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Choosing an establishment injury log

Summary A pharmaceutical employer asked which of its two facilities should record an injury when a worker was temporarily at the other site. OSHA said the case belonged on the log for the establishment where the worker was injured under the former OSHA 200 rules. OSHA labels the letter archival.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1999-07-14
Date issued
July 14, 1999
Status
Archived by the agency
OSHA labels this letter an archive document that may no longer represent OSHA policy; it cites former OSHA 200 log guidance.
Status last verified October 9, 2026

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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OSHA labels this letter an archive document that may no longer represent OSHA policy; it cites former OSHA 200 log guidance. 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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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OSHA archive notice: "This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only."

July 14, 1999

Scott Holt
Manager, Safety and Ecology
Knoll Pharmaceutical Company
[Recipient address omitted]

Dear Mr. Holt:

Thank you for your letter of April 1, 1999 requesting written confirmation of an interpretation you received verbally concerning which of two facilities of the same company should record an injury on its log. I will cite the Recordkeeping Guidelines for Occupational Injuries and Illnesses (Blue Book) whenever possible.

Question: If an employee was hurt while at another facility of the same company, which facility should record the injury on the OSHA 200 log?

Answer: In most instances, employees are injured in the establishment to which they normally report. In these situations, a recordable case would be entered in the records of that establishment. In some cases, employees may normally report to one location, but be injured at another one of the employers' establishments where they are temporarily working. In these situations, a recordable case would be entered on the records of the establishment in which they were injured or became ill (Guidelines P 20, Q&A 10). If your company includes more than one establishment, then separate logs for each establishment must be maintained, and each recordable case should be recorded on the log for the establishment in which the employee was injured or became ill.

I hope you find this information useful. If you have any further questions or comments, please contact the Division of Recordkeeping Requirements, at Area Code: (202)693-1702.

Sincerely,

Cheryle A. Greenaugh
Director, Directorate of Information Technology

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