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:

Clarification of OSHA safety requirements between a temporary staffing agency and its client

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.

November 21, 2012

Ms. Kathryn Bernard
Executive Vice President and General Counsel
Staffmark
435 Elm Street, Suite 300
Cincinnati, OH 45202

Dear Ms. Bernard:

Determining who is the responsible party to record an injury or illness

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.

October 19, 2015

Jeff Dahlquist, Jim Evilsizer, Monica Zapp
Magna Exteriors & Interiors
Nascote Industries, Inc.
18310 Enterprise Ave.
Nashville, IL 62263

Dear Mr. Dahlquist, Mr. Evilsizer, and Ms. Zapp:

Clarification of 1904.31 regarding who is responsible for recording injuries and illnesses when supervision is shared by a prime contractor and subcontractors.

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.

April 25, 2017

Mr. Fred Hartz
Holtec International
200 Braddock Avenue
Turtle Creek, PA; 15145

Dear Mr. Hartz: