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Answer · Recordkeeping

Is OSHA reporting based on company size or site size?

2 min read Checked against current CFR text Sep 2026 Reviewed by Renae Irek
Short answer

The establishment. The electronic reporting thresholds apply to each individual physical location rather than to the company as a whole.

A company with 120 employees spread across three yards of 40 is three establishments of 40 — not one establishment of 120.

29 CFR 1904.41 Read it on osha.gov.

Why this catches people both ways

A growing company can cross a company-wide headcount that feels significant and owe nothing new, because no single location crossed anything. And a company that consolidates two yards into one can acquire an obligation it did not have, without hiring a single person.

What counts as an establishment

A single physical location where business is conducted. For construction and trades work this is the question that needs care, because a crew working from vehicles is not obviously located anywhere — 1904.46 has the definition and it is worth reading rather than assuming.

Related questions

Each answers one question with the rule it comes from.

How do I count employees across multiple sites? 1904.41 Do I have to submit injury data to OSHA electronically? 1904.41 How do I count employees for the small-employer exemption?

Safety Sherpa is software, not a safety consultancy. This page quotes the cited regulation and links to the source text so you can read it yourself. It is not legal advice and does not replace a qualified person's judgment about a genuinely unclear case — our tools walk you through the decisions the regulations require and record your reasoning. The determination is yours to make.