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OSHA interpretation · 1992-09-02

Recordkeeping requirements for separate sites and types of records to be maintained.

← All interpretations§ 1904

OSHA’s standing caveat

Interpretation letters explain existing requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. Enforcement guidance may be affected by later changes to OSHA rules, and a letter addresses the facts it was given — not necessarily yours.

September 2, 1992 Ms. Jeanne Veverka Society for Handicapped Citizens of Medina County, Inc. 4283 Paradise Road Seville, Ohio 44273-9728 Dear Ms. Veverka: Your letter dated July 14, 1992 requesting clarification of OSHA recordkeeping issues was forwarded to my office from the Bureau of Labor Statistics. My Division of Recordkeeping Requirements is responsible for the administration of the OSHA injury and illness recordkeeping system nationwide. As stated on page 28 of the enclosed Recordkeeping Guidelines for Occupational Injuries and Illnesses , for OSHA recordkeeping purposes, you are required to record information about every occupational death; every nonfatal occupational illness; and those nonfatal occupational minor injuries which involve one or more of the following: loss of consciousness, restriction of work or motion, transfer to another job, or medical treatment (other than first aid). As stated on page 26 of the Guidelines, workers' compensation determinations should not impact the recordability of cases under OSHA. Some cases may be covered by workers' compensation but are not recordable; others may be OSHA recordable but are not covered by workers' compensation. Cases should be evaluated solely on the basis of OSHA requirements. As found on page 19 of the Guidelines, the regulations require that injury and illness records be maintained for each establishment, which is defined as a single physical location where business is conducted or where operations are performed. Therefore, each of your 5 separate homes must maintain a separate OSHA Log. I hope you find this information useful. If you have any further questions, please contact my staff at Area Code 202 523-1463. Sincerely, Stephen A. Newell Acting Director Office of Statistics

Reproduced verbatim from osha.gov. US Government work, public domain (17 U.S.C. § 105).

Other letters on the same sections

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Not legal advice. This page republishes 29 CFR Part 1904 as published by the eCFR and explains it. The recordkeeping duty is the employer’s. Where the rule requires judgement, Job13 says so rather than guessing — run your own case through the free check.