May an employer keep the OSHA injury and illness records for all their establishments at the headquarters.

Frequently Asked Questions

Question: May an employer keep the OSHA injury and illness records for all their establishments at the headquarters.

Answer:

Yes. Section 1904.30(b)(2) provides that employers can keep injury and illness records for all establishments at their headquarters or other central location. However, section 1904.30(b)(2) makes clear that this is only permitted when the employer can (1) transmit information about injuries and illnesses from the establishment to the central location within seven calendar days of receiving information that a recordable injury or illness has occurred, and (2) produce copies of the injury and illness forms when access to them is needed by a government representative, employee or former employee, or an employee representative, as required by sections 1904.35 and 40. Also, employers must physically post the OSHA 300A Annual Summary at each establishment where the employer maintains an OSHA form 300 from February 1st through April 30th each year per 1904.32(b)(6).

Clarification of Multiple Business Establishments and Covered Employees

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 https://www.osha.gov.

August 10, 2011

Mr. Brent Clark
Seyfarth Shaw LLP
131 South Dearborn Street
Suite 2400
Chicago, Illinois 60603

Dear Mr. Clark:

How to maintain logs for employees across multiple locations.

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 https://www.osha.gov.

June 25, 2015

Feliza Guerrero
Excel Building Services
1061 Serpentine Lane
Suite H
Pleasanton, CA 94566

Dear Ms. Guerrero:

Clarification of Multiple Business Establishments and Covered Employees

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 https://www.osha.gov.

February 28, 2014

John D. Smart
500 Winstead Building
2728 N. Harwood Street
Dallas, Texas 75201

Dear Mr. Smart: