OSHA 300 Logs for Multiple Establishments and Short-Term Jobsites

A company with one workplace can usually identify the right injury Log without much discussion. The decision gets harder when a crew moves between projects, a technician visits a customer's property, or an employee from one branch is injured at another. A central safety team may receive every incident report, yet the OSHA 300 record still has to be associated with the correct establishment or permitted short-term group.

For an employer that is required to keep records under OSHA Part 1904, 29 CFR 1904.30 supplies the core allocation rules. An establishment expected to operate for one year or more generally has its own OSHA 300 Log. Short-term establishments are still covered by the recordkeeping duty, but the employer may combine their cases in a permitted short-term Log. Workers who move around must be linked to an establishment. Where a case occurred can then decide which Log receives it.

This page answers that allocation question. It does not decide whether the employer is covered in the first place, whether a particular injury is recordable or which employer records a temporary worker supervised by two businesses. Those are separate questions. The live Complys overview of OSHA 300 and 300A covers the wider form system.

Start with coverage, then map establishments

Do not create a separate Log for every address in a spreadsheet before checking coverage and what OSHA means by an establishment. The small-employer partial exemption uses the entire company's peak employment in the previous calendar year. The industry partial exemption is assessed by establishment classification. A company with activities in different industries may therefore have covered establishments and partially exempt establishments. A regulator's written request can also require records despite a routine partial exemption.

If Part 1904 recordkeeping applies, section 1904.46 generally defines an establishment as a single physical location where business is conducted or services or industrial operations are performed. For work where employees do not operate from one fixed place, the definition points to a main or branch office, terminal, station or similar base that supervises the activity or from which staff carry it out. It also contains limited rules for treating multiple operations at one location separately or combining nearby locations. A mailing address alone does not resolve that fact-specific definition.

Create an internal establishment list that identifies each covered long-term location, expected operating period, supervising base for mobile staff and recordkeeping contact. The list is an editorial management tool, not a separate OSHA form. Its value is consistency: without one, a case can be duplicated at headquarters and a project or vanish between both.

Long-term sites normally need their own Logs

Section 1904.30, paragraph a requires a separate OSHA 300 Log for each establishment expected to operate for one year or longer. This is about the establishment's expected duration, not whether someone happened to be injured there. A covered location with zero recordable cases still needs to be considered in the annual recordkeeping process.

The rule matters to a contractor that occupies a dedicated client-site space for a continuing service contract. OSHA's 2014 interpretation says that, under the facts in that letter, a company's continuous physical presence at a client's site for a year or more is treated as an establishment requiring a separate Log. The letter explains the regulation for those facts; it is not a universal rule that every visit to a customer creates a separate establishment. The actual arrangement, expected duration and who supervises the work must be examined.

Once an establishment is identified, keep its cases associated with it even if a corporate office stores the file. Separate where the Log belongs from where its electronic or paper copy is held. A central database can hold several establishment-specific Logs without turning them into one combined long-term Log.

Short-term jobsites can share a Log

OSHA defines a short-term establishment in this provision as one expected to exist for less than a year. Under section 1904.30, paragraph b1, an employer still keeps injury and illness records for such establishments but need not maintain a separate OSHA 300 Log for each one. It may keep one Log covering all short-term establishments or group short-term establishments in Logs for company divisions or geographic regions.

That option is useful for companies with many brief projects, repair jobs or service assignments. It does not mean the company can ignore injuries from short projects. A case still needs to reach the recordkeeping owner and appear once on the appropriate Log if it is recordable. Nor does a short-term site automatically become the host company's OSHA establishment merely because work takes place on the host's premises. Check who operates the establishment and the Part 1904 facts.

An employer should choose a defensible grouping method and use it consistently. For example, a contractor might group brief projects by region, while maintaining separate Logs for long-term offices and long-term sites. OSHA's 2015 interpretation says the employer may choose any case numbering system as long as cases on a given Log have unique numbers. An internal project identifier can help trace the event back to its location, but the letter does not prescribe a particular code format.

If an assignment initially expected to be short becomes a continuing operation, revisit the establishment determination. Do not let the original scheduling assumption persist without checking the actual and expected operation. That review is a sensible internal control; the precise treatment of a particular transition may need case-specific analysis of the regulation and current OSHA guidance.

Where does a travelling employee's case go?

An employee may work at several company sites, visit customers or operate on the road. Section 1904.30, paragraph b3 requires the employer to link each employee with one establishment for recordkeeping. A qualifying case belongs on the injured employee's linked establishment Log or on a Log covering the relevant short-term establishment. That link should be established before an incident forces a rushed decision.

The rule then distinguishes another of the employer's establishments from a location that is not one of the employer's establishments. Under section 1904.30, paragraph b4, if an employee of one establishment is injured or becomes ill while visiting or working at another of that employer's establishments, the case is recorded on the Log of the establishment where it happened. If the event occurs away from any of the employer's establishments, it is recorded on the Log of the establishment where the employee normally works.

Consider an employee based at Branch A who visits Branch B, another establishment of the same employer. If a recordable case occurs at Branch B, section 1904.30 directs it to Branch B's Log. Now consider the same employee doing work at a customer location that is not an establishment of the employer. If a recordable case occurs there, the rule points to the establishment where that employee normally works. These examples assume the case meets the recording criteria. They do not decide whether a client location has become the employer's own long-term establishment.

For staff who work remotely or do not report to a single facility, make the link explicit in internal records. Section 1904.46 says a telecommuting employee's home is not a separate OSHA establishment and the employee must be linked to an establishment under section 1904.30. OSHA's 2014 interpretation also discusses remote employees under a specific set of facts. Neither source makes every home injury work-related. Work-relatedness remains a separate test under Part 1904.

What if the worker is supplied by another employer?

The establishment allocation rule does not settle which employer must record a temporary or contract worker's injury. Section 1904.31 says covered employers record employees on their payroll and also employees not on their payroll whom they supervise day to day. It directs businesses and staffing providers to coordinate so a temporary or leased worker's injury is recorded once by the employer with the relevant day-to-day supervision.

Determine the recording employer before selecting that employer's Log. Do not treat the site owner's property boundary, invoice relationship or employee badge as a substitute for the supervision facts. This page addresses the next step: once the responsible employer is identified, which establishment or short-term group in that employer's recordkeeping system receives the case?

The same distinction helps avoid duplicate entries. A host can keep an internal incident report for its own investigation even where another employer is responsible for the Part 1904 entry. An internal incident record and an OSHA 300 Log entry are not identical documents. Their existence should not be used to infer that two employers must each record the same case.

Can headquarters store every Log?

Yes, subject to conditions. Section 1904.30, paragraph b2 allows an employer to maintain an establishment's records at headquarters or another central location if injury and illness information can reach that location within seven calendar days of the employer receiving information that a recordable case occurred. The employer must also be able to produce and send records back to the establishment within the access time frames that apply when government representatives or employees request them under sections 1904.35 and 1904.40.

Central storage is therefore an operational promise, not merely a choice of software folder. Local supervisors need a route to send case facts promptly. The central team needs a way to retrieve the correct establishment's records and return them within the relevant deadline. Section 1904.35 addresses employee access, while section 1904.40 addresses authorized government requests. Their recipients and timing should be checked for the actual request.

The employer may use electronic records if it can produce equivalent forms when needed under section 1904.29. That does not prove that a particular vendor product can generate a valid form or satisfy a request. Test the actual output and access workflow before relying on a system for statutory records.

Do not mix Log allocation with 300A posting or ITA submission

Three related processes are often compressed into the instruction “send everything to corporate.” They should remain distinct. First, the employer decides which OSHA 300 Log owns a recordable case under section 1904.30. Second, it prepares and posts the annual Form 300A under section 1904.32. Third, an establishment that meets the separate electronic submission categories submits the required data through the ITA.

The company-wide small-employer test and establishment-specific industry exemption should not be confused with the ITA's establishment categories. A multi-site employer can have different recordkeeping and electronic submission outcomes among its locations. The site inventory should keep the reasons for each coverage decision, rather than one company-wide “OSHA 300 required” checkbox.

OSHA's 2014 interpretation explains that displaying the 300A electronically to all employees did not satisfy the physical posting requirement in the circumstances addressed. The summary belongs where the regulation requires posting for the relevant establishment. Keep the question of whether a short-term site has its own Log separate from any site-specific posting question. If a complex network of short-term sites and remote workers raises a posting issue, apply the actual rule and current OSHA guidance rather than assuming one corporate intranet page solves it.

A practical case-allocation sequence

OSHA's regulation gives the legal rules. The following sequence is an internal decision aid, not an official OSHA form or substitute for the case facts.

1. Check routine recordkeeping coverage. Use the company-wide size test and each establishment's industry classification. Record any regulator instruction that changes an exemption outcome. 2. Identify the responsible employer. If the injured worker is supplied by another business, check day-to-day supervision under section 1904.31 before allocating the case among your Logs. 3. Decide whether the case is recordable. Apply the work-relatedness, new-case and recording criteria. A location decision does not prove recordability. 4. Locate the event. Did it happen at one of your own establishments, at a short-term establishment, at another of your long-term establishments or away from all of them? 5. Check the worker's linked establishment. For mobile or remote workers, identify the establishment assigned for recordkeeping and where the worker normally works. 6. Apply section 1904.30. Use the occurrence establishment when the injury happened at another of your establishments. Use the normally worked establishment when the event was away from all your establishments. Use the permitted short-term Log where that is the relevant establishment structure. 7. Preserve retrievability. If corporate staff keep the file, confirm local-to-central information transfer and the ability to return the correct records when requested. 8. Review connected duties separately. The annual summary, posting and ITA decision have their own conditions. Do not use an enterprise case list as a replacement for establishment-specific statutory records.

An internal master list can record establishment name, supervising base, expected duration, short-term grouping, worker assignment, Log owner and annual-summary contact. That list is a process recommendation. OSHA does not prescribe this particular format. It makes it easier to explain why a case appears on one Log rather than another and to spot a case that has been counted twice.

The decision to document before choosing software

For a multi-site employer, the critical question is not simply whether a system can store incidents. It is whether the organization's process can identify the responsible employer, correct establishment, correct year and correct OSHA form while preserving access to the underlying evidence. A central system should not silently merge all cases into one company Log when separate establishment Logs are required. Nor should a short-term site vanish because it was never assigned to a region or supervising base.

Use the general Complys OSHA 300 guide for the broader forms and coverage picture. If you are assessing software for a multi-site operation, explore Complys for US businesses and ask to see the current establishment and record-export workflow. Confirm any OSHA-specific form, allocation or submission capability in the product before relying on it. The federal allocation rules remain the employer's responsibility to apply to its actual sites and workers.

Related guides

See also: OSHA 300 Privacy Concern Cases: the Log and Confidential List, Temporary Worker Injury: Host or Staffing Agency OSHA 300 Log?.