Definitions and establishment criteria

An establishment is a single physical location where business is conducted or where services or industrial operations are performed. See the definition in 1904.46.

• This includes a fixed plant, office, store, or similar location where employees report to work.
• For industries where employees don’t work at one fixed site (for example, construction or transportation), the employer’s main or branch offices, terminals, or stations that supervise or dispatch those employees represent the establishment. See 1904 for part-level context.

Yes — an employer may consider two or more separate businesses that share a single location to be separate establishments only when all four specific conditions in 1904.46(1) are met.

• Each operation must represent a distinctly separate business (1904.46(1)(i)).
• Each business must be engaged in a different economic activity (1904.46(1)(ii)).
• No single NAICS (2007) industry code should describe the combined activities (1904.46(1)(iii)).
• Separate business reports (employees, wages, sales/receipts, etc.) must routinely be prepared for each business (1904.46(1)(iv)).

If any of these elements is missing, treat the location as a single establishment for recordkeeping.

It means each business must perform fundamentally different kinds of work such that one NAICS code cannot describe both operations together. See 1904.46(1)(ii) and 1904.46(1)(iii).

• Example: a construction contractor and a lumber retailer sharing a site are in different economic activities and likely have different NAICS codes, so they may qualify as separate establishments (see the example in 1904.46(1)(iv)).
• If the two operations are variations of the same line of business (same NAICS), they should not be split for recordkeeping.

If the employer routinely prepares separate business records—such as separate reports on number of employees, wages and salaries, sales or receipts, and other business information—then the operations may be separate establishments under 1904.46(1)(iv).

• Practical indicators include separate payrolls, distinct sales/receipts records, independent employee rosters, or separate tax or business filings for each business on the shared site.
• If records are combined (one payroll, one set of financials), that suggests a single establishment.

An employer may combine multiple physical locations into one establishment only when all three conditions in 1904.46(2) are met.

• The locations must be operated as a single business under common management (1904.46(2)(i)).
• The locations must be in close proximity to each other (1904.46(2)(ii)).
• The employer must keep one set of business records for the combined locations (employees, wages, sales, etc.) (1904.46(2)(iii)).

If any of these is missing, the locations should generally be treated as separate establishments for recordkeeping.

"Close proximity" generally means the locations are near enough to be operated together as a single business unit—for example, a main plant, a warehouse a few blocks away, and an administrative building across the street—as described in 1904.46(3).

• There is no strict mileage limit in the rule; the key is whether the locations are close enough to be managed and recorded as one operation.
• If locations are geographically distant or operate independently despite common ownership, they normally should be separate establishments.

No — an employee’s home is not a business establishment for telecommuters, and you do not need a separate OSHA 300 Log for their home; instead, telecommuting employees must be linked to one of your establishments under 1904.30(b)(3) and 1904.46(3).

• Record any work-related injury or illness of a telecommuter on the OSHA log for the establishment to which that telecommuter is linked.
• The linkage should reflect the establishment that supervises or is the base for that employee’s work activities.

Link telecommuters to one of your existing establishments — typically the office, branch, or worksite that supervises their work or serves as their work base — as required by 1904.30(b)(3).

• Choose the establishment that manages the employee’s work assignments, timekeeping, or payroll, or the office that the employee reports to for supervision.
• Document the decision so you can show which establishment’s OSHA 300 log will be used for recording any telecommuter cases.

Yes — when the locations are operated as a single business unit under common management, are in close proximity, and are recorded with one set of business records, they may be combined as one establishment, as the example in 1904.46(3) illustrates.

• Verify the three combining conditions in 1904.46(2): common management, close proximity, and one set of records.
• If any condition is missing (e.g., separate payrolls), treat them as separate establishments.

An injury or illness is an abnormal condition or disorder — for example, cuts, fractures, sprains, amputations (injuries) or skin disease, respiratory disorders, or poisoning (illnesses) — and is recordable only if it is a new, work-related case that meets recording criteria in Part 1904. See the definition in 1904.46.

• To be recordable the case must also meet the general recording criteria in 1904.7 (e.g., medical treatment beyond first aid, days away from work, restricted work, loss of consciousness, or significant diagnosis).

A "Physician or Other Licensed Health Care Professional" is someone whose legally permitted scope of practice (license, registration, or certification) allows them to independently perform—or be delegated to perform—the health care activities described in the recordkeeping regulation, per 1904.46.

• This definition determines who can make medical diagnoses or recommend treatments that affect recordability decisions (for example, a physician, nurse practitioner, or other licensed practitioner acting within their legal scope).

In Part 1904, "you" means an employer as defined in section 3 of the Occupational Safety and Health Act of 1970 (29 U.S.C. 652), according to the definitions in 1904.46.

• That means the obligations in Part 1904 (recordkeeping and reporting) apply to employers as defined by the Act.

Yes — if the construction company and lumber yard at the same location meet all the criteria in 1904.46(1), including routine preparation of separate business reports (like separate payrolls), they may be treated as separate establishments, as the example in 1904.46(1)(iv) shows.

• Confirm they are distinct businesses, engaged in different economic activities, not covered by one NAICS code, and that separate records are maintained.

Yes — software-generated forms can be used as substitutes for OSHA Form 300 and Form 300A if they are equivalent to the OSHA forms and meet the requirements in the recordkeeping regulation, as explained in OSHA’s interpretation Software-generated OSHA recordkeeping forms.

• Equivalence means the form contains the same information, is as readable and understandable, and is completed using the same instructions as the OSHA form (see the interpretation and the general Part 1904 context at 1904).
• Electronic systems are permitted provided they can produce equivalent forms for employee access and government inspection as required by the rules.

If you combine locations into a single establishment, you must keep one set of business records such as records on number of employees, their wages and salaries, sales or receipts, and other business information, per 1904.46(2)(iii).

• Examples: one payroll file covering all locations, consolidated employee headcounts, combined sales or receipts reports, and a single set of personnel records used for OSHA log assignment.

Establishments that meet the size and industry criteria must electronically submit Form 300A data as outlined in OSHA’s enforcement memo on electronic submission (Electronic injury record submission enforcement) and the Part 1904 requirements.

• Generally, establishments with 250 or more employees must submit Form 300A; certain establishments with 20–249 employees in higher-hazard industries must also submit — see the detailed categories in the memo (Electronic injury record submission enforcement).
• If you combine locations into a single establishment under 1904.46(2), apply the submission requirement based on that combined establishment’s employee count and NAICS where applicable.

Not necessarily — to combine locations or operations as a single establishment you must meet all applicable criteria. If you are trying to treat two operations at one site as separate establishments under 1904.46(1), having separate sales records supports separation. Conversely, if combining under 1904.46(2), you must have a single set of business records — so separate sales records would weigh against combining.

• Decision depends on which pathway you seek (splitting a site into multiple establishments vs. combining multiple locations into one): match the fact pattern to the right subsection and its full set of conditions.