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September-October 2017

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palletcentral.com PalletCentral • September-October 2017 21 employees do not work at a single physical location, such as construction; transportation; communications, electric, gas and sanitary services; and similar operations, the establishment is represented by main or branch offices, terminals, stations, etc. that either supervise such activities or are the base from which personnel carry out these activities. Section 1904.30(a) provides that employers must keep a separate OSHA 300 log for each establishment that is expected to be in operation for one year or longer. If your company has a continuous presence at a client's site (i.e., a physical space at the job site for one year or longer), you must treat it as an establishment and maintain an OSHA 300 log. On the other hand, Section 1904.30(b)(1) provides that for short-term establishments, (i.e., those that will exist for less than one year, such as short-term storage locations), employers are required to keep injury and illness records, but are not required to keep separate OSHA 300 logs. Instead, employers may keep a single OSHA 300 log covering all of its short-term establishments, or they may include short-term establishment records in logs that cover individual company divisions or geographic regions. Regardless of the method of internal tracking, the data for

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