Multi-Establishment OSHA Recordkeeping: One 300 Log Per Location and the Rules Multi-Site Employers Miss

A single OSHA 300 Log covering an entire company is one of the most common recordkeeping setups at small and mid-size multi-site employers — and one of the most common things OSHA inspectors find wrong. The rule, in a single sentence from 29 CFR 1904.30(a), is unambiguous: "You must keep a separate OSHA 300 Log for each establishment that is expected to be in operation for one year or longer."

What looks like a paperwork preference is actually a structural rule that touches almost every other part of recordkeeping — where employees are logged, how hours and cases are calculated, whether the industry exemption applies, who submits to the ITA, and how records are produced when a government representative shows up. If you operate more than one location, the multi-establishment rules quietly decide most of your compliance posture.

This post walks through the rules that actually trip up multi-site employers, with worked examples drawn from the kinds of operations LogStead customers run — field-service companies, multi-location retail and manufacturing, construction contractors, and businesses with remote and traveling employees.

What Counts as an "Establishment"

Most multi-establishment confusion starts with a fuzzy understanding of what an establishment actually is. OSHA defines it in 29 CFR 1904.46: "An establishment is a single physical location where business is conducted or where services or industrial operations are performed. For activities where 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."

Two things matter in that definition. First, the default is a single physical location. Second, when employees do not work at a single location — field crews, drivers, traveling techs — the establishment is the office or terminal they are based out of or supervised from. That second clause is the entire foundation of how field-service and construction employers comply with this rule.

One Building, Two Establishments

OSHA allows a single physical location to be treated as two establishments only when each operation runs separately and meets three conditions: distinct management, distinct business or operational identity, and separate business records (employees, wages, sales). In practice this is rare. Most companies that occupy a single building treat it as one establishment, regardless of how many internal departments they run.

Two Buildings, One Establishment

The mirror exception also exists: two physical locations can be treated as one establishment if they share a single set of business records — same employees, same wages, same operational identity. This is most common when an employer occupies two adjacent buildings on the same campus. If business records are commingled, it is one establishment.

Telecommuters and Home-Based Workers

OSHA addresses home offices directly. A telecommuter's home is not a business establishment for recordkeeping purposes. Telecommuters are linked to one of the employer's brick-and-mortar establishments under 29 CFR 1904.30(b)(3) — typically the office that supervises them.

Short-Duration Establishments: The Construction Job-Site Rule

The "one year" qualifier in 1904.30(a) creates a meaningful carve-out. Establishments expected to exist less than a year do not need their own dedicated 300 Log. Under 29 CFR 1904.30(b)(1), employers can satisfy the recordkeeping obligation for short-term sites in one of two ways: keep a separate 300 Log for each short-term location, or maintain one 300 Log covering all short-term establishments — optionally organized by company division or by geographic region.

The construction industry is the obvious case. A general contractor with a permanent corporate office and 18 active project sites in a given year keeps a 300 Log at the corporate office (year-round establishment) and a second consolidated 300 Log covering all 18 project sites. The project-site log can be physically maintained at headquarters as long as cases get entered correctly and the recordkeeping is current.

This same rule applies anywhere an employer runs short-term operations — pop-up retail, temporary event staffing, seasonal facilities expected to close within twelve months. If the location is genuinely expected to be in operation less than a year, the consolidated short-term log is available.

Where Does an Employee Go on the Log?

The most-asked question in multi-site recordkeeping is also the most-misunderstood. An employee works at three of your establishments, gets injured at a fourth, and you have to record the case somewhere. Where?

The rule is in 29 CFR 1904.30(b)(3): "You must link each of your employees with one of your establishments, for recordkeeping purposes." Each employee is linked to one — and only one — establishment. That linkage controls where the employee's injuries are recorded, regardless of where they happen.

OSHA clarified the application of this rule in a February 28, 2014 Letter of Interpretation: "Recordable injuries or illnesses sustained by an employee at a remote location must be recorded on that employee's home establishment's OSHA 300 log."

The "home establishment" is the location that supervises the employee day-to-day, or that they are formally based out of. It is not necessarily where they spend the most physical time, and it is not the location of the injury.

Traveling Sales Reps

A sales rep covers a six-state territory and is supervised out of a regional sales office in Denver. Injuries on the road are recorded on the Denver office's 300 Log, regardless of whether they occurred in Wyoming, Idaho, or Utah.

Field Service Technicians

A field tech is dispatched daily from a service depot in Phoenix to customer sites across central Arizona. The Phoenix depot is the home establishment. A laceration sustained at a customer site is recorded on the Phoenix depot's 300 Log. This is the pattern most LogStead customers in HVAC, telematics installation, electrical, plumbing, and equipment maintenance follow.

Remote and Distributed Workers

A fully remote software engineer is supervised by a manager working out of the company's San Francisco headquarters. The engineer's recordable injury — for example, a documented case of work-related musculoskeletal disorder from their home office setup — is recorded on the San Francisco headquarters' 300 Log.

Employees Temporarily Working at Another Establishment

Under 29 CFR 1904.30(b)(4), if an injury occurs at one of your other establishments while the employee is temporarily assigned there, you record it at the establishment where the injury occurred. If the employee is injured somewhere outside any of your establishments while on temporary assignment, record it at their home establishment.

Mixed-NAICS Companies: Exemptions Are Evaluated Per Establishment

Multi-site employers with operations in different industries run into a rule that catches a lot of people: the size exemption and the industry exemption work on different scales.

The size exemption under 29 CFR 1904.1 — ten or fewer employees at all times during the previous calendar year — is measured company-wide. If your company has three sites with four employees each, you have twelve employees company-wide, and the size exemption does not apply, even though no single establishment exceeds ten.

The industry exemption under 29 CFR 1904.2 (the NAICS codes listed in Appendix A to Subpart B of 29 CFR Part 1904) is evaluated establishment-by-establishment. Each location is evaluated against the NAICS code that describes its actual primary activity. A company can have one exempt establishment and one non-exempt establishment at the same time.

Worked example: Smith Holdings is a 40-employee company operating two locations. One is a hardware retail store classified in NAICS 444110 (partially exempt under Appendix A to Subpart B). The other is a small specialty manufacturing line classified in NAICS 332710 (not on the exempt list). The size exemption is unavailable because Smith Holdings has more than ten employees company-wide. The hardware store still does not keep a 300 Log because the industry exemption applies at the establishment level. The manufacturing line does. Smith Holdings maintains exactly one 300 Log — at the manufacturing establishment.

The reverse trap is more common. A company assumes its corporate classification — say, NAICS 5511 Management of Companies (exempt) — carries through to every location. It does not. A holding company with corporate offices in 5511 and operating subsidiaries in non-exempt industries must keep records at the operating subsidiaries' establishments.

For the full exemption framework, see our companion guide on recordkeeping exemptions for small employers.

Hours and 300A Calculations Are Per-Establishment

Under 29 CFR 1904.32(b)(2)(ii), every 300A annual summary must report "the calendar year covered, the company's name, establishment name, establishment address, annual average number of employees covered by the OSHA 300 Log, and the total hours worked by all employees covered by the OSHA 300 Log."

The numbers on each 300A reflect only the cases, employees, and hours of that one establishment. Rolling up company-wide totals onto a single summary is one of the most common 300A errors in multi-site operations. Each establishment's 300A is a self-contained snapshot, and each location's TRIR and DART rates are calculated from its own data — not from company averages.

For the field-by-field walkthrough of the form, see OSHA 300A Annual Summary: Deadlines, Calculations, and Common Mistakes.

Centralized Recordkeeping: Allowed, With Two Strict Conditions

OSHA permits a multi-site employer to keep its records at one central location instead of physically at each establishment — but only if the employer can meet two requirements set out in 29 CFR 1904.30(b)(2):

(i) Transmit information about the injuries and illnesses from the establishment to the central location within seven (7) calendar days of receiving information that a recordable injury or illness has occurred; and

(ii) Produce and send the records from the central location to the establishment within the time frames required by §§ 1904.35 and 1904.40 when you are required to provide records to a government representative, employees, former employees or employee representatives.

The second requirement triggers the four-business-hour rule. Under 29 CFR 1904.40(a): "When an authorized government representative asks for the records you keep under part 1904, you must provide copies of the records within four (4) business hours."

In practice that means: if your records live at corporate headquarters and an inspector arrives at a satellite location asking for the local 300 Log, you have four business hours to get a copy from headquarters to that establishment. Cloud-based recordkeeping, secure email, and electronic portals are all acceptable transmission methods — the rule is silent on form and focused on timing.

The thing to test before relying on centralized recordkeeping is whether the chain actually works. Pick a satellite location, ask your central record-holder to produce the most recent three years of 300 Logs and 300As for that site, and time it. If four business hours is genuinely achievable from your current setup, centralized recordkeeping is fine. If it is not, you have a structural compliance gap that an inspection will surface immediately.

Posting Still Happens Locally

Centralizing your records does not centralize your posting obligation. Under 29 CFR 1904.32(b)(5), the 300A must be physically posted at each establishment from February 1 through April 30 every year. OSHA's February 28, 2014 Letter of Interpretation confirmed that electronic posting alone does not satisfy this requirement. Every covered establishment needs a printed, certified 300A on the wall during the three-month posting window — regardless of where the underlying records live.

ITA Submissions Are Per Establishment, Not Per Company

The electronic submission thresholds in 29 CFR 1904.41 apply at the establishment level. Each establishment is evaluated independently against the size and industry tests, and each covered establishment submits its own 300A through the Injury Tracking Application.

The three coverage tiers, all establishment-by-establishment:

• 20 to 249 employees in a designated Appendix A to Subpart E industry → submit 300A only
• 250 or more employees, not in an Appendix A to Subpart B exempt industry → submit 300A
• 100 or more employees in a designated Appendix B to Subpart E high-hazard industry → submit 300A plus case-level 300 and 301 data

A 600-employee company operating three 200-employee manufacturing sites in a high-hazard NAICS code submits three separate 300As — one for each establishment — not a single combined company-wide submission.

The ITA portal supports managing multiple establishments under a single Login.gov account. For employers with many locations, CSV upload and API integration are faster than entering each establishment manually through the web form.

The CY 2025 deadline of March 2, 2026 has already passed for this cycle. CY 2026 data is due by March 2, 2027. Late submissions are still accepted through the ITA portal — late filing is better than non-filing, but it does not eliminate the risk of a citation if an inspector identifies the late submission during an inspection. For the step-by-step submission process, see How to Submit Your OSHA Data Electronically via the ITA Portal.

Retention Survives Closure

Under 29 CFR 1904.33(a), all 300 Logs, 300A summaries, and 301 incident reports must be retained for five years following the end of the calendar year they cover. This obligation applies per establishment and survives the establishment's closure.

If you close a satellite location at the end of 2026, the recordkeeping obligation for that site runs through the end of 2031. If you sell the establishment, 29 CFR 1904.34 governs how records are transferred to the new owner. If you simply shut the location down, the parent company retains custody of the records for the full five-year window.

This catches employers who, in the course of closing or consolidating an establishment, discard the local recordkeeping binder as part of cleaning out the office. Five years of retention is independent of whether the establishment still exists.

State-Plan State Nuances

Twenty-two states and territories operate their own OSHA-approved state plans covering private-sector employers. Under 29 CFR 1904.37(b)(2), state plans must be at least as effective as federal OSHA and may impose additional or more stringent requirements.

California (Cal/OSHA), Washington (DOSH), Oregon OSHA, and other state-plan jurisdictions generally mirror the federal 1904 framework but layer on supplemental obligations — particularly around posting, sharps recordkeeping, and indoor heat. If you operate in multiple states with a mix of federal and state-plan jurisdictions, each establishment is subject to its own state's recordkeeping requirements. The federal rules in this post are the floor, not the ceiling.

What OSHA Enforcement Actually Looks for at Multi-Site Employers

A few specific failure patterns show up repeatedly when OSHA inspects multi-site employers.

Missing logs at satellite locations. A 300 Log exists at headquarters but not at the branch the inspector is visiting, and centralized recordkeeping cannot produce a copy in four hours.

300A posted only at corporate. The annual summary is up at headquarters but not at the satellite location where the inspection is happening. This is a separate citation from any underlying recordkeeping error.

Employees not linked to a home establishment. Records exist, but it is unclear which establishment a particular employee's injuries should appear on, and the cases are scattered or duplicated.

Centralized records that cannot actually be produced in four hours. The records exist on paper at headquarters, but headquarters is unreachable, the record-holder is unavailable, or the production process has never been tested.

ITA submissions that do not match the establishment structure. One company-wide submission instead of one per establishment, or covered establishments that were never submitted at all.

The April 17, 2024 memo on the Instance-by-Instance Citation Policy for Serious, Repeat, and Other-Than-Serious Violations — signed by Kimberly A. Stille (Director, Directorate of Enforcement Programs) and Scott C. Ketcham (Director, Directorate of Construction) — expanded OSHA's discretion to issue separate citations for each instance of certain violations. One of the explicit triggers listed in the memo is: "The inspection revealed widespread recordkeeping deficiencies (for which IBI recordkeeping citation items may be proposed)."

For a multi-site employer, this matters because the same kind of recordkeeping failure repeated across five locations can become five citations rather than one. Per OSHA's January 14, 2025 penalty adjustment news release, "the maximum OSHA penalties for serious and other-than-serious violations will increase from $16,131 to $16,550 per violation. The maximum penalty for willful or repeated violations will increase from $161,323 to $165,514 per violation." Those ceilings carry into 2026 and compound under the instance-by-instance framework.

For the broader picture of how OSHA identifies multi-site employers for inspection, see How OSHA Picks Who to Inspect: The Site-Specific Targeting Program, Explained. The most common recordkeeping mistakes — many of which compound at multi-site employers — are covered in 5 OSHA Recordkeeping Mistakes That Lead to Citations.

A Field-Service Walkthrough

To bring the rules together, consider Acme HVAC, a typical LogStead-customer-shaped operation.

Acme has a main office in Phoenix with 40 employees, a warehouse 20 miles away in Mesa with 8 employees, and 25 field service technicians dispatched daily from the Phoenix office to customer sites across central Arizona. The Phoenix office and the Mesa warehouse are both year-round establishments, so each gets its own 300 Log under 1904.30(a). The 25 traveling techs are based out of Phoenix — that is their home establishment — so under 1904.30(b)(3) all of their recordable injuries are entered on the Phoenix 300 Log, regardless of which customer site the injury actually occurred at.

If a Phoenix-based tech is temporarily assigned to the Mesa warehouse for a week and gets injured there, the case goes on the Mesa 300 Log under the 1904.30(b)(4) exception. If the same tech is injured at a customer site that is not one of Acme's establishments, the case goes back on Phoenix's log.

Acme's accounting and recordkeeping are run from Phoenix. Both establishments' 300 Logs are maintained electronically in a centralized recordkeeping system, and the system has been tested against the four-business-hour production rule. Each February, Acme prints, certifies, and posts a separate 300A at each location. Each March, Acme submits two 300As to the ITA — one for Phoenix, one for Mesa — assuming each establishment crosses the relevant employee-count and industry thresholds in 1904.41.

Two locations, two logs, two 300As, two ITA submissions, one centralized recordkeeping platform that can produce records in four hours. That is the entire compliance frame for a typical multi-site field-service operation.