- Standard Number:
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
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