New Establishments and OSHA Logs: When to Start Separate Records
A new site expected to operate for a year or longer needs its own 300 Log from day one; sites expected to last less than a year can share a short-term log.
The short answer
A new site expected to operate for a year or longer needs its own 300 Log from day one; sites expected to last less than a year can share a short-term log. Set it up before the first injury: establishment profile, NAICS code, and the employees linked to it.
New locations create messy logs if setup waits until the first injury.
The rule in plain English
Keep a separate 300 Log for each establishment expected to operate for a year or longer (29 CFR 1904.30). An establishment is a single physical location where business is conducted; for mobile work such as construction or transportation, it is the office or terminal that supervises the work. Short-term establishments (under a year) still need records, but they can share one log per company, division, or region. Records may be kept centrally if case information reaches the central office within 7 calendar days and records can be produced in time for employee and government requests. Every employee must be linked to one establishment.
How it plays out on site
Start establishment-level records when the site is expected to operate long enough to require separate tracking. A company-wide spreadsheet feels efficient until someone needs one site's log by the next business day, or one site's 300A for posting. The fix is an explicit establishment model: every employee has a home establishment, every case lands on exactly one log, and each site's forms can be produced on their own.
Operations leaders rarely make the recordkeeping call, but they control the schedules, postings, and site managers that make the deadlines work.
The common mistake
Teams add new-site cases to headquarters by default.
Each establishment has its own 300A to certify and post, its own ITA coverage decision, and its own rates, so a case on the wrong log distorts two sites at once.
Edge cases
- Short-term sites may follow different recordkeeping handling.
- An injury at another of your establishments goes on the log where it happened; an injury away from any of your establishments goes on the log of the employee's home establishment.
Worked example
A logistics company opens a cross-dock in March with a five-year lease. It gets its own log in March, not in January of the next year, and its first recordable case in April goes there rather than on headquarters' log. It posts its own 300A the following February.
Checklist
- Decide the expected duration.
- Create the establishment profile and NAICS code.
- Link employees to it.
- Set intake so cases land on the right log.
What to keep in the case file:
- An establishment list with addresses, NAICS codes, and expected duration
- The home establishment for each employee, including remote and traveling staff
- The rule used to place cases that happen away from the home site
- The retrieval procedure for next-business-day and 4-business-hour requests
Where 300log helps
300log is organized by establishment: each site has its own log, 300A, and exports, while one team can review every site from the same workspace.
Frequently asked questions
Does each location need its own OSHA 300 Log?
Each establishment expected to operate for a year or more does. Short-term sites can share one log per company, division, or region.
Can headquarters keep all the logs?
Yes, if case information reaches headquarters within 7 calendar days and records can be sent to each establishment in time for employee and government requests.
Where do injuries away from any site go?
On the log of the establishment where the employee normally works.
Can one address hold two establishments?
Only when distinctly separate businesses with different economic activities share it and each keeps its own business records.
Sources
Primary regulation and agency guidance this article relies on.
- [1]29 CFR 1904.30: Multiple business establishmentsOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [2]29 CFR 1904.29: OSHA Forms 300, 300A, and 301Occupational Safety and Health Administration · osha.gov(opens in a new tab)
- [3]29 CFR 1904.32: Annual summary certification and postingOccupational Safety and Health Administration · osha.gov(opens in a new tab)
Written and reviewed by the 300log Editorial Team. Guidance, not legal advice: confirm edge cases with OSHA or counsel.