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OSHA interpretation · 1995-09-11

The location and maintenance of OSHA injury and illness records.

← 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 11, 1995 Ms. Cherryl McDougall Worldwide Health Services Manager Digital Equipment Corporation 111 Powdermill Road Maynard, Massachusetts 01754 Dear Ms. McDougall: Thank you for your letter dated August 17, requesting an interpretation concerning the location and maintenance of OSHA injury and illness records. Guidance on the location of records can be found in sections B and C on pages 20 through 22 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses . It is possible to prepare and maintain the Log at an alternate location if two requirements are met: (1) Sufficient information must be available at the alternate location to complete the Log entry within 6 workdays after the receipt of information that a recordable case has occurred; and (2) a copy of the Log updated to within 45 calendar days must be present at all times in the establishment. Please be aware that the location exception applies only to the Log, and not to the other OSHA records (e.g. Supplementary Record of Occupational Injuries and Illnesses, OSHA 101). Employers are required to maintain a separate OSHA Log for each of its establishments. An establishment is defined as a single physical location where business is conducted or where services or industrial operations are performed. If an establishment is capable of producing the Log immediately upon request, it is considered to be within compliance of 29 CFR 1904.2. Based upon the description of your ability to fax completed logs to their designated sites within minutes of receiving a request of access at the site, your system is considered to be within compliance of the OSHA requirements. Please be aware that OSHA is currently in the process of revising its injury and illness recordkeeping requirements, including the centralization and access provisions. We are attempting to take greater advantage of modern technology and provide employers with greater options for centralizing the injury and illness records. We hope to publish a Notice of Proposed Rulemaking this fall and look forward to receiving any comments you may have regarding this topic. I hope you find this information useful. If you have any further questions, please contact my staff at Area Code (202) 219-6463. Sincerely, Bob Whitmore Chief Division of Recordkeeping Requirements

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.