July 21, 1999

Dale J. Block
Director, Medical Services
Weirton Steel Corporation
400 Three Springs Drive
Weirton, West Virginia 26062-4989

Dear Dr. Block:

Thank you for your letter dated December 9, 1998 requesting clarification on an issue of recordability. Please excuse the delay in our response. I will respond by citing the regulations from 29 CFR Part 1904 and the Recordkeeping Guidelines for Occupational Injuries and Illnesses (Guidelines), by page and Q&A number(s), whenever possible.

Question 1: For employees who are temporarily assigned to work at a location other than their assigned location within the same facility, and

     a) who are supervised by their assigned location manager, or
     b) who are supervised by a manager at their temporarily assigned location,

is it required through a recordkeeping regulation that a recordable injury or illness be logged in the area

     a) where the incident occurred in the facility or
     b) where the employee has his regular assigned location?

Employers are required to maintain a separate OSHA Log for each of its establishments (29 CFR Part 1904.2(a) and Guidelines P 19, Section A). An establishment is defined in 29 CFR Part 1904.12(g) as, "A single physical location where business is conducted or where services or industrial operations are performed.....Where distinctly separate activities are performed at a single physical location (such as contract construction activities operated from the same physical locations as a lumber yard), each activity shall be treated as a separate establishment." Each distinctly separate activity should be considered an establishment where: (1) no one industry description in the Standard Industrial Classification (SIC) Manual, 1987 includes such combined activities; (2) the employment in each such economic activity is significant; and (3) separate reports can be prepared on the number of employees, their wages and salaries, sales or receipts, and other types of establishment data (SIC Manual 1987, Page 12).

If your facility includes more than one establishment, then separate logs for each establishment must be maintained, and each recordable case should be recorded on the log for the establishment in which the employee was injured or became ill (Guidelines P 20, Q&A 10). If your facility includes only one establishment, all recordable injuries and illnesses would be recorded on the one log. However, an employer may sub-divide an establishment's log to provide separate listings by department, but must combine all separate listings into one establishment log for all purposes, including the access, summary and posting provisions required by the recordkeeping regulations (Guidelines P 19, Q&A 4 and P 20, Q&A 6).

In sum, for each establishment, the log is used for recording and classifying recordable occupational injuries and illnesses and for noting the extent and outcome of each case. The log shows when the occupational injury or illness occurred, to whom, what the injured or ill person's regular job was at the time of the injury or illness exposure even though the employee was doing a different job, the department where the person was regularly employed even though temporarily assigned elsewhere, the kind of injury or illness, how much time was lost, and whether the case resulted in a fatality , etc. (Guidelines Chapter II, Section A and OSHA No. 200).

Question 2: Have there been any recent revisions of the recordkeeping regulations dealing with the issue of assigning recordable injuries and illnesses to a particular area within a facility?

No, however, please be aware that OSHA is currently in the process of revising its injury and illness recordkeeping requirements. We hope to have a new recordkeeping system in place by the year 2000.

I hope you find this information useful. If you have any further questions or comments, please contact the Division of Recordkeeping Requirements, at Area Code: (202) 693-1702.

Sincerely,

Cheryle A. Greenaugh
Director, Directorate of Information Technology