OSHA Recordkeeping for Franchise Locations: Employer Establishment and Log Ownership
The OSHA log belongs to the injured worker's employer, which is usually the franchisee that hires and supervises the staff, not the franchisor brand.
The short answer
The OSHA log belongs to the injured worker's employer, which is usually the franchisee that hires and supervises the staff, not the franchisor brand. Each franchise location is its own establishment, and the franchisee's company-wide headcount decides the 10-employee exemption.
Franchise operations can blur brand control, employer identity, and establishment responsibility.
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 with the actual employer establishment and supervision facts before deciding who keeps the OSHA log. 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.
As a franchisee you are usually the employer, so the records are yours to keep even when brand standards come from the franchisor.
The common mistake
Teams assume the franchisor brand automatically owns or avoids every recordkeeping obligation.
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
- Shared staffing, management companies, or common ownership can change the analysis.
- 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 franchisee owns four fitness studios with 6 to 9 employees each. The brand sets operating standards but does not employ anyone at the studios. The franchisee had more than 10 employees company-wide, so each studio keeps its own log. Fitness centers (7139) are not on the partially exempt list, so the franchisee cannot rely on an industry exemption.
Checklist
- Identify the legal employer at each location.
- Confirm who supervises staff day to day.
- Set up a log per establishment.
- Agree who handles severe-injury reporting.
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
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.
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.
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 1904.31: Covered employeesOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [3]29 CFR 1904.29: OSHA Forms 300, 300A, and 301Occupational 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.