This year a company was issued three citation items that the company failed to have a “company executive” certify its annual summaries of workplace injuries and illnesses entered on its OSHA 300 Logs for 2007, 2008, and 2009, in violation of 29 C.F.R. § 1904.32(b)(4). OSHA proposed a penalty of $800 for each alleged violation. OSHA’s sole allegation in this case is that the company’s Safety and Risk Manager (“safety manager”) did not qualify as a “company executive” under § 1904.32(b)(4) when he certified the annual summaries for the years in question. The ALJ and the OSHRC upheld this citation. The company’s defense was that the phrase “highest ranking company official” was “vague”! Here are the details and results of the case…