Safety Sherpa Safety Sherpa
See what you're missing
Answer · Recordkeeping

How do I count employees across multiple sites on one campus?

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

Under most circumstances a campus is a single physical location and is treated as a single establishment, so you count everyone on it together.

You may divide one location into two or more establishments only when each facility represents a distinctly separate business and each is engaged in a different economic activity.

29 CFR 1904.41 Read it on osha.gov.

The test is conjunctive, and that is the part people miss

Both conditions have to hold. Separate buildings are not enough. Separate managers are not enough. Separate cost centres are not enough. The facilities must be distinctly separate businesses and they must be doing different economic activities.

Why the default matters commercially

Because the thresholds are per establishment, treating a campus as several small establishments would remove an obligation. That is exactly why the rule is narrow, and why an aggressive reading of it is a poor place to be if the records are ever examined.

Related questions

Each answers one question with the rule it comes from.

Is OSHA reporting based on company size or site size? 1904.41 Which NAICS code do I use for OSHA reporting? 1904.41 Do I have to submit injury data to OSHA electronically? 1904.41

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.