A recordkeeping conundrum

Responding is Lisa Neuberger, editor – workplace safety, J. J. Keller & Associates Inc., Neenah, WI.

One common injury and illness recordkeeping challenge arises when a company has its headquarters located in one state but has offices or subsidiaries located in others. Things get more complicated if the company employs teleworkers or remote workers, such as custodial service workers, who do not report to an office at all.

The key to unlocking these recordkeeping challenges is to understand OSHA’s definition of an “establishment.” OSHA says you must keep a separate OSHA log for each establishment that is expected to be in operation for a year or longer. An establishment, according to the regulations, is a “single location where business is conducted or where services or industrial operations are performed.”

For a large company with satellite operations in several states, each of those locations would be required to maintain its own OSHA 300 log, post its own 300A Summary, and complete the accompanying 301 Incident Reports (or equivalent forms) if they will be in operation for a year or longer.

Many companies want to keep the records for all of their locations in one place. OSHA allows you to centralize records, provided you can:

• Transmit information about injuries and illnesses to the central location within seven calendar days.
• Produce the records within four hours for OSHA or state inspectors, or within one business day for an employee or former employee.

For employers with short-term establishments, such as construction sites, the agency also allows you to keep one log covering all of your short-term sites. You can also keep one log for all your short-term establishments for individual company divisions or geographic regions. For example, a theater production company that is producing plays in several states may keep separate logs for each state along with another OSHA 300 log for each production that is expected to be running for a year or longer.

But what about staff who report to customers’ worksites? OSHA requires you to link each of your employees with one of your establishments. You can also link the employee with your home office or with one of the logs that covers your short-term establishments.

In all cases, you must post a copy of the annual summary from Feb. 1 to April 30 in each establishment where notices are normally posted. OSHA has said that for employees who work in remote locations or at a client’s site, an annual summary posted at the employee’s home or linked establishment will satisfy the requirement.

OSHA-approved State Plan states may have slightly different injury and illness recordkeeping requirements, so be sure to check on your state recordkeeping obligations.

In a nutshell, OSHA wants to make sure that no employee is overlooked in the injury and illness recordkeeping process. Whether you have locations all over the country, employees working remotely or several short-term work sites, you can meet OSHA’s recordkeeping requirements by making sure no work-related injuries or illnesses are missed.

Editor's note: This article represents the independent views of the author and should not be construed as a National Safety Council endorsement.