OSHA Log postings

HRinGA

I am in disagreement with my colleagues on this one. I don't think I'm doing this correctly, so I'm asking for input.
My business has several smaller locations throughout the area. We are under one umbrella for tax purposes and are listed as XYZ Company, d/b/a (name of each paper). Each paper has it's own publisher, they report to the president who is here with me. I guess you would call them subsidiaries.
Do I need to do a separate form 300A for each paper? I was simply doing one for my GA properties and another for my SC. I think I should be doing one for each paper.
What say you forumite gurus?

HRQ

We are similarly situated: one company, multiple locations, but all the same employer.

I do a separate 300A for each of our locations, because the form asks for the work site address.

I also receive the Survey of Occupational Injuries for specific locations, not for the whole company.

I assume there should be a separate form for each location but am curious to see what others say...

aliciac

I have a similar situation, 11 locations, one tax umbrella. I fill out seperate 300 and 300A forms for each location, and that's the way we've always done it.

JILL M

We have three plants (with three different adresses and zip codes) but one actual company address. I have always completed only one 300 & 300A for the whole company. OSHA has inspected these and we have never been told we were doing anything wrong.

HRinGA

Well now I'm confused. The OSHA log instructions state: "employers must keep a log for each establishment or site. If you have more than one establishment, you must keep a separate log and summary for each physical location that is expected to be in operation for one year or longer."

So....

hrpagersd

I called the OSHA hotline once and asked this question as I have several locations in 1 town. They asked me how many employees I have at each location and I said around 10 and they said that I can do one sheet for the company.

HRQ

Here - answers the question once and for all. From the recordkeeping section of the OSHA website... x:-)

Regulations (Standards - 29 CFR)
Multiple business establishments. - 1904.30

1904.1(a)(1)
If your company had ten (10) or fewer employees at all times during the last calendar year, you do not need to keep OSHA injury and illness records unless OSHA or the BLS informs you in writing that you must keep records under § 1904.41 or § 1904.42. However, as required by § 1904.39, all employers covered by the OSH Act must report to OSHA any workplace incident that results in a fatality or the hospitalization of three or more employees.

1904.1(a)(2)
If your company had more than ten (10) employees at any time during the last calendar year, you must keep OSHA injury and illness records unless your establishment is classified as a partially exempt industry under § 1904.2.

[font color="red"] 1904.30(a)
Basic requirement. You must keep a separate OSHA 300 Log for each establishment that is expected to be in operation for one year or longer.[/font]