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Separate injury log for a shared warehouse

Summary A company asked whether a warehouse shared by two manufacturing sites needed its own injury and illness log, even though no workers were permanently assigned there. OSHA said the warehouse was a separate establishment under the then-current rules and required a separate OSHA 200 log. OSHA marks the letter archival.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1998-04-14-0
Date issued
April 14, 1998
Status
Archived by the agency
OSHA labels this letter an archive document that may no longer represent OSHA policy; it discusses former OSHA 200 logs.
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1904 Recordkeeping Establishments
Source
View the official document

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The current status of this document is unclear
OSHA labels this letter an archive document that may no longer represent OSHA policy; it discusses former OSHA 200 logs. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

April 14, 1998

Michael Stevens
Safety Coordinator
Moore Response Marketing Services
[Recipient address omitted]
Dear Mr. Stevens:

Thank you for your letter of January 29 to John Miles asking for a clarification of OSHA's injury and illness recording and reporting regulations (Part 1904 of Title 29 of the Code of Federal Regulations) for a shared warehouse. Your letter was forwarded to OSHA's Office of Statistics, which is responsible for interpreting the 1904 regulations.

Your question involves a warehouse facility being used by two separate manufacturing establishments. The warehouse is staffed by employees from the two manufacturing facilities who work at the warehouse on a intermittent basis depending on the workload. At any given time there may be zero to four employees working at the facility, but there are no employees assigned permanently to the warehouse location.

The recordkeeping regulations, at 1904.2(a) require a separate OSHA 200 Log for each establishment. The warehouse you have described is a separate establishment from each of your manufacturing facilities. Therefore, you should maintain a separate OSHA Log for the warehouse facility. This question is addressed by Question A-2 on page 19 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses (enclosed).

Should you have any additional concerns in this matter, please contact the Division of Recordkeeping Requirements at (202) 219-6463. Thank you for your interest in occupational safety and health.

Sincerely,

Ruth McCully
Acting Coordinator,
OSHA Information Technology

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