OSHA makes injury records establishment-specific

The OSHA log population begins with the establishment

The direct answer in 29 CFR 1904.30 is that an employer must keep a separate OSHA 300 Log for each establishment expected to remain in operation for one year or longer. That makes establishment identity part of the recordkeeping control. A corporate total, business-unit dashboard, or centralized incident repository can support oversight, but it does not replace the establishment-level log required by this section.

A maintained data model should preserve the establishment identifier, physical or operating location, expected duration, ownership period, industry classification where relevant, responsible official, employee population, log year, and applicable exemption analysis. Mergers, relocations, reorganizations, temporary projects, shared campuses, and changes in operating duration need governed effective dates so a case does not move merely because an organizational hierarchy changed later.

Short-term locations have a different aggregation rule

The standard says employers must keep records for short-term establishments—those expected to operate for less than a year—but do not have to create a separate log for each one. The employer may keep one log covering all short-term establishments and may organize such a log for individual company divisions or geographic regions. That is an allowed aggregation choice, not an instruction to omit the underlying location.

Software should retain the project or short-term establishment attached to each case even when the regulatory log aggregates several locations. The configuration needs a documented scope, calendar year, grouping rule, accountable owner, and change history. Without the case-to-location link, an organization may produce the combined log yet lose the ability to investigate recurring hazards, answer an establishment-specific request, or reconcile cases when a supposedly temporary operation lasts longer than expected.

Central storage is allowed only with timely movement and access

Section 1904.30 permits records to be maintained at headquarters or another central location if information about an injury or illness can be transmitted there within seven calendar days after the employer receives information that a recordable case occurred. The employer must also be able to produce and send records to the establishment within the time frames required when government representatives, employees, former employees, or their representatives are entitled to them.

Centralization therefore changes custody, not the establishment attribution or access obligation. A system should preserve the received date, transmission time, completeness checks, establishment owner, central custodian, requested record, requester authority, disclosure review, response deadline, and delivery evidence. Batch synchronization without exception monitoring can create a timing gap even when all data ultimately arrive in one warehouse.

Mobile and visiting workers need an explicit assignment

For employees who work at several locations or at no fixed establishment, the regulation requires the employer to link each employee with one establishment for recordkeeping. If an employee is injured or becomes ill at another establishment of the same employer, the case is recorded on the log of the establishment where the event occurred. If the event occurs away from an establishment, the case is recorded where the employee normally works.

These rules are record-assignment rules, not a complete determination that a case is work-related or recordable. The workflow still has to apply the other provisions of Part 1904 and any applicable State Plan requirements. This article does not decide coverage, attribution, privacy, or recordability for a real event. It identifies the establishment logic a system should expose so the accountable safety and legal teams can apply the current rule to documented facts.

Enterprise buyer test

Translate this change into the exact population, record type, workflow stage, decision owner, effective date, and evidence that could be affected. Ask current or prospective providers to demonstrate the named workflow with representative data and an exception—not a polished feature tour. Record what official documentation establishes, what a provider states, what the team observes, and what remains unresolved.

A defensible review also identifies the dependency outside the product. Authority interpretation, policy configuration, data quality, integrations, human judgment, approval rights, release governance, training, and retained evidence may remain customer or service responsibilities. The evaluation should preserve those boundaries instead of treating a technology claim as the complete operating model.

What we will watch next

Safety Operations Standard will watch the named source and affected market records for later evidence that changes status, scope, availability, implementation timing, workflow consequence, or the limits of the initial report. A later announcement does not silently overwrite this dated account; the change ledger preserves the sequence.