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
