Occupational (OSHA) and Environmental Hazards/DART rate

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Question
If a company has three separate entities with different names, but with common ownership, should/can their loss experience be combined to calculate their DART rate for OSHA?

Thanks.

Answer
Subject: DART rate

Question: If a company has three separate entities with different names, but with common ownership, should/can their loss experience be combined to calculate their DART rate for OSHA?  Thanks.

Answer: Bill, the answer to this will depend on how closely related the entities are. If they share any management or business functions such as accounting or human resources, they can be combined as one operation to calculate the rates. This could also happen if the share a common physical location. If this is not the case you will want to calculate the rate for each unit separately which would be considered the norm.  Even if the units share some functions it is normally to calculate each unit separately and also have a combined rate which would include each of  the separate entities and also the numbers for any employees or staff included in the central unit. This is the approach taken by many companies with different operations at different locations. There may be considerations outside of safety/health to not have the entities identified as belonging to a central company so I would suggest  some input from the legal staff before a final decision is made. If the entities are handled separately you might have to justify your approach in the event of an OSHA inspection but that should not be difficult if there are not any shared functions. I would like to have to have been able to give you a simple Yes or No answer but as you well know life is never that simple and your approach will depend on many factors not listed in your question. (Please note that this answer may be different for concerns other than safety.) If I can be of any further assistance, please feel free to inquire.
Michael Brown, CSP Retired

Occupational (OSHA) and Environmental Hazards

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Mike Brown CSP Retired

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I specialize in the professional management of occupational safety and health as well as workers` compensation to reduce losses and improve production and address related issues through a comprehensive approach by senior management using proven principals.I worked for over twenty (20) years in the management of occupational safety, health and workers` compensation and safety training (Retired from employment in 1996 due to a stroke, which prevented the extensive travel required).

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