Job13

OSHA interpretation · 1999-07-14

Recording injuries that occur at secondary facility of the same company.

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.

July 14, 1999 Scott Holt Manager, Safety and Ecology Knoll Pharmaceutical Company 30 North Jefferson Road Whippany, NJ 07981 Dear Mr. Holt: Thank you for your letter of April 1, 1999 requesting written confirmation of an interpretation you received verbally concerning which of two facilities of the same company should record an injury on its log. I will cite the Recordkeeping Guidelines for Occupational Injuries and Illnesses (Blue Book) whenever possible. Question : If an employee was hurt while at another facility of the same company, which facility should record the injury on the OSHA 200 log? Answer : In most instances, employees are injured in the establishment to which they normally report. In these situations, a recordable case would be entered in the records of that establishment. In some cases, employees may normally report to one location, but be injured at another one of the employers' establishments where they are temporarily working. In these situations, a recordable case would be entered on the records of the establishment in which they were injured or became ill ( Guidelines P 20, Q&A 10). If your company includes more than one establishment, then separate logs for each establishment must be maintained, and each recordable case should be recorded on the log for the establishment in which the employee was injured or became ill. I hope you find this information useful. If you have any further questions or comments, please contact the Division of Recordkeeping Requirements, at Area Code: (202)693-1702. Sincerely, Cheryle A. Greenaugh Director, Directorate of Information Technology

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

Other letters on the same sections

Deciding a case of your own?

The free recordability check works through Part 1904 in the order the regulation sets out and quotes the provision behind every step.

Check a case — free

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.