Keeping Injury Records for Every Establishment

By Lisa Neuberger, EHS Editor at J. J. Keller & Associates, Inc.

Employers covered by the injury and illness recordkeeping provisions of Part 1904 must create and maintain a 300 Log for each establishment. Understanding how OSHA defines an “establishment” is critical to complying with those requirements.

Normally, an establishment is a single physical location. In some cases, one location could be two or more establishments, but only if the location has two or more distinct businesses with different NAICS codes. For example, if a construction company operates from the same location as a lumber yard, the employer may consider each business to be a separate establishment.

On the other side of that coin, several locations could be considered one establishment, but only if they are in close proximity, operate as a single location, and share one set of business records. For example, a manufacturing establishment might include the main plant, a warehouse a few blocks away, and an administrative building across the street.

For industries such as construction or transportation, employees might not work at a fixed location. In those cases, their establishment is the branch or main office from which they are supervised or carry out their work.

Similarly, employees who work from home must be linked to one establishment. Again, this should be the location from which they are supervised or receive job assignments.

Temporary Locations

You must keep a separate 300 Log for each establishment expected to be in operation for one year or longer. You do not need a separate 300 Log for establishments that exist for less than one year, but you do need to capture any recordable cases to employees at temporary locations.

You could keep one 300 Log that covers all short-term establishments or create 300 Logs covering short-term establishments based on company divisions or geographic regions. You may not, however, lump the temporary establishment employees on the 300 Log for a fixed or long-term establishment.

Multiple Locations

If you have more than one location, some employees might travel between them. If an employee has a recordable incident while working at another location, the case must be recorded on the 300 Log for the establishment where the incident occurred, even if the employee normally works elsewhere.

However, if an employee has a recordable incident and is not at any of your establishments (such as traveling between locations), you must record the case on the 300 Log for the establishment where the employee normally works or is linked.

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