OSHA Recordkeeping for Multiple Locations: A Guide for Multi-Site Employers

Employers operating across multiple worksites face a common question: how should OSHA injury and illness records be organized when the company has more than one location? The answer depends on understanding what OSHA considers an "establishment" and applying the rules in 29 CFR Part 1904, especially §1904.30 (multiple establishments) and §1904.46 (establishment definition).

This guidance assumes you're required to keep OSHA injury and illness records. If your company had 10 or fewer employees at all times during the last calendar year (company-wide), you do not need to routinely keep OSHA injury and illness records unless OSHA or the Bureau of Labor Statistics informs you in writing that you must keep records under §1904.41 or §1904.42. However, all employers covered by the OSH Act must still report to OSHA any work-related incident that results in a fatality, the in-patient hospitalization of one or more employees, an amputation, or a loss of an eye, as required by §1904.39.

Some individual establishments are also partially exempt if they are classified in an industry listed in Appendix A to Subpart B (based on the establishment's NAICS classification), unless OSHA/BLS requires recordkeeping in writing; this exemption also does not change the §1904.39 severe-incident reporting requirement.

This guide explains OSHA recordkeeping requirements for multiple locations, including when separate logs are required, how to handle short-term sites, and where to record injuries for employees who work at more than one place. Getting this structure right matters. Because many Part 1904 duties are establishment-based, recordkeeping errors across multiple establishments can increase citation exposure.

OSHA's enforcement policy allows (in appropriate, discretionary cases) instance-by-instance (IBI) citation items and separate penalties for certain violations, including other-than-serious recordkeeping violations, when OSHA determines it is needed for deterrence.

What Counts as an Establishment Under OSHA Recordkeeping Rules

An establishment is a single physical location where business is conducted or where services or industrial operations are performed, according to 29 CFR 1904.46. Before deciding how many OSHA 300 Logs your company needs, you must first identify how many establishments you have.

For employers whose workers do not report to a single physical location (i.e., where employees do not work at a single physical location), the establishment is the main office, branch office, terminal, or station that supervises those activities or serves as the base from which employees work. A regional service office that dispatches technicians to customer sites, for example, would be the establishment for those technicians.

OSHA also allows some flexibility in how locations are grouped. Two or more physical locations can be treated as a single establishment if they operate under common management, are located close to each other, and share one set of business records. A manufacturing plant with a warehouse across the street and an administrative building next door could qualify as one establishment under these conditions.

OSHA allows a single physical location to be divided into two or more establishments only under limited conditions. You may divide one location only when:

1. Each is a distinctly separate business
2. Each is engaged in a different economic activity
3. No single NAICS code applies to the joint activities
4. Separate routine reports are prepared for each establishment (employees, wages, sales/receipts, etc.)

In practice: A company that runs both a retail operation and a repair shop at the same address, each with its own accounting and workforce records, may treat them as two separate establishments if all four conditions are met.

One important clarification: an employee's home is not an establishment. Workers who telecommute must be linked to one of the employer's actual establishments for recordkeeping purposes.

The Separate Log Requirement

Employers must keep a separate OSHA 300 Log for each establishment expected to be in operation for one year or longer, according to 29 CFR 1904.30(a). OSHA requires employers to use Forms 300, 300A, and 301 (or equivalents). You must keep a separate Form 300 Log for each establishment expected to operate for one year or longer, prepare and post an annual Form 300A summary for each establishment, and complete a Form 301 incident report (or equivalent) for each recordable case. You must post the 300A no later than February 1 of the following year and keep it posted until April 30.

Because Part 1904 duties apply at the establishment level, repeated recordkeeping deficiencies across multiple establishments can increase citation exposure. In some cases, OSHA may also use instance-by-instance citation items where its policy criteria are met.

For guidance on completing the incident report that accompanies each recordable case, see our guide to OSHA Form 301 requirements.

Handling Short-Term Establishments

Not every worksite requires its own dedicated log. Under 29 CFR 1904.30(b)(1), establishments expected to exist for less than one year are considered short-term, and employers have flexibility in how they organize records for these sites.

For short-term establishments, employers may keep one OSHA 300 Log that covers all such sites company-wide. Alternatively, records for short-term sites can be grouped by company division or geographic region. A company with temporary project sites in multiple states might maintain one short-term log per state rather than one per site.

The challenge is determining whether a site qualifies as short-term at the outset. The regulation uses the phrase "expected to be in operation," which requires a judgment call when project timelines are uncertain. Because the rule is based on what the site is expected to be at the time, employers should document their good-faith expectation. If circumstances change and a site becomes expected to operate for one year or longer, treat it as an establishment going forward and maintain establishment-specific records as required. When in doubt, treating a site as a full establishment (with its own log) is the safer approach.

Common mistake: Assuming all field project sites are automatically short-term. If your company has a continuous presence at a client's site (i.e., a physical space at the job site for one year or longer), you must treat it as an establishment and maintain an OSHA 300 Log.

Central Recordkeeping for Multiple Establishments

Employers are not required to physically store records at each establishment. Under 29 CFR 1904.30(b)(2), records may be kept at headquarters or another central location if you meet two conditions:

1. Transmit information about work-related injuries and illnesses from the establishment to the central location within 7 calendar days of receiving information that a recordable injury or illness has occurred.
   
   
2. Produce and send the records from the central location to the establishment within the time frames required by §§1904.35 and 1904.40 when you are required to provide records to a government representative, employees, former employees, or employee representatives.

This arrangement allows companies to consolidate recordkeeping administration without violating the separate-log requirement. The records still belong to each establishment even when stored elsewhere. If an OSHA compliance officer requests records during an inspection at one of your sites, you must be able to retrieve and provide that location's specific forms within the required timeframe.

Access deadlines when records are kept centrally:

• Government representative request: 4 business hours (§1904.40)
  
  
• Employee/representative request for 300 Log: end of next business day (§1904.35)
  
  
• Employee/former employee/personal representative request for OSHA 301 for that employee's case: end of next business day (§1904.35)
  
  
• Authorized employee representative request for OSHA 301 ("Tell us about the case" section only): within 7 calendar days (§1904.35). You must remove all other information from the OSHA 301 (or equivalent) before providing it to the authorized employee representative.

In practice: Many multi-site employers use a centralized safety management system to capture incident data in real time and generate establishment-specific logs on demand. The system must support the 7-calendar-day transmission requirement and allow you to meet the record-access deadlines (e.g., within 4 business hours for an authorized government representative and by the end of the next business day for employee access to the OSHA 300 Log).

Assigning Employees to Establishments

Every employee must be linked to one establishment for recordkeeping purposes, per 29 CFR 1904.30(b)(3). This assignment determines which OSHA 300 Log will capture that employee's work-related injuries and illnesses when they occur away from any company establishment.

For employees who work exclusively at one location, the assignment is obvious. The complexity arises with employees who split time between multiple fixed locations or who work primarily in the field. The regulation requires a link but does not specify criteria for making the decision. Employers typically use factors such as payroll or HR assignment location, the site where the employee's supervisor is based, or the location where the employee spends the most time.

Whatever method you choose, the assignment should be made proactively (when the employee is hired or their role changes) rather than after an injury occurs. Documenting the basis for each assignment provides clarity if questions arise later. Remote workers and employees who telecommute must also be linked to an establishment, since their home does not qualify as one.

Common mistake: Failing to assign mobile employees to any establishment, then scrambling to decide where to record an injury after it happens. This creates inconsistency and potential compliance gaps.

Where to Record Injuries Based on Location

Once employees are assigned to establishments, the rules for where to record injuries follow a clear pattern based on where the incident occurs.

Injury at the Employee's Assigned Establishment

When an employee is injured at their assigned (home) establishment, record the case on that establishment's OSHA 300 Log. This is the most straightforward scenario.

Injury at a Different Company Establishment

When an employee is injured while visiting or working at another company establishment, record the case on the log of the establishment where the injury occurred, not the employee's home location. If a corporate staff member is injured while visiting a branch office, the branch office's log captures that case.

Injury Away from All Company Establishments

When an employee is injured at a location that is not one of the employer's establishments (such as a client site, while traveling, or at a remote work location), record the case on the OSHA 300 Log of the employee's linked home establishment. This rule ensures that injuries to field workers, traveling employees, and remote staff are captured even when no company establishment is involved in the incident.

Getting Multi-Location Recordkeeping Right

Setting up OSHA recordkeeping for multiple locations comes down to four steps: define your establishments using OSHA's criteria, decide whether to keep records on-site or centrally, link every employee to one establishment, and apply the recording rules consistently based on where injuries occur.

The most common pitfall is treating an entire company as a single establishment when locations actually meet the criteria for separate establishments. This can result in inaccurate data that masks site-specific safety problems and creates compliance exposure if OSHA inspects any individual location.

Accurate records across all locations do more than satisfy regulatory requirements. They provide the data needed to identify trends, compare safety performance between sites, and direct resources where they will have the greatest impact.