OSHA insists recordkeeping obligations are ongoing (United States Court of Appeals for the D.C. circuit ruled differently)

OSHA is making a formal request of the Advisory Committee on Construction Safety and Health to submit a recommendation on whether the agency should proceed with proposed amendments to the recordkeeping regulations at 29 CFR Part 1904.  The proposed amendments would clarify that employers have a duty to make and maintain accurate records of work-related injuries and illnesses and that this duty is an ongoing obligation.  The proposal comes in response to a 2012 court ruling that went against OSHA (AKM LLC dba Volks Constructors v. Secretary of Labor, 675 F.3d 752).

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