Separate establishment injury logs under older rules

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

August 15, 1996

Mr. Brad Brown
Planning & Research Associate II
Department of Labor, Bureau of Labor Standards
Research & Statistics Division
[Recipient address omitted]
Dear Brad:

Thank you for your letter dated July 31, requesting interpretations concerning several OSHA injury and illness recordkeeping issues. I will address each issue by first repeating the question and by referring to the appropriate Q&A and page numbers in the Recordkeeping Guidelines for Occupational Injuries and Illnesses.

Q1. May records be kept for each department rather than for an establishment as a whole? Everything would still be recorded but would not be together on one form.

A1. Employers are required to maintain a separate OSHA Log for each of its establishments. An establishment is defined as single physical location where business is conducted or where services or industrial operations are performed. An employer may sub-divide the Log to provide separate listings by department, but must consider the combination of all separate listings to be one Log for all purposes, including the access, summary and posting provisions required by the recordkeeping regulations.

Q2. May records be kept for all establishments in a region together on one form?

A2. For OSHA injury and illness recordkeeping purposes, employers are required to maintain a separate OSHA Log for each of its establishments. An establishment is defined as single physical location where business is conducted or where services or industrial operations are performed (page 19, section A). While the recordkeeping process may be centralized in a region, etc., records for multiple establishments in a region may not be consolidated on one form and meet OSHA's requirements (page 21, section C).

Q3. Can the attached accident report be regarded as an equivalent to the OSHA 101?

A3. The form is missing the following data fields found on the OSHA 101: Employer name, address and location; case or file number from the OSHA Log 200 (if different from the claim number); place of accident/exposure; what the employee was doing at the time of the accident/exposure; did the employee die; and the name and title of the person who prepared the report (if different from the employee's supervisor). If you add or attach this information to your form, it will be an acceptable equivalent (page 18, C-7).

I hope you find this information on the current system useful. If you have any further questions, please call us at Area Code (202) 219-6463.

Sincerely,

Bob Whitmore Chief Division of Recordkeeping Requirements