OSHA Question of the Month: January

by Dwayne Towles

Why Keep Two OSHA Logs When One Will Do?

Scenario: You just took a job as the new Safety Manger for a medium sized manufacturing company.  You learn that you are responsible for maintaining the OSHA 300 log for the operation.  Prior to your arrival, these logs were maintained by the Human Resources Director who was very excited to hand that responsibility off to you.  She stopped by your office the very first week you were on the job with several large file folders and told you where the logs were being kept electronically on the company server.  Her parting words were “good luck”.  You went through the logs and discovered that for whatever reason, the HR director was keeping two separate 300 logs, one for your company employees and a second log for temporary workers.  You took a look at 29 CFR Section 1904.31 that states employers who supervise temporary or leased employees at their facility are required to maintain the OSHA 300 Logs for those employees.

Question: You wonder if keeping two separate logs is necessary and if it is acceptable to put them all on one log? Or, are you required to maintain two logs?

Answer:  The log is to be kept for an establishment. Under Section 1904.46 Definitions, an establishment is a single physical location where business is conducted or where services or industrial operations are performed. The controlling employer (using firm) may subdivide the OSHA 300 Log to provide separate listings of temporary workers, but must consider the separate listings to be one record for all recordkeeping purposes, including access by government representatives, employees, former employees and employee representatives as required by Section 1904.35 and 1904.40 in the Recordkeeping regulation.

OSHA’s view is that a given establishment should have one OSHA Log. Injuries and illnesses for all the covered employees at the establishment are then entered into that record to create a single OSHA 300A Summary form at the end of the year.