Separate establishments for injury recordkeeping at one site

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

October 16, 1989

MEMORANDUM FOR: Byron R. Chadwick
Regional Administrator

THRU: Carey, Director
Office of Field Programs

FROM: Thomas J. Shepich, Director
Directorate of Compliance Programs

SUBJECT: Recordkeeping Interpretation

This is in response to your memorandum of June 9, received in this office on August 4, in which you sought policy guidance. The issues arose over calculation of LWDI rates at a Coors Brewery, where the company has a can plant, a bottle plant, and a brewery, located at the same physical site. You also had a question as to how to handle a maintenance shop at the Coors Brewery, which is a common service provided to the three operations and cannot be attributed to any single establishment except the administrative complex, which is low-hazard and would not be subject to a programmed inspection.

First, we agree with your determination that Coors does have three separate manufacturing establishments on this site. As you are aware, 29 CFR 1904.12(g)(1) treats the above-mentioned situation as a "separate establishment".

Second, the maintenance shops should be treated as a separate establishment for recordkeeping purposes. Guidance is provided in Chapter iii(A), page 19, of the BLS Recordkeeping Guidelines for Occupational Injuries and Illnesses. A separate set of logs should be kept for these employees since they are not identified exclusively with any one of the three manufacturing establishments. Additionally, because maintenance shops are not considered low hazard, they may fall within the scope of a comprehensive programmed or unprogrammed inspection, as discussed in Chapter II(B)(5)(a) of the Field operations Manual.

[June 9 regional request memorandum reproduced on OSHA page; omitted here.]