your manufacturing facilities. Therefore, you should maintain a separate OSHA Log for the warehouse facility. This question is addressed by Question A-2 on page 19 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses (enclosed).

Should you have any additional concerns in this matter, please contact the Division of Recordkeeping Requirements at (202) 219-6463. Thank you for your interest in occupational safety and health.


Ruth McCully
Acting Coordinator,
OSHA Information Technology