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Blank injury logs at construction jobsites

Summary A construction company asked whether it needed blank OSHA 200 injury logs at sites with no recordable cases. OSHA said blank logs were unnecessary, but a zero-entry summary had to be completed and retained; it described where to keep and when to post the summary. OSHA now archives the letter as potentially outdated.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1989-04-17-0
Date issued
April 17, 1989
Status
Archived by the agency
OSHA archives this letter and says it may no longer represent OSHA policy.
Status last verified October 10, 2026

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

APR 17 1989

Mr. D.L. Martin
Safety Director Fischbach Corporation
[Recipient address omitted]
Dear Mr. Martin:

This is in response to your December 9, 1988, letter and to your telephone conversation with James C. Dillard, of my staff, several weeks ago in which you sought the Occupational Safety and Health Administration's (OSHA) ruling as to whether blank OSHA-200 logs must be maintained at each jobsite where no recordable injuries or illnesses have occurred. The following guidelines are presented from the Bureau of Labor Statistics' Recordkeeping Guidelines for Occupational Injuries and Illnesses: (Copy enclosed)

a. An employer is not required to maintain blank OSHA-200 logs at the jobsite where there are no recordable injuries and illnesses. However, the summary portion of the OSHA-200 log for such jobsites must be completed with zero entries and retained for a five (5) year period. (See page 13, A-6; p.15, B-6.) The summary portion must be kept at the jobsite if the construction activity lasts one (1) year or more. Otherwise it can be kept at a field office or an established central location.

b. The summary portion of the OSHA-200 logs must be completed and posted for each establishment during the entire month of February. (See page 15, B-3.)

If there are further questions about this matter, please feel free to contact Mr. Dillard again at FTS 523-8041.

Sincerely,

Thomas J. Shepich, Director Directorate of Compliance Programs

Enclosure

[Internal referral, requester letter, and interim response reproduced on OSHA page; omitted here.]

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