[Federal Register Volume 81, Number 243 (Monday, December 19, 2016)]
[Rules and Regulations]
[Pages 91792-91810]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-30410]
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DEPARTMENT OF LABOR
Occupational Safety and Health Administration
29 CFR Part 1904
[Docket No. OSHA-2015-0006]
RIN 1218-AC84
Clarification of Employer's Continuing Obligation To Make and
Maintain an Accurate Record of Each Recordable Injury and Illness
AGENCY: Occupational Safety and Health Administration (OSHA), Labor.
ACTION: Final rule.
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SUMMARY: OSHA is amending its recordkeeping regulations to clarify that
the duty to make and maintain accurate records of work-related injuries
and illnesses is an ongoing obligation. The duty to record an injury or
illness continues for as long as the employer must keep records of the
recordable injury or illness; the duty does not expire just because the
employer fails to create the necessary records when first required to
do so. The amendments consist of revisions to the titles of some
existing sections and subparts and changes to the text of some existing
provisions. The amendments add no new compliance obligations and do not
require employers to make records of any injuries or illnesses for
which records are not currently required to be made.
The amendments in this rule are adopted in response to a decision
of the United States Court of Appeals for the District of Columbia
Circuit. In that case, a majority held that the Occupational Safety and
Health Act does not permit OSHA to impose a continuing recordkeeping
obligation on employers. One judge filed a concurring opinion
disagreeing with this reading of the statute, but finding that the text
of OSHA's recordkeeping regulations did not impose continuing
recordkeeping duties. OSHA disagrees with the majority's reading of the
law, but agrees that its recordkeeping regulations were not clear with
respect to the continuing nature of employers' recordkeeping
obligations. This final rule is designed to clarify the regulations in
advance of possible future federal court litigation that could further
develop the law on the statutory issues addressed in the D.C. Circuit's
decision.
DATES: This final rule becomes effective on January 18, 2017.
Collections of information: There are collections of information
contained in this final rule (see Section XI, Office of Management and
Budget Review Under the Paperwork Reduction Act of 1995).
Notwithstanding the general date of applicability that applies to all
other requirements contained in the final rule, affected parties do not
have to comply with the collections of information in the recordkeeping
regulations (as revised by this final rule) until the Department of
Labor publishes a separate document in the Federal Register announcing
that the Office of Management and Budget has approved them under the
Paperwork Reduction Act.
FOR FURTHER INFORMATION CONTACT: Press inquiries: Mr. Frank Meilinger,
Director, Office of Communications, OSHA, U.S. Department of Labor,
Room N-3647, 200 Constitution Avenue NW., Washington, DC 20210;
telephone (202) 693-1999; email meilinger.francis2@dol.gov.
Technical inquiries: Ms. Mandy Edens, Director, Directorate of
Technical Support and Emergency Management, OSHA, U.S. Department of
Labor, Room N-3653, 200 Constitution Avenue NW., Washington, DC 20210;
telephone (202) 693-2270; email edens.mandy@dol.gov.
Copies of this Federal Register notice and news releases:
Electronic copies of these documents are available at OSHA's Web page
at http://www.osha.gov.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Background
A. The OSH Act and Citation of OSH Act Violations
B. OSHA's Recordkeeping Regulations and the Importance of
Accurate Workplace Injury and Illness Data
C. An Employer's Failure to Record a Recordable Illness or
Injury Is a Failure To Maintain Accurate Injury and Illness Records
and Is a Continuing Violation
D. The D.C. Circuit's Decision in Volks II
E. Events Preceding This Final Rule
II. Legal Authority
A. Overview
B. The OSH Act Authorizes the Secretary To Impose a Continuing
Obligation on Employers To Make and Maintain Accurate Records of
Work-Related Injuries and Illnesses, and Incomplete or Otherwise
Inaccurate Records Create Ongoing, Citable Conditions
1. Section 8(c) of the Act Governs Employers' Recordkeeping
Obligations, and That Provision Authorizes the Imposition of
Continuing Obligations on Employers To Make and Maintain Accurate
Records of Work-Related Illnesses and Injuries
2. The OSH Act's Statute of Limitations Does Not Define OSHA
Violations or Address When Violations Occur, Nor Does the Language
in Section 9(c) Preclude Continuing Recordkeeping Violations
3. Incomplete or Otherwise Inaccurate Records of Work-Related
Illnesses and Injuries Create an Ongoing Condition Detrimental to
Full Enforcement of the Act
4. OSHA Is Acting Within Its Regulatory Authority, and
Consistently With the General Case Law, in Issuing This Clarifying
Rule
III. Summary and Explanation of the Final Rule
A. Description of Revisions
1. Section 1904.0--Purpose
2. Subpart C--Making and Maintaining Accurate Records,
Recordkeeping Forms, and Recording Criteria
3. Paragraph (a) of Sec. 1904.4--Basic Requirement
4. Note to Paragraph (a) of Sec. 1904.4
5. Paragraph (b)(3) of Sec. 1904.29--How quickly must each
injury or illness be recorded?
6. Section 1904.32--Year-End Review and Annual Summary
7. Paragraph (a) of Sec. 1904.32--Basic Requirement
8. Paragraph (b)(1) of Sec. 1904.32--How extensively do I have
to review the OSHA 300 Log at the end of the year?
9. Section 1904.33--Retention and Maintenance of Accurate
Records
10. Paragraph (b)(1) of Sec. 1904.33--Other than the obligation
identified in Sec. 1904.32, do I have further recording duties with
respect to OSHA 300 Logs and 301 Incident Reports during the five-
year retention period?
11. Paragraph (b)(2) of Sec. 1904.33--Do I have to make
additions or corrections to the annual summary during the five-year
retention period?
12. Paragraph (b)(3) of Sec. 1904.33
13. Section 1904.34--Change in Business Ownership
14. Paragraph (b)(2) of Sec. 1904.35--Do I have to give my
employees and their representatives access to the OSHA injury and
illness records?
15. Paragraph (b)(2)(iii) of Sec. 1904.35--If an employee or
representative asks for access to the OSHA 300 Log, when do I have
to provide it?
16. Subpart E--Reporting Accurate Fatality, Injury, and Illness
Information to the Government
17. Section 1904.40--Providing Accurate Records to Government
Representatives
18. Paragraph (a) of Sec. 1904.40--Basic Requirement
IV. State Plans
V. Final Economic Analysis
VI. Regulatory Flexibility Certification
VII. Environmental Impact Assessment
VIII. Federalism
IX. Unfunded Mandates
X. Consultation and Coordination With Indian Tribal Governments
XI. Office of Management and Budget Review Under the Paperwork
Reduction Act of 1995
I. Background
A. The OSH Act and Citation of OSH Act Violations
The Occupational Safety and Health Act of 1970 (OSH Act or Act)
arose out of a Congressional finding that personal injuries and
illnesses arising out of work situations impose a substantial burden
upon, and are a hindrance to, interstate commerce in terms of lost
production, wage loss, medical expenses, and disability compensation
payments. See 29 U.S.C. 651(a). Accordingly, the purpose of the statute
is to assure so far as possible every working man and woman in the
Nation safe and healthful working conditions. See 29 U.S.C. 651(b).
To effectuate the Act's purpose, Congress authorized the Secretary
of Labor to promulgate occupational safety and health standards (29
U.S.C. 655); a standard, as defined in the Act, requires conditions, or
the adoption or use of one or more practices, means, methods,
operations, or processes, reasonably necessary or appropriate to
provide safe or healthful employment and places of employment. See 29
U.S.C. 652(8). The Act also grants broad authority to the Secretary to
promulgate other types of regulations such as those related to employer
self-inspections and keeping employees informed of matters related to
occupational safety and health. 29 U.S.C. 657(c). The OSH Act
specifically directs the Secretary to promulgate regulations requiring
employers to make and maintain accurate records of work-related
injuries and illnesses. 29 U.S.C. 657(c)(1) and (2), 673(a); see also
651(b)(12), 657(g)(2), 673(e).
OSHA issues citations and assesses monetary penalties when it finds
that employers are not complying with the Act or with applicable
standards and regulations. 29 U.S.C. 658, 659, 666. Section 9(c) of the
OSH Act contains a statute of limitations providing that no citation
may be issued after the expiration of six months following ``the
occurrence of any violation.'' 29 U.S.C. 658(c). Generally, OSH Act
violations continue to occur for as long as employees are exposed to
the condition posed by the non-compliant workplace. See Sec'y of Labor
v. Cent. of Georgia R.R. Co., 5 BNA OSHC 1209, 1211 (Rev. Comm'n 1977)
(explaining that a violation occurs ``whenever . . . [a] standard is
not complied with and an employee has access to the resulting zone of
danger''). Thus, employers have an ongoing obligation to correct
conditions that violate OSHA standards and regulations, and under
section 9(c), violations are subject to citations and penalties for up
to six months after the last instance of employee exposure to the
violative condition.
B. OSHA's Recordkeeping Regulations and the Importance of Accurate
Workplace Injury and Illness Data
In 1971, OSHA issued its first recordkeeping regulations at 29 CFR
part 1904. OSHA promulgated revisions to these regulations in 2001 in
an effort to improve the quality of workplace injury and illness
records by making OSHA's recordkeeping system easier to use and
understand. See 66 FR 5916 (January 19, 2001).
OSHA's recordkeeping regulations require employers to record
information about certain injuries and illnesses occurring in their
workplaces, and to make that information available to employees, OSHA,
and the Bureau of Labor Statistics (BLS). Employers must record work-
related injuries and illnesses that meet one or more recording
criteria, including injuries and illnesses resulting in death, loss of
consciousness, days away from work, restricted work activity or job
transfer, medical treatment beyond first aid, or a diagnosis of a
significant injury or illness by a physician or other licensed health
care professional. 29 CFR 1904.7. Employers must document each
recordable injury or illness on an ``OSHA 300'' form, which is a log of
all work-related injuries and illnesses. 29 CFR 1904.29(a) through
(b)(1). Employers also must prepare a supplementary ``OSHA 301 Incident
Report'' or equivalent form for each recordable injury and illness; the
Incident Reports provide additional details about the injuries and
illnesses recorded in the 300 Log. 29 CFR 1904.29(b)(2).
At the end of each calendar year, employers must review their 300
Logs to verify that the entries are complete and accurate. 29 CFR
1904.32(a)(1). Employers also must correct any deficiencies identified
during this annual review. Id. By February 1 of each year, employers
must create, certify, and post annual summaries of the cases listed on
their 300 Logs for the prior calendar year. 29 CFR 1904.32(a), (b).
Annual summaries must remain posted until April 30 each year. 29 CFR
1904.32(b)(6). Employers must retain their OSHA Logs, Incident Reports,
and annual summaries for five years following the end of the calendar
year that they cover. 29 CFR 1904.33(a). The regulations contain
provisions explaining when records need to be revised during the
retention period.
Accurate injury and illness records serve several important
purposes. See 66 FR at 5916-17, January 19, 2001. One purpose is to
provide information to employers. The information in the OSHA-required
records makes employers more aware of the kinds of injuries and
illnesses occurring and the hazards that cause or contribute to them.
When employers analyze and review the information in their records,
they can identify and correct hazardous workplace conditions. Injury
and illness records are essential for employers to manage their safety
and health programs effectively; these records permit employers to
track injuries and illnesses over time so they can evaluate the
effectiveness of protective measures implemented in response to
identified hazards.
Similarly, employees--who have access to OSHA injury and illness
records throughout the five-year retention period (see 29 CFR
1904.35)--can use information about the occupational injuries and
illnesses occurring in their workplaces to become better informed
about, and more alert to, the hazards they face. Employees who
are aware of the hazards around them may be more likely to follow safe
work practices and to report workplace hazards to their employers. When
employees are aware of workplace hazards, and participate in the
identification and control of those hazards, the overall level of
safety and health in the workplace can improve.
OSHA also has access to employer injury and illness records during
the retention period (see 29 CFR 1904.40 and 1904.41), and these
records are an important source of information for OSHA and enhance its
enforcement efforts. During the initial stages of an inspection, an
OSHA representative reviews the employer's injury and illness data so
that OSHA can focus its inspection on the hazards revealed by the
records. In some years, OSHA has also surveyed a subset of employers
covered by the OSH Act for their injury and illness data, and used that
information to help identify the most dangerous types of worksites and
the most prevalent types of safety and health hazards.
Additionally, BLS uses data derived from employers' injury and
illness records to develop national statistics on workplace injuries
and illnesses. These statistics include information about the source,
nature, and type of the injuries and illnesses that are occurring in
the nation's workplaces. To obtain the data to develop national
statistics, BLS and participating State agencies conduct an annual
survey of employers in almost all sectors of private industry. BLS
makes the aggregate survey results available for research purposes and
for public information. This data provides information about the
incidence of workplace injuries and illnesses and the nature and
magnitude of workplace safety and health problems. Congress, OSHA, and
safety and health policymakers in Federal, State, and local governments
use BLS statistics to make decisions concerning safety and health
legislation, programs, and standards. And employers and employees can
use BLS statistics to compare the injury and illness data from their
workplaces with data from the nation as a whole.
C. An Employer's Failure To Record a Recordable Illness or Injury Is a
Failure To Maintain Accurate Injury and Illness Records and Is a
Continuing Violation
A continuing violation exists when there is noncompliance with
``the text of . . . [a] pertinent law [that] imposes a continuing
obligation to act or refrain from acting.'' Earle v. Dist. of Columbia,
707 F.3d 299, 307 (D.C. Cir. 2012). Where there is an ongoing
obligation to act, each day the action is not taken results in a
continuing, ongoing violation. In other words, ``a new claim accrues
each day the violation is extant.'' Interamericas Inv., Ltd. v. Fed.
Reserve Sys., 111 F.3d 376, 382 (5th Cir. 1997). For example, in United
States v. Edelkind, 525 F.3d 388 (5th Cir. 2008), the Fifth Circuit
found that willfully failing to pay child support as required by
federal law was a continuing offense because ``each day's acts . . .
[brought] a renewed threat of the substantive evil Congress sought to
prevent.'' Id. at 394-95 (internal quotation marks and citations
omitted). And in Postow v. OBA Federal Savings & Loan Association, 627
F.2d 1370 (D.C. Cir. 1980), the D.C. Circuit held that a lender's
failure to provide required disclosures to borrowers was a continuing
violation of the Truth-in-Lending Act because the violation subverted
the goals of the statute every day the borrowers did not have the
information. Id. at 1379-80. See also, e.g., United States v. Bailey,
444 U.S. 394, 413 (1980) (escape from federal custody is a continuing
offense in light of ``the continuing threat to society posed by an
escaped prisoner''); United States v. George, 625 F.3d 1124 (9th Cir.
2010) (failure to comply with statute requiring registration as a sex
offender is a continuing offense), vacated on other grounds, 672 F.3d
1126 (9th Cir. 2012); United States v. Franklin, 188 F.2d 182 (7th Cir.
1951) (Alien Registration Act imposes ongoing registration obligation;
failure to register is a continuing violation).
OSHA has long treated recordkeeping violations under the OSH Act as
continuing violations--and, as explained below in Section II.B.1 of
this preamble--this view is consistent with section 8(c) of the Act, in
which Congress instructed the Secretary to require employers to make
and maintain accurate records of workplace injuries and illnesses.
OSHA's longstanding position is that an employer's duty to record an
injury or illness continues for the full duration of the record-
retention-and-access period, i.e., for five years after the end of the
calendar year in which the injury or illness became recordable. This
means that if an employer initially fails to record a recordable injury
or illness, the employer still has an ongoing duty to record that case;
the recording obligation does not expire simply because the employer
failed to record the case when it was first required to do so. As long
as an employer fails to comply with its ongoing duty to record an
injury or illness, and therefore with its obligation to maintain
accurate records, there is an ongoing violation of OSHA's recordkeeping
requirements that continues to occur every day employees work at the
site. Therefore, OSHA can cite employers for such recordkeeping
violations for up to six months after the five-year retention period
expires without running afoul of the OSH Act's statute of
limitations.\1\ OSHA has consistently issued such citations since it
enacted its first recordkeeping regulations, as evidenced by the case
law in the following paragraph. The purpose of this final rule is
simply to clarify what has always been OSHA's interpretation of its
recordkeeping regulations.
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\1\ Of course, OSHA may not issue a citation more than six
months after the employer corrects the violation. See, e.g., Sec'y
of Labor v. Manganas Painting Co., 21 BNA OSHC 2043, 2048 (Rev.
Comm'n 2007) (citation was time-barred where the employer abated the
violation more than six months prior to the issuance date).
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The Occupational Safety and Health Review Commission has upheld
OSHA's position on the continuing nature of recordkeeping violations.
See, e.g., Sec'y of Labor v. Gen. Dynamics, 15 BNA OSHC 2122 (Rev.
Comm'n 1993) (recordkeeping violations ``occur'' at any point during
the retention period when records are inaccurate, so citations for
those violations are not barred simply because they are issued more
than six months after the obligation to record first arose); Sec'y of
Labor v. Johnson Controls, Inc., 15 BNA OSHC 2132 (Rev. Comm'n 1993)
(recordkeeping violations continue until correction or expiration of
the retention period). The Commission addressed this issue most
recently in Secretary of Labor v. AKM LLC, 23 BNA OSHC 1414 (Rev.
Comm'n 2011) (Volks I), confirming that an employer's failure to make a
required OSHA record is a continuing violation, and that an uncorrected
violation continues until the employer is no longer required to keep
OSHA records for the year at issue.\2\
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\2\ Although the Coalition for Workplace Safety stated that OSHA
has never expressed a policy of treating recordkeeping violations as
ongoing, Ex. 0013, OSHA's citation history--and the Commission
decisions upholding those citations--make clear that OSHA took this
approach for many years. See Martin v. OSHRC, 499 U.S. 144, 157
(1991) (OSHA citations embody the Secretary's interpretation of
regulations). See discussion in Section I.C, Background, above.
Throughout this preamble, exhibit numbers are referred to in the
form Ex. XXXX, where XXXX reflects the last four digits of the full
document number (OSHA-2015-006-XXXX).
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D. The D.C. Circuit's Decision in Volks II
A panel of the D.C. Circuit reviewed the Commission's Volks I
decision, and on April 6, 2012, issued a decision--
Volks II--reversing the Commission. AKM LLC v. Sec'y of Labor, 675 F.3d
752 (D.C. Cir. 2012) (Volks II). The majority opinion in Volks II,
without discussion of Commission precedent to the contrary, held that
the OSH Act does not provide authority for the Secretary to impose a
continuing recordkeeping obligation on employers, explaining that ``the
. . . language in [the OSH Act] . . . which deals with record-keeping
is not authorization for OSHA to cite the employer for a record-making
violation more than six months after the recording failure.'' Id. at
758; see also id. at 756-57. The majority stated that OSHA must cite an
employer for failing to record an injury or illness within six months
of the first day on which the regulations require the recording; a
citation issued later than that, according to the Volks II majority, is
barred by the OSH Act's statute of limitations. Id. at 753-59.
In a separate opinion concurring in the judgment in Volks II, Judge
Garland disagreed with the majority's conclusion that the OSH Act did
not permit continuing record-making obligations. Judge Garland agreed
with the Secretary that the OSH Act does allow for continuing
violations of recordkeeping requirements. He concluded, however, that
the specific language in the recordkeeping regulations reviewed by the
panel did not implement this statutory authority and did not create
continuing recordkeeping obligations. Id. at 759-64. Under the analysis
in Judge Garland's concurring opinion, OSHA in fact has statutory
authority to create a continuing obligation for employers to make and
maintain accurate records of work-related illnesses and injuries, and
can revise its recordkeeping regulations to more clearly implement that
statutory authority.
Thus, because of the Volks II decision, OSHA has decided to clarify
employers' obligations under its recordkeeping regulations and to
elaborate on its understanding of the statutory basis for those
obligations. OSHA disagrees with the legal holding in the majority
opinion in Volks II, but agrees with Judge Garland that, while the OSH
Act gives the Secretary authority to impose continuing recordkeeping
obligations, the text of the recordkeeping regulations did not make
clear OSHA's longstanding intention to fully implement that authority.
Therefore, OSHA is changing its recordkeeping regulations to clarify
that the duty to make and maintain an accurate record of a work-related
illness or injury is an ongoing obligation that continues until the
required record is made or until the end of the record-retention-and-
access period prescribed by the regulations. To that end, OSHA is
revising the titles of some sections and subparts in part 1904 and
changing the text of some of the recordkeeping requirements. OSHA
describes the changes in SUPPLEMENTARY INFORMATION, Section III, later
in this preamble.
E. Events Preceding This Final Rule
On July 29, 2015, OSHA issued a proposed rule entitled
``Clarification of Employer's Continuing Obligation to Make and
Maintain an Accurate Record of Each Recordable Injury and Illness.'' 80
FR 45116. Before issuing the proposal, OSHA consulted with the Advisory
Committee on Construction Safety and Health (ACCSH). OSHA provided
ACCSH with a summary and explanation of the proposal and a statement
regarding the need for the proposed revisions to 29 CFR part 1904. On
December 4, 2014, ACCSH voted to recommend that OSHA proceed with the
proposal.\3\
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\3\ The National Federation of Independent Businesses has
requested that the transcript of ACCSH's meeting be added to the
docket of this rulemaking. Ex. 0014. The transcript can now be found
at Ex. 0030.
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OSHA provided 60 days for public comment and eventually extended
the comment period for an additional 30 days. 80 FR 57765. OSHA
received a total of 30 comments. The comments are addressed elsewhere
in this preamble.
II. Legal Authority
A. Overview
As explained previously, in SUPPLEMENTARY INFORMATION, Section I.A,
the OSH Act authorizes the Secretary of Labor to issue ``standards''
and other ``regulations.'' See, e.g., 29 U.S.C. 655, 657. An
occupational safety and health standard, issued pursuant to section 6
of the Act, prescribes measures to be taken to remedy an identified
occupational hazard. Other regulations, issued pursuant to general
rulemaking authority found, inter alia, in section 8 of the Act,
establish enforcement or detection procedures designed to further the
goals of the Act generally. 29 U.S.C. 657(c); Workplace Health and
Safety Council v. Reich, 56 F.3d 1465, 1468 (D.C. Cir. 1995). This
final rule amends OSHA's recordkeeping regulations issued pursuant to
authority expressly granted by sections 8 and 24 of the Act. 29 U.S.C.
657, 673. It simply clarifies existing duties under part 1904, and does
not impose any new substantive recordkeeping requirements.
Many commenters suggested that OSHA does not have legal authority
to promulgate this rule. Exs. 0003, 0008, 0009, 0010, 0011, 0012, 0013,
0014, 0016, 0017, 0020, 0021, 0023, 0026. OSHA disagrees. As recognized
by Judge Garland in his concurring opinion in Volks II, and explained
in more detail in SUPPLEMENTARY INFORMATION, Section II.B, later in
this preamble, the OSH Act plainly authorizes this regulatory action.
Numerous provisions of the OSH Act both underscore Congress'
acknowledgement that accurate injury and illness records are a critical
component of the national occupational safety and health program and
give the Secretary broad authority to enact recordkeeping regulations
that create a continuing obligation for employers to make and maintain
accurate records of work-related illnesses and injuries. Section
2(b)(12) of the Act states that one of the purposes of the OSH Act is
to assure, so far as possible, safe and healthful working conditions by
providing for appropriate reporting procedures that will help achieve
the objectives of the Act and ``accurately describe'' the nature of the
occupational safety and health problem. See 29 U.S.C. 651(b)(12).
Section 8(c)(1) requires each employer to ``make, keep and preserve''
and to ``make available'' to the Secretary such records prescribed by
regulation as necessary or appropriate for the enforcement of the Act
or for developing information regarding the causes and prevention of
occupational accidents and illnesses. See 29 U.S.C. 657(c)(1). Section
8(c)(2) requires the Secretary to prescribe regulations requiring
employers to ``maintain accurate records'' of, and to make periodic
reports on, work-related deaths, injuries and illnesses. See 29 U.S.C.
657(c)(2). Section 8(g)(2) of the Act generally empowers the Secretary
to prescribe such rules and regulations as he may deem necessary to
carry out his responsibilities under the Act. See 29 U.S.C. 657(g)(2).
Section 24(a) requires the Secretary to develop and maintain an
effective program of collection, compilation, and analysis of
occupational safety and health statistics and to compile accurate
statistics on work injuries and illnesses. See 29 U.S.C. 673(a). And
Section 24(e) provides that on the basis of the records made and kept
pursuant to section 8(c) of the Act, employers must file such reports
with the Secretary as the Secretary prescribes by regulation as
necessary to carry out his functions under the Act. See 29 U.S.C.
673(e).
B. The OSH Act Authorizes the Secretary To Impose a Continuing
Obligation on Employers To Make and Maintain Accurate Records of Work-
Related Injuries and Illnesses, and Incomplete or Otherwise Inaccurate
Records Create Ongoing, Citable Conditions
1. Section 8(c) of the Act Governs Employers' Recordkeeping
Obligations, and That Provision Authorizes the Imposition of Continuing
Obligations on Employers To Make and Maintain Accurate Records of Work-
Related Illnesses and Injuries
``Whether [an] . . . obligation is continuing is a question of
statutory construction.'' Earle, 707 F.3d at 307. The express language
of the OSH Act readily supports a continuing violation theory in
recordkeeping cases. And section 8(c) grants the Secretary broad
authority to impose requirements he considers ``necessary or
appropriate,'' including recordkeeping regulations that provide that an
employer's duty to make records of injuries and illnesses is an ongoing
obligation. 29 U.S.C. 657(c).
Section 8(c)(2) requires the Secretary to prescribe regulations
requiring employers to ``maintain accurate records'' of work-related
deaths, injuries and illnesses. See 29 U.S.C. 657(c)(2) (emphasis
added). And section 8(c)(1) requires employers to ``make, keep and
preserve'' and to ``make available'' records that the Secretary
identifies as necessary or appropriate for the enforcement of the Act
or for developing information regarding the causes and prevention of
occupational accidents and illnesses. See 29 U.S.C. 657(c)(1) (emphasis
added). The language Congress used in these provisions therefore
authorizes the Secretary to require employers to have on hand and to
make available records that accurately reflect all of the recordable
injuries and illnesses that occurred during the designated time period.
Moreover, this statutory language is inconsistent with any suggestion
that Congress intended the duty to record an injury or illness to be a
discrete obligation that expires if the employer fails to comply on the
first day the Secretary's regulations require recording.
This is because the words ``accurate'' and ``maintain'' in section
8(c)(2) of the Act connote a continued course of conduct that includes
an ongoing obligation to create records. The word ``maintain'' means to
``[c]ause or enable (a condition or state of affairs) to continue,'' an
example being when one works to ensure that something stays ``in good
condition or in working order by checking or repairing it regularly.''
http://www.oxforddictionaries.com/us/definition/american_english/maintain?searchDictCode=all. Therefore, ``maintain'' plainly implies an
ongoing action. See, e.g., Carey v. Shiley, Inc., 32 F.Supp.2d 1093,
1103 (S.D. Iowa 1998) (``continuing duty to maintain records for'' the
Food and Drug Administration). And ``accurate'' means ``conforming
exactly to truth,'' and is synonymous with ``exact.'' http://www.merriam-webster.com/dictionary/accurate. See also, e.g., Huntington
Sec. Corp. v. Busey, 112 F.2d 368, 370 (6th Cir. 1940) (noting that the
term `` `accurately' . . . in its ordinary use[ ] means precisely,
exactly correctly, without error or defect''). Therefore, the OSH Act's
direction to enact regulations requiring employers to ``maintain
accurate [injury and illness] records'' is a mandate for the Secretary
to impose an ongoing or continuing duty on employers to have true or
exact documentation of recordable incidents. An employer cannot be said
to have (or to be keeping or maintaining) accurate (or true or exact)
records of injuries and illnesses for a particular calendar year if
there are recordable injuries or illnesses that occurred during that
year that are missing from those records. Put simply, the Secretary
cannot fulfill the statutory obligation of ensuring that employers
``maintain accurate records'' without imposing on employers an ongoing
duty to create records for injuries and illnesses in the first place; a
duty to maintain accurate records inherently implies an ongoing
obligation to create the records that must be maintained.
The Fourth Circuit recognized as much in Sierra Club v. Simkins
Industries, 847 F.2d 1109, 1115 (4th Cir. 1988), a Clean Water Act
case, when it refused to allow a company to defend against its failure
to file and retain water sampling records on the ground that it never
collected the data it needed to create the records in the first place.
The court ruled that an ongoing duty to maintain records implies a
corresponding, and continuing, duty to have those records, explaining
that it would not allow the company ``to escape liability . . . by
failing at the outset to sample and to create and retain the necessary
. . . records.'' Id. See also, e.g., Big Bear Super Mkt. No. 3 v. INS,
913 F.2d 754, 757 (9th Cir. 1990) (per curiam) (statutory and
regulatory scheme described by the court as requiring companies to
``maintain'' documents is interpreted to impose a ``continuing duty''
on those companies ``to prepare and make'' the documents in the first
instance); Park v. Comm'r of Internal Revenue, 136 T.C. 569, 574 (U.S.
Tax Ct. 2011) (noting that a party that did not create required records
thereby failed to ``keep'' those records), rev'd and remanded on other
grounds, 722 F.3d 384 (D.C. Cir. 2013).
The ``make, keep, and preserve'' and ``make available'' language in
section 8(c)(1) similarly envisions a continuing duty to record and
provides additional support for the Secretary's interpretation of the
``maintain accurate records'' language in section 8(c)(2). ``Keep'' is
a synonym for ``maintain,'' http://thesaurus.com/browse/maintain, and
both words imply a continued course of conduct, as does ``preserve.''
\4\ See, e.g., Powerstein v. Comm'r of Internal Revenue, T.C. Memo
2011-271, 2011 WL 5572600, at *13 (U.S. Tax Ct. Nov. 16, 2011)
(interpreting statutory and regulatory requirements to ``keep'' tax
records to mean that taxpayers must ``maintain'' such records);
Freedman v. Comm'r of Internal Revenue, T.C. Memo 2010-155, 2010 WL
2942167, at *1 (U.S. Tax Ct. July 21, 2010) (same).
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\4\ The legislative history of the OSH Act shows that Congress
used ``keep'' and ``maintain'' synonymously. In a Senate Report,
Congress described section 8(c)(2)--which talks about
``maintaining'' records--as ``requiring employers to keep records of
all work-related injuries and diseases.'' S. Rep. No. 91-1282, at 31
(1970), reprinted in Subcomm. on Labor of the Comm. on Labor and
Public Welfare, Legislative History of the Occupational Safety and
Health Act of 1970, at 171 (1971) (emphasis added).
---------------------------------------------------------------------------
The fact that Congress included the word ``make'' in a phrase with
two other terms that both call for a continuing action suggests that
``make'' was also intended to signify a continuing course of conduct in
the recordkeeping context. The most reasonable reading of section
8(c)(1), particularly in light of the ``maintain accurate records''
language in section 8(c)(2), is that the phrase ``make, keep, and
preserve'' authorizes one continuous recordkeeping requirement that
includes both the creation and the keeping of records. See, e.g., Davis
v. Michigan Dep't of Treasury, 489 U.S. 803, 809 (1989) (noting a
``fundamental canon of statutory construction that the words of a
statute must be read in their context and with a view to their place in
the overall statutory scheme''). The related authorization to the
Secretary to prescribe such recordkeeping regulations as he considers
``necessary or appropriate'' further emphasizes the breadth of the
Secretary's discretion in implementing the statute.
Thus, the Secretary does not believe that section 8(c) authorizes
two and only two discrete duties: A duty to create a record that can
arise at only one moment in time, and a duty to preserve
that record if it should be created. Such a view would be inconsistent
with the most relevant provision of the Act, section 8(c)(2), which is
the provision that specifically addresses the Secretary's authority to
prescribe regulations for injury and illness recordkeeping, i.e., to
prescribe regulations that require employers to ``maintain accurate
records'' of workplace illnesses and injuries. Nothing about the
Congressional direction to ``maintain accurate records'' is naturally
read as creating two entirely discrete obligations, or as conveying
Congressional intent to limit the duty to make a required record to a
single point in time. Records that omit work-related injuries and
illnesses are not accurate, and no purpose is served by maintaining
inaccurate records. Instead, Congress intended employers, employees,
and the Secretary to have access to accurate information about injuries
and illnesses occurring in workplaces.
The requirement in section 8(c)(1) that employers ``make
available'' such records as the Secretary prescribes regarding injuries
and illnesses further illustrates that section 9(c)'s statute of
limitations does not limit the Secretary to acquiring only six months
of accurate injury and illness data. A regulation requiring employers,
if requested, to make available accurate records showing injuries and
illnesses that have occurred within the past few years is on its face
well within the OSH Act's grant of authority. Nothing in the statutory
language suggests that the Secretary can only require employers to
provide information regarding work-related injuries and illnesses that
have occurred within the past six months. Such a limitation would
cripple OSHA's ability to gather complete information and to improve
understanding of safety and health issues, contrary to Congressional
intent. Furthermore, the duty to make accurate multi-year records
available upon request arises when the request is made, and the statute
of limitations therefore does not begin to run until the request is
made and the employer fails to comply.
It therefore follows that section 8(c) of the Act authorizes the
Secretary to enact regulations that impose a continuing obligation on
employers to make and maintain accurate records of work-related
illnesses and injuries. Not only are such recordkeeping regulations
expressly called for by the language of section 8(c), but they are also
consistent with Congressional intent and the purpose of the OSH Act.
The Supreme Court recognizes a ``familiar canon of statutory
construction that remedial legislation should be construed broadly to
effectuate its purposes.'' Tcherepnin v. Knight, 389 U.S. 332, 336
(1967). And reading the statute in light of its protective purposes
further supports the Secretary's interpretation that the Act calls for
treating the duty to record injuries and illnesses as a continuing
obligation. See, e.g., United States v. Advance Mach. Co., 547 F. Supp.
1085, 1090-91 (D. Minn. 1982) (requirement in Consumer Product Safety
Act to ``immediately inform'' the government of product defects is read
as creating a continuing obligation to report because any other reading
would frustrate the statute's goal of protecting the public from
hazards).
The legislative history of the OSH Act also demonstrates that
Congress wanted employers to have accurate injury and illness records
both for the purpose of making workplaces safer and healthier and for
the purpose of allowing the federal government to study the nation's
occupational safety and health problems. As the House Committee on
Education and Labor noted, before passage of the OSH Act it was
impossible to know the extent of national occupational safety and
health issues due to variability in state reporting measures; thus,
Congress viewed it as an ``evident Federal responsibility'' to provide
for ``[a]ccurate, uniform reporting standards.'' H.R. Rep. No. 91-1291,
at 15 (1970), reprinted in Subcomm. on Labor of the Comm. on Labor and
Public Welfare, Legislative History of the Occupational Safety and
Health Act of 1970, at 845 (1971). See also 29 U.S.C. 673(a) (``The
Secretary shall compile accurate statistics on work injuries and
illnesses . . .''); Sec'y of Labor v. Gen. Motors Corp., 8 BNA OSHC
2036, 2039 (Rev. Comm'n 1980) (``Examination of the legislative history
of [sections 8(c)(1) and 8(c)(2)] . . . shows a clear congressional
intent that th[e] reporting requirement be interpreted broadly in order
to develop information for future scientific use.'').
Some commenters, including the Coalition for Workplace Safety and
the American Health Care Association, stated a concern that
interpreting section 8(c) to authorize continuing violations means that
OSHA is claiming unfettered discretion to essentially eliminate any
statute of limitations for recordkeeping violations. Exs. 0011, 0013,
0020. OSHA disagrees. OSHA's interpretation does not mean that the
Secretary's authority is unconstrained. Under section 8(c)(1), the
records the Secretary requires must be ``necessary or appropriate'' to
enforcement of the Act or to gathering information regarding the causes
or prevention of occupational accidents or illnesses. 29 U.S.C.
657(c)(1). Under section 8(d), the Secretary must obtain information
with a minimum burden on employers, especially small businesses, and
reduce unnecessary duplication to the maximum extent feasible. 29
U.S.C. 657(d). Moreover, under the Paperwork Reduction Act, the
Secretary and the Office of Management and Budget must determine that a
recordkeeping requirement will have practical utility and will not be
unduly burdensome. 44 U.S.C. 3506(c)(3).
2. The OSH Act's Statute of Limitations Does Not Define OSHA Violations
or Address When Violations Occur, Nor Does the Language in Section 9(c)
Preclude Continuing Recordkeeping Violations
As explained previously, it is section 8(c) of the OSH Act that
authorizes the Secretary to establish the nature and scope of
employers' recordkeeping obligations. The OSH Act's statute of
limitations in section 9(c) deals only with the question of when OSHA
can cite a violation; it says nothing about what constitutes a
violation, or when a violation occurs. A violation is a breach of a
duty, and the question of what duties the Secretary may prescribe must
logically be dealt with prior to addressing the statute of limitations.
Section 9(c) cannot be read as prohibiting the Secretary from imposing
continuing recordkeeping obligations on employers covered by the OSH
Act when the text and legislative history of the Act show that section
8(c) authorizes the Secretary to create such obligations. Thus, the OSH
Act's statute of limitations simply sets the period within which legal
action must be taken after the obligation ceases or the employer comes
into compliance. See, e.g., Inst. For Wildlife Prot. v. United States
Fish & Wildlife Serv., No. 07-CV-358-PK, 2007 WL 4117978, at *6 (D. Or.
Nov. 16, 2007) (declining to apply applicable statute of limitations to
``nullify . . . [the government's] ongoing duty to designate critical
habitat'' for an endangered species ``and . . . insulate the agency
from challenges to any continued inaction'').
Moreover, ``statutes of limitation in the civil context are to be
strictly construed in favor of the Government against repose,''
Interamericas, 111 F.3d at 382 (citing Badaracco v. Comm'r of Internal
Revenue, 464 U.S. 386 (1984) and E.I. Dupont De Nemours & Co. v. Davis,
264 U.S. 456 (1924)), and nothing in section 9(c) precludes continuing
violations in recordkeeping cases. To the contrary, the language in
section 9(c)
is very general, providing only that ``[n]o citation may be issued . .
. after the expiration of six months following the occurrence of any
violation.'' 29 U.S.C. 658(c). The ``occurrence'' of something is not
necessarily a discrete event; it can encompass actions or events that
continue over time. For example, one dictionary defines ``occurrence''
as ``the existence or presence of something.'' http://dictionary.cambridge.org/dictionary/american-english/occurrence_2. See
also, e.g., PECO Energy Co. v. Boden, 64 F.3d 852, 856-57 (3d Cir.
1995) (scheme of repeated thefts over the span of six years constituted
a single ``occurrence'' such that only one insurance deductible applied
to the resulting loss). Similarly, the term ``occurrence of any
violation'' in section 9(c) does not mean that an OSHA violation is
necessarily a discrete event that takes place at one, and only one,
point in time.
Had Congress wanted the statute of limitations to run from the time
a violation first occurred, it could have used language so stating.
Indeed, Congress has used language more readily susceptible to that
interpretation in other statutes. See, e.g., the Multiemployer Pension
Plans Amendments Act, 29 U.S.C. 1451(f)(1) (statute of limitations runs
from ``the date on which the cause of action arose''); the Federal
Employers' Liability Act, 45 U.S.C. 56 (statute of limitations runs
from ``the day the cause of action accrued''); the general statute of
limitations governing civil actions against the United States, 28
U.S.C. 2401(a) (claims barred unless ``filed within six years after the
right of action first accrues'').
This new rule is intended to clarify that if an employer fails to
record an injury or illness within seven days, the obligation to record
continues on past the seventh day, such that each successive day where
the injury or illness remains unrecorded constitutes a continuing
``occurrence'' of the ongoing violation. If the employer records the
injury on the twentieth, thirtieth, or some later day, the violation
ceases to occur at that point, and any citation would need to be issued
within six months of the cessation of the violation. This position is
entirely consistent with section 9(c). Neither OSHA nor the Commission
nor any court has ever treated section 9(c) as precluding all
continuing violations. Indeed, continuing violations are common in the
OSHA context, with the Commission taking the position that violations
of OSHA requirements, including recordkeeping violations, generally
continue as long as employees are exposed to the non-complying
conditions. See, e.g., Sec'y of Labor v. Arcadian Corp., 20 BNA OSHC
2001 (Rev. Comm'n 2004) (violation of the OSH Act's general duty clause
stemming from the unsafe operation of a urea reactor); Johnson
Controls, 15 BNA OSHC 2132 (recordkeeping); Sec'y of Labor v. Safeway
Store No. 914, 16 BNA OSHC 1504 (Rev. Comm'n 1993) (hazard
communication program and material safety data sheets); Sec'y of Labor
v. Yelvington Welding Serv., 6 BNA OSHC 2013 (Rev. Comm'n 1978)
(fatality reporting); Cent. of Georgia R.R., 5 BNA OSHC 1209
(housekeeping).\5\ Indeed, the Volks II panel also acknowledged that
the duties to preserve records, to train employees, and to correct
unsafe machines may continue. 675 F.3d at 756, 758. The OSH Act simply
would not achieve Congress' fundamental objectives if basic employer
obligations were not continuing.
---------------------------------------------------------------------------
\5\ The American Petroleum Institute stated that the OSH Act
limits continuing obligations only to ``physical hazards.'' Ex.
0020. This assertion finds no basis in the statute or case law. In
any event, access to accurate injury and illness records helps
employers and employees address and avoid physical hazards. See
Section II.B.3, Legal Authority.
---------------------------------------------------------------------------
These cases reflect fundamental OSH Act principles. Safety and
health standards are rules that require, inter alia, ``conditions.'' 29
U.S.C. 652(8). The absence of a required condition violates the
standard. It does not matter when the absence first arose or how long
it has persisted. If a condition is required and is not present (e.g.,
a machine is not guarded or a hazardous materials container is not
labeled), a violation occurs and a citation requiring abatement may be
issued within six months of the observed noncompliance. This
construction follows from the language of the Act and is essential to
the Secretary's ability to enforce compliance. Accordingly, continuing
obligations and violations are a regular occurrence under the OSH Act.
Nothing in section 9(c), which applies equally to standards and
regulations such as recordkeeping requirements, bars them.
In addition, continuing violations have been found to exist under
other laws with statutes of limitations that contain language similar
to that in section 9(c) of the OSH Act. For example, in National
Railroad Passenger Corporation v. Morgan, 536 U.S. 101 (2002), the
Supreme Court addressed the statute of limitations in Title VII of the
Civil Rights Act of 1964, which precludes the filing of claims a
certain number of days after the alleged unlawful employment practice
``occurred.'' See 42 U.S.C. 2000e-5(e)(1). The Court concluded that the
statute authorized application of a continuing violations doctrine in
hostile work environment cases, holding that in such cases, an unlawful
employment action can ``occur'' over a series of days or even years.
Morgan, 536 U.S. at 116-20. Similarly, in Havens Realty Corporation v.
Coleman, 455 U.S. 363 (1982), the Supreme Court found continuing
violations of the Fair Housing Act, which at the time required the
commencement of civil actions within 180 days ``after the alleged
discriminatory housing practice occurred.'' And in Postow, 627 F.2d
1370, the D.C. Circuit found a continuing violation of the Truth-in-
Lending Act, which, at 15 U.S.C. 1640(e), provides that actions must be
brought within one year from the date of the ``occurrence'' of the
violation. The language of section 9(c) of the OSH Act is at least
equally receptive to continuing violations, since it allows citation
within six months of ``the occurrence of any violation.''
``Occurrence'' of ``any'' violation is open-ended language that does
not suggest that a violation can exist at only one moment in time.
Notably, even the Volks II majority appeared to recognize that the
word ``occurrence'' does not necessarily have a single fixed meaning,
stating that ``[o]f course, where . . . a company continues to subject
its employees to unsafe machines . . . or continues to send its
employees into dangerous situations without appropriate training . . .
OSHA may be able to toll the statute of limitations on a continuing
violations theory since the dangers created by the violations
persist.'' 675 F.3d at 758. The court also acknowledged that a
violation of the record-retention requirement--through the loss or
destruction of a previously-created record--is a violation that
continues from the time of the loss or destruction until the conclusion
of the five-year retention period. Id. at 756; see id. at 763
(concurring opinion).
Moreover, continuing violations have been found even under statutes
of limitations that contain language that is arguably less receptive to
continuing violations than section 9(c); courts implicitly recognize
that the underlying legal requirement, not the statute of limitations,
determines whether there is a continuing legal obligation. For example,
courts have found continuing violations of various laws that are
governed by the general five-year statute of limitations for criminal
cases in 18 U.S.C. 3282(a), which requires initiation of an action
``within five years . . . after
. . . [the] offense shall have been committed.'' See, e.g., United
States v. Bell, 598 F.3d 366, 368-69 (7th Cir. 2010) (continuing
violation of child support payment requirements), overruled on other
grounds, United States v. Vizcarra, 668 F.3d 516 (7th Cir. 2012);
Edelkind, 525 F.3d 388 (same); United States v. Are, 498 F.3d 460 (7th
Cir. 2007) (crime of being found in the United States after deportation
is a continuing violation).
The D.C. Circuit has suggested that suits alleging a continuing
failure to act are permissible even under the general statute of
limitations governing civil actions against the United States (28
U.S.C. 2401(a)), which provides that claims are barred unless ``filed
within six years after the right of action first accrues.'' Wilderness
Soc'y v. Norton, 434 F.3d 584 (D.C. Cir. 2006). In Wilderness Society,
the court intimated, but did not decide, that an agency's failure to
act in accordance with a statutory deadline for action was a continuing
violation, such that a lawsuit to compel agency action would not be
time-barred just because it was filed more than six years after the
agency first missed the statutory deadline. The court explained that
because the suit `` `does not complain about what the agency has done
but rather about what the agency has yet to do,' '' it likely would not
be time-barred. Id. at 589 (quoting In re United Mine Workers of
America Int'l Union, 190 F.3d 545, 549 (D.C. Cir. 1999)). See also,
e.g., Padres Hacia Una Vida Mejor v. Jackson, No. 1:11-CV-1094 AWI DLB,
2012 WL 1158753 (E.D. Cal. April 6, 2012) (28 U.S.C. 2401(a) did not
bar a claim based on EPA's ongoing failure to act on complaints of
discrimination within regulatory deadlines). And the Fifth Circuit
found continuing violations of the Bank Holding Company Act in a case
governed by the general statute of limitations in 28 U.S.C. 2462, which
requires actions to enforce civil fines, penalties, or forfeitures to
be ``commenced within five years from the date when the claim first
accrued.'' Interamericas, 111 F.3d 376. See also, e.g., Newell
Recycling Co. v. EPA, 231 F.3d 204 (5th Cir. 2000) (finding a
continuing violation of disposal requirements for polychlorinated
biphenyls under the Toxic Substances Control Act in a case involving
the general statute of limitations at 28 U.S.C. 2462); Advance Mach
Co., 547 F.Supp. at 1085 (finding a continuing violation of the
Consumer Product Safety Act in a case governed by 28 U.S.C. 2462); cf.
Capital Tel. Co v. FCC, 777 F.2d 868, 871 (2d Cir. 1985) (per curiam)
(deferring to FCC determination that company's ``actions constituted a
`continuing violation' '' despite an applicable statute of limitations
(47 U.S.C. 415(b)) requiring the filing of complaints ``within two
years from the time the cause of action accrues'').
Finally, concerns about stale claims have little bearing on OSHA
recordkeeping cases. OSHA recognizes that statutes of limitations are
designed to ``keep stale claims out of the courts.'' Havens Realty, 455
U.S. at 380. They protect parties from having to defend against stale
claims and ensure that courts are not faced with ``adjudicat[ing]
claims that because of their staleness may be impossible to resolve
with even minimum accuracy.'' Stephan v. Goldinger, 325 F.3d 874, 876
(7th Cir. 2003). Claims generally are considered stale when so much
time has passed that relevant evidence has been lost and witnesses are
no longer available or do not have reliable memories of the relevant
occurrence. Id. But ``[w]here the challenged violation is a continuing
one, the staleness concern disappears.'' Havens Realty, 455 U.S. at
380. And nothing about continuing violations in the context of OSHA
recordkeeping violations undermines this general principle.
The American Petroleum Institute cited an example of a case where
the employer's recordkeeper had passed away by the time of the hearing.
Ex. 0020. However, reliance on witness recollection is often not
necessary in recordkeeping cases because one can ordinarily ascertain
whether an injury or illness occurred, and what treatment was
necessary, by looking at medical reports, workers' compensation
documents, and other relevant records, even if the affected employee or
other witnesses are no longer available. In fact, OSHA's Recordkeeping
Policies and Procedure Manual, CPL 02-00-135 (Dec. 30, 2004), directs
compliance officers to review medical records to determine whether an
employer has failed to enter recordable injuries and illnesses on the
OSHA forms. And with respect to whether the employer recorded the
injury or illness, the only evidence the parties and the court will
need are the employer's OSHA Log and Incident Report Forms, which
existing regulations require employers to maintain for five years.
Furthermore--and contrary to the comment by the American Petroleum
Institute that staleness concerns primarily hurt employers (Ex. 0020)--
OSHA ultimately bears the burden of proving that a recordable injury or
illness occurred and the employer did not record it. Therefore, the
absence of documents and witnesses generally will be more prejudicial
to OSHA's case than to the employer's defense. See Secretary v. Home
Depot #6512, 22 BNA OSHC 1863 (Rev. Comm'n 2009) (vacating citation for
failure to report employee fatality because Secretary did not provide
sufficient evidence to establish fatality was work-related). And any
limited staleness concerns that exist are outweighed by the fact that
ongoing recordkeeping requirements are essential to fulfilling the
purposes of the OSH Act. See generally Connecticut Light & Power Co. v.
Sec'y of Labor, 85 F.3d 89, 96 (2d Cir. 1996) (``Consideration of
limitations periods requires a fair and reasonable weighing of the
conflicting concerns of the remedial intent of the [statute] . . . and
the desire to keep stale claims out of the courts.'').
Moreover, under this final rule, an employer's obligation is the
same as under the current rule: To record injuries and illnesses within
seven days and maintain the records for five years. The new rule simply
clarifies that an employer cannot avoid the five-year maintenance
requirement by failing to make the record in the initial seven days;
rather, the obligation to make the record continues throughout the
five-year maintenance period even if the employer fails to meet its
initial obligation. Therefore, employers who record injuries and
illnesses promptly, as paragraph 1904.29(b)(3) requires, will not face
staleness concerns.
3. Incomplete or Otherwise Inaccurate Records of Work-Related Illnesses
and Injuries Create an Ongoing Condition Detrimental to Full
Enforcement of the Act
OSHA records ``are a cornerstone of the Act and play a crucial role
in providing the information necessary to make workplaces safer and
healthier.'' Gen. Motors Corp., 8 BNA OSHC at 2041. As explained
previously, in SUPPLEMENTARY INFORMATION, Section I.B, employers must
give employees (as well as OSHA and BLS) access to injury and illness
records. OSHA injury and illness records are designed to be used by
employers, employees, the public health community, and the government
to learn about the injuries and illnesses that are occurring in
American workplaces. See ``Improve Tracking of Injuries and
Illnesses,'' 81 FR 29623 (May 12, 2016). Accurate OSHA injury and
illness records enable employers to identify, and correct, hazardous
conditions, allow employees to learn about the hazards they face, and
permit the government to determine where and why injuries are occurring
so that
appropriate regulatory or enforcement measures can be taken. (See
SUPPLEMENTARY INFORMATION, Section I.B, earlier in this preamble, for a
full discussion of the purposes served by OSHA injury and illness
records.) Thus, Congress viewed accurate records as necessary for the
enforcement of the Act. 29 U.S.C. 657(c). Inaccurate or incomplete
injury and illness records will leave all of the relevant parties
underinformed, and thereby create an ongoing hazardous condition
detrimental to full enforcement of the Act. The Commission has
recognized as much. See, e.g., Gen. Dynamics, 15 BNA OSHC at 2131 n. 17
(recordkeeping regulations ``clearly are safety- and health-related'');
Johnson Controls, 15 BNA OSHC at 2135-36 (``[A] failure to record an
occupational injury or illness . . . does not differ in substance from
any other condition that must be abated pursuant to . . . occupational
safety and health standards . . .'').
Nor is there any meaningful distinction to be drawn between cases
involving inadequate training or unsafe machines (which may also be
seen as involving repeated affirmative acts, for example, sending
untrained employees to work in hazardous conditions) and recordkeeping
cases (involving failures to create and maintain accurate records of
workplace illnesses and injuries). The lack of access--by employers,
employees and OSHA--to accurate records is as much an ongoing non-
complying condition under the Act as is an untrained employee or an
unguarded machine. Whether the condition was created by an act of
omission or of commission, the condition is one that continues to
violate the Act until it is abated.
Moreover, under the system Congress established in the OSH Act, any
distinction that can be drawn between action and inaction lacks legal
significance. As the Commission recognizes, ``unlike other federal
statutes in which an overt act is needed to show any violation, the OSH
Act penalizes both overt acts and failures to act in the face of an
ongoing, affirmative duty to perform prescribed obligations.'' Volks I,
23 BNA OSHC at 1417 n.3 (emphasis in original). See also, e.g., Gen.
Dynamics, 15 BNA OSHC at 2130 (``[T]he Act penalizes the occurrence of
noncomplying conditions which are accessible to employees and of which
the employer knew or reasonably could have known. That is the only
`act' that the Secretary must show to prove a violation.''). That is
why it is still a citable violation if an employer has left a hazardous
machine unguarded for years--even though the employer has not done
anything to the machine since first removing the guard. That is why it
is a violation if an employer fails to label containers of hazardous
chemicals or have safety data sheets on hand, regardless of how long
the inaction persists or when it first occurred. And courts regularly
find that a failure to act in accordance with an ongoing legal
obligation constitutes a continuing violation. Such cases have included
a lender's failure to make required disclosures to a borrower (Postow,
627 F.2d 1370), a sex offender's failure to register with authorities
(George, 625 F.3d 1124), a parent's failure to pay child support
(Edelkind, 525 F.3d 388), an agency's failure to comply with statutory
mandates and deadlines (Wilderness Soc'y, 434 F.3d 584), a company's
failure to create and maintain water sampling records (Sierra Club, 847
F.2d 1109), and a failure on the part of the government to act on
complaints of discrimination (Padres Hacia Una Vida Mejor, 2012 WL
1158753).
Incomplete and inaccurate OSHA records therefore result in an
ongoing non-complying condition--namely employers, employees, and the
government being denied access to information necessary to full
enforcement of the Act. This non-complying condition continues every
day that the records are inaccurate.\6\
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\6\ For this reason, Gabelli v. SEC, 133 S.Ct. 1316 (2013),
cited by Nabors Drilling USA and the National Association of
Manufacturers, is inapposite. Exs. 0010, 0026. Gabelli deals with
the discovery rule, which pertains to whether a claim's accrual date
should be extended until the plaintiff learns of the unlawful
conduct. The discovery rule is not needed where, as here, the
unlawful conduct is ongoing. In Gabelli, which involved a civil
enforcement action under the Investment Advisers Act, the Supreme
Court held that the five-year statute of limitations in 28 U.S.C.
2462 ran from the date a fraud was complete, not from the date the
government discovered the fraud. Gabelli does not stand for the
proposition that the language in 28 U.S.C. 2462 precludes
application of a continuing violation theory. Indeed, in Gabelli the
government agreed that the alleged illegal activity ended more than
five years prior to the filing of the complaint, so there was no
issue about the duration of the violative conduct.
---------------------------------------------------------------------------
Additionally, the legislative history of the Act reflects Congress'
concern about harm resulting to employees in workplaces with incomplete
records of occupational injuries and illnesses. Most notably, a report
of the Senate Committee on Labor and Public welfare stated that
``[f]ull and accurate information is a fundamental precondition for
meaningful administration of an occupational safety and health
program.'' S. Rep. No. 91-1282, at 16 (1970), reprinted in Subcomm. on
Labor of the Comm. on Labor and Public Welfare, Legislative History of
the Occupational Safety and Health Act of 1970, at 156 (1971) (emphasis
added). Additionally, a report from the House of Representatives shows
that Congress recognized ``comprehensive [injury and illness]
reporting'' as playing a key role in ``effective safety programs.''
H.R. Rep. No. 91-1291, at 15 (1970), reprinted in Subcomm. on Labor of
the Comm. on Labor and Public Welfare, Legislative History of the
Occupational Safety and Health Act of 1970, at 845 (1971).
Some commenters, including Nabors Drilling USA and the North
American Insulation Manufacturers' Association, expressed the opinion
that this rule will do nothing to improve safety and health. Exs. 0010,
0016, 0017, 0019, 0026. For the reasons already stated, OSHA disagrees,
and evidence submitted by other commenters supports OSHA's conclusion.
For example, North America's Building Trades Unions commented that
records of workplace injuries and illnesses are valuable to help
identify hazards and correct problems in the workplace, both
immediately and over time, and that this information is of particular
value in the construction industry where workers change jobsites often.
Ex. 0025. The United Steelworkers (USW) provided an example of a
company safety committee noticing that the employer was not accurately
recording hand lacerations caused by certain equipment; later, an
employee using the same equipment suffered an amputation. Ex. 0028.
Properly maintained records could have helped alert the employer to the
hazardous machine before the amputation occurred. The USW also provided
several examples of workplace hazards that emerge as trends over time,
including occupational hearing loss, exposure to hazardous chemicals,
and musculoskeletal disorders. Injury and illness records are an
important tool in the identification of these types of hazards. Ex.
0028.
Additionally, as noted by commenter ORCHSE Strategies, LLC,
although most employers are diligent about recording injuries and
illnesses as required, some are not.\7\ Ex. 0015. OSHA's ability to
enforce the recordkeeping regulations is an important tool to ensure
that accurate information about workplace safety is
available and that conscientious employers are not placed at a
disadvantage by employers who intentionally underreport and thus appear
safer than they actually are. Ex. 0015; see Ex. 0024. Although OSHA's
recordkeeping rules have always required employers to maintain records
for five years, they did not previously expressly state that an
employer cannot skirt this requirement by ignoring its obligation to
record an injury or illness when first learning of it. This final rule
clarifies the recordkeeping requirements and enables OSHA to ensure
that employers make and keep an accurate, five-year record of workplace
injuries and illnesses. Indeed, without this clarification, as the AFL-
CIO noted, the rule would not achieve Congress' intent that the
Secretary collect accurate data about workplace safety. Ex. 0024.
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\7\ The USW suggested that OSHA incorporate into this rule a
prohibition on employer practices that discourage reporting of
injuries and illnesses. Ex. 0028. Such a prohibition would be beyond
the scope of this rulemaking, which is limited to clarifying
existing obligations. However, such practices are addressed in
OSHA's recent rulemaking, ``Improve Tracking of Injuries and
Illnesses,'' 81 FR 29623 (May 12, 2016).
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4. OSHA Is Acting Within Its Regulatory Authority, and Consistently
With the General Case Law, in Issuing This Clarifying Rule
Several commenters expressed the view that the Volks II majority
opinion prohibits the Secretary from imposing a continuing obligation
on employers to record, and maintain records of, injuries and
illnesses, with a few commenters stating that OSHA is improperly
attempting to ``overturn'' the Volks II decision. Exs. 0003, 0008,
0009, 0010, 0011, 0012, 0013, 0014, 0016, 0017, 0020, 0021, 0023, 0026.
OSHA disagrees. For the reasons described below, OSHA does not believe
it is improper to respond to the Volks II decision by clarifying the
regulations before there is any additional litigation over OSHA's
statutory authority to establish continuing recordkeeping obligations.
Given that OSHA agrees with Judge Garland that the regulations as
previously written did not clearly convey the intended continuing
obligation, it would have been fruitless for OSHA to seek further
appellate review of the Volks II decision, as some commenters
suggested. See Exs. 0017, 0020, 0021. The executive branch of the
federal government may elect not to appeal an adverse decision from the
judiciary for a number of reasons unrelated to its views about the
merits of the ruling, and, as the Supreme Court recognizes, the
government's decision to forgo appeal in a particular case should not
foreclose future review of relevant issues in other appropriate
judicial forums. See United States v. Mendoza, 464 U.S. 154, 160-61
(1984) (declining to apply non-mutual collateral estoppel against the
federal government in part because doing so ``would force the . . .
[government] to abandon prudential concerns and to appeal every adverse
decision in order to avoid foreclosing further review''). Thus, OSHA
has acted reasonably in deciding to clarify its regulations before
there is any additional litigation over the issues of statutory
interpretation addressed in Volks II.
OSHA acknowledges that this clarification of its recordkeeping
regulations to address the textual deficiencies identified by Judge
Garland leaves unsettled the issue of OSHA's statutory authority to
regulate in this manner. (Two of three judges on the Volks II panel
found that the OSH Act did not permit OSHA to issue continuing
recordkeeping regulations; however, Judge Garland disagreed with the
majority's holding on this point.) When OSHA implements this rule, that
issue will likely be the subject of future litigation in various
federal courts, and potentially in the Supreme Court. Courts generally
recognize the value of allowing the law to develop through litigation
in multiple forums. See, e.g., Mendoza, 464 U.S. at 160 (noting
``benefit . . . from permitting several courts of appeals to explore a
difficult question before this Court grants certiorari''); Califano v.
Yamasaki, 442 U.S. 682, 702 (1979) (``It often will be preferable to
allow several courts to pass on a given class claim in order to gain
the benefit of adjudication by different courts in different factual
contexts.''). See also Holland v. Nat'l Mining Ass'n, 309 F.3d 909, 815
(D.C. Cir. 2002) (``Allowing one circuit's statutory interpretation to
foreclose . . . review of the question in another circuit would squelch
the circuit disagreements that can lead to Supreme Court review.'').
OSHA has issued rules with a similar clarifying purpose following
adverse court decisions before. For example, after the Fifth Circuit
held that OSHA's respirator standard and the training provisions in the
asbestos standard did not permit citing an employer for each individual
employee who was not provided the required respirator or training, OSHA
issued a final rule ``to make it unmistakably clear that each covered
employee is required to receive PPE and training, and that each
instance when an employee subject to a PPE or training requirement does
not receive the required PPE or training may be considered a separate
violation subject to a separate penalty.'' 73 FR 75568-01, 75569 (Dec.
12, 2008); see Chao v. OSHRC and Erik K. Ho, 401 F.3d 355 (5th Cir.
2005). See also 72 FR 64342-01, 64342-43 (Nov. 15, 2007) (final rule
clarifying employers' responsibility to pay for PPE, issued in response
to Commission decision vacating citation for employer's failure to
pay).\8\
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\8\ Nor is it uncommon for federal agencies to engage in
nonacquiescence when faced with what they believe are erroneous
court decisions. See, e.g., Samuel Estreicher & Richard L. Revesz,
Nonacquiescence by Federal Administrative Agencies, 98 Yale L.J. 679
(1989).
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OSHA also disagrees with the commenters, including the Coalition
for Workplace Safety and the National Association of Home Builders, who
suggested that a Supreme Court case, National Cable and
Telecommunications Association v. Brand X Internet Services, 545 U.S.
967 (2005) (``Brand X''), precludes the Secretary from promulgating
this final rule. Exs. 0011, 0013, 0017, 0020. In holding that the Ninth
Circuit should have deferred to the FCC's interpretation of a statutory
term instead of following the contrary interpretation the court had
adopted in an earlier case, Brand X stated that ``[a] court's prior
judicial construction of a statute trumps an agency construction
otherwise entitled to Chevron deference only if the prior court
decision holds that its construction follows from the unambiguous terms
of the statute and thus leaves no room for agency discretion.'' 545
U.S. at 982 (emphasis added). Brand X does not control here, however,
because Volks II did not clearly hold that the OSH Act unambiguously
forecloses continuing recordkeeping violations. Indeed, the court
expressly acknowledged that the loss or destruction of a record
previously made constitutes a continuing violation of the requirement
to retain records for five years. 675 F.3d at 756; see id. at 763
(concurring opinion). Moreover, although parts of the majority opinion
suggest that the ``clear'' language in the OSH Act's statute of
limitations precludes continuing record-making violations (because the
majority said that the word ``occurrence'' requires a discrete action
to have taken place within the six-month limitations period, 675 F.3d
at 755-56), the court nevertheless acknowledged ambiguity in the
meaning of ``occurrence'' when it agreed that training and machine
guarding violations can continue, not because a discrete action occurs
within the six-month window, but because ``the dangers created by
th[ose] violations persist.'' Id. at 758.\9\ Notably, nothing in
the OSH Act's statute of limitations distinguishes between standards
(such as machine guarding requirements) and regulations (such as
recordkeeping requirements). Finally, the fact that Judge Garland
disagreed with the majority about what the statute says lends further
support to OSHA's view that Volks II should not be read as holding that
the OSH Act unambiguously forecloses this regulatory action.
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\9\ The Coalition for Workplace Safety also stated that the
cases Local Lodge No. 1424 (Bryan Mfg.) v. NLRB, 362 U.S. 411 (1960)
and Ledbetter v. Goodyear, 550 U.S. 618 (2007) prohibit this final
rule. Ex. 0013. However, these cases do not control this rule
because they involve causes of action that the Court found to accrue
at one discrete moment in time--the illegal execution of a
collective bargaining agreement and a particular instance of sex
discrimination, respectively. In contrast, a failure to maintain an
accurate record of workplace injuries and illnesses is a continuing
violation that reoccurs each day it persists.
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As touched upon previously in this preamble, OSHA further believes
that general case law on continuing violations clearly supports a
continuing violation theory for OSHA recordkeeping violations. The
Volks II majority stated that recordkeeping violations are not ``the
sort of conduct we generally view as giving rise to a continuing
violation[,]'' i.e., the kind of violation ``whose `character as a
violation . . . [does] not become clear until . . . repeated during the
limitations period . . . because it is . . . [the] cumulative impact .
. . that reveals . . . illegality.' '' Volks II, 675 F.3d at 757
(quoting Taylor v. FDIC, 132 F.3d 753, 765 (D.C. Cir. 1997)). While the
``cumulative impact'' theory is one way to establish a continuing
violation (see, e.g., Morgan, 536 U.S. 101 (hostile environment claims
under Title VII)), established precedent recognizes a second type of
continuing violation--a violation that continues to occur on a day-by-
day (or act-by-act) basis and whose illegality was clear from the
beginning. See, e.g., Edelkind, 525 F.3d 388 (failure to pay child
support is a continuing offense); Sierra Club, 847 F.2d 1109 (finding
continuing violations of the Clean Water Act where the company failed
to comply with permit requirements for reporting and record retention);
Postow, 627 F.2d 1370 (violation of Truth-in-Lending Act's disclosure
requirements is a continuing violation). This is the type of continuing
violation relevant here because all OSHA violations--including
recordkeeping violations--``continue'' only insofar as non-compliant
conditions exist.
The D.C. Circuit explicitly recognized the existence of these two
types of continuing violation cases in Earle, 707 F.3d 299, 1307--a
post-Volks II case that made no reference to the Volks II majority
opinion, but cited, with approval, Judge Garland's concurring
opinion.\10\ In Earle, the court, quoting Judge Garland, explained that
where a statute `` `imposes a continuing obligation to act, a party can
continue to violate it until that obligation is satisfied and the
statute of limitations will not begin to run until it does.' '' Id. at
307. And ``[w]hether the obligation is continuing is a question of
statutory construction.'' Earle, 707 F.3d at 307. The court explained
that Postow had found a continuing violation of the Truth-in-Lending
Act because the ``goals of the Act'' required construing the obligation
to be continuing. Id. So too, the goals of the OSH Act require
construing the recordkeeping obligation to be continuing. The purpose
of recording injuries is to allow the recorded information to be used
thereafter, throughout the retention and access period. Accurate and
complete OSHA records enable employers, employees, and the government
to understand the hazards present in the workplace so that corrective
measures can be taken. Inaccurate and incomplete records, by contrast,
are likely to be misleading.
---------------------------------------------------------------------------
\10\ It is also noteworthy that Earle was written by Judge
Henderson, who was part of the Volks II majority.
---------------------------------------------------------------------------
The Secretary recognizes that one court has said that: ``The
Supreme Court has made clear . . . that the application of the
continuing violations doctrine should be the exception, rather than the
rule.'' Cherosky v. Henderson, 330 F.3d 1243, 1248 (9th Cir. 2003) (not
referring to any specific decision) (quoted in Volks II, 675 F.3d at
757). Even so, the Secretary believes that the language and purposes of
the OSH Act make it clear that the duty to maintain and make available
records is a continuing obligation for all the reasons set forth
previously.\11\
---------------------------------------------------------------------------
\11\ In Toussie v. United States, 397 U.S. 112 (1970), the
Supreme Court stated that ``the doctrine of continuing offenses
should be applied in only limited circumstances since . . . `the
tension between the purpose of a statute of limitations and the
continuing offense doctrine is apparent.' '' Id. at 115 (citations
omitted). But Toussie was a criminal case subject to the general
principle that ``criminal limitations statutes are `to be liberally
interpreted in favor of repose.' '' Id. (emphasis added and
citations omitted). See also Diamond v. United States, 427 F.2d
1246, 1247 (Ct. Cl. 1970) (per curiam) (``[T]he considerations
moving the Court to decide [in Toussie] that the offense was not a
continuing one were entwined with the criminal aspects of the
matter, and the holding was limited to criminal statutes of
limitations.''). In contrast, as noted previously, in Legal
Authority, Section II.B.2, OSHA civil enforcement cases are subject
to the opposing principle that ``statutes of limitation in the civil
context are to be strictly construed in favor of the Government
against repose.'' Interamericas, 111 F.3d at 382.
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III. Summary and Explanation of the Final Rule
OSHA is amending its recordkeeping regulations, 29 CFR part 1904,
to clarify that employers covered by the recordkeeping requirements
have a continuing obligation to make and maintain accurate records of
all recordable injuries and illnesses. This obligation continues for as
long as the employer must maintain records for the year in which an
injury or illness became recordable, and it does not expire if the
employer fails to create a record when first required to do so.
The continuing obligation to make and maintain accurate records of
work-related illnesses and injuries is in accord with longstanding OSHA
policy. Thus, this final rule does not impose new or additional
obligations on employers covered by part 1904. Employers will not be
required to make records of any injuries or illnesses for which records
are not currently required; nor are the recording requirements
themselves changing. Because the rule imposes no new burdens or
obligations and changes no law, it is simply a clarification, not a
substantive change (as a few commenters contended; see Exs. 0012, 0014,
0020). As discussed at length previously, the amendments are meant
simply to clarify employers' obligations in the wake of the Volks II
decision. The amendments consist of revisions to various sections of
the regulatory text as well as changes to the titles of some sections
and subparts. (Titles are useful for clarity but do not change the
legal meaning of the text itself. See Penn. Dept. of Corrections v.
Yeskey, 524 U.S. 206, 212 (1998); INS v. Nat'l Ctr. for Immigrants'
Rights, Inc., 502 U.S. 183, 189-90 (1991)).
As discussed in more detail later in this preamble, the amendments
clarify the following: (1) OSHA 300 Log. Employers must record every
recordable injury or illness on the Log. This obligation continues
through the five-year record retention-and-access period if employers
do not create the record when first required to do so. During that
period, employers must update the Log by adding cases not previously
recorded and by noting changes to previously recorded cases. (2) OSHA
301 Incident Report. Employers must prepare a Form 301 Incident Report
for each recordable illness or injury. This obligation continues
throughout the five-year retention-and-access period if employers do
not prepare the report when first required to do so. Unlike with the
Log, employers are not required to update the Incident Report
to show changes to the case that occur after the form is initially
prepared. (3) Year-end records review; preparation certification; and
posting of the Form 300A annual summary. These ancillary tasks are
intended to be performed at particular times during each year. They are
not continuing obligations.
Many commenters expressed concern that this rule increases
recordkeeping obligations and thus will require employers to devote
additional time and resources to recordkeeping. Exs. 0008, 0010, 0012,
0013, 0014, 0020, 0021, 0026, 0027. For example, Nabors Drilling USA
commented that the new rule will force it ``to hire one or more
individuals whose sole job will be to police our volumes of OSHA 300,
300A, and 301 logs for accuracy one-hundred percent of the time,'' and
the National Federation of Independent Businesses stated its belief
that the rule imposes on employers ``a duty of daily reconsideration''
of each ``decision to not record or to not fully record an injury.''
Exs. 0010, 0014. This concern is misplaced. An employer's obligation
remains the same as it was before: To record workplace injuries and
illnesses within seven days and to maintain the record for five years.
There is no new requirement to review or reassess existing records over
the course of the maintenance period (and, correspondingly, there are
no additional costs involved). The new rule simply makes clear that if
an employer fails to record an injury or illness within seven days, it
is not relieved of the requirement to make and keep an accurate record
of all recordable injuries and illnesses for the duration of five
years. As explained above in Section I.C, this has long been OSHA's
position. In response to the observation in Volks II that a record
cannot be maintained if it was never made, 657 F.3d at 756, the new
rule is meant to explain that the obligations to make and maintain
records go hand-in-hand. An employer cannot skirt the requirement to
maintain accurate injury and illness records by failing to make the
records in the first place.
The commenters' concern about needing to regularly reassess
recordkeeping determinations applies to only one type of recordkeeping
violation--the type in which a well-intentioned employer simply makes a
mistake and fails to record a recordable case (e.g., due to
administrative oversight or because of an erroneous belief that the
case is not recordable). The commenters' concern has no relevance to
cases in which employers simply decide not to record cases they know to
be recordable or in which employers have known, pervasive shortcomings
in their recordkeeping policies and systems. See Ex. 0019 (comment from
American Society of Safety Engineers). While inadvertent mistakes are
always a possibility with respect to any regulatory obligation--whether
discrete or continuing--OSHA generally focuses its recordkeeping
enforcement resources on systematic recording failures, not on one-time
errors made in good-faith attempts at compliance.\12\ See, e g.,
Secretary v. Pepperidge Farm, Inc., 17 BNA OSHC 1993 (Rev. Comm'n 1997)
(affirming 176 willful recordkeeping violations where employer failed
to train responsible employee on how to complete OSHA forms and failed
to record dozens of injuries of a type that affected workers at ``an
extraordinarily high rate''). And while employers are responsible for
complying with the requirement to accurately record workplace injuries
and illnesses and to maintain accurate records for five years, there is
no separate requirement for daily (or regular) reconsideration of
decisions not to record. Thus, even though OSHA may cite an employer
for failing to record a recordable case, OSHA would have no basis for
separately citing an employer for failing to reconsider prior
recordkeeping determinations.
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\12\ OSHA notes, however, that an employer may be cited for an
OSH Act violation as long as it has knowledge that the cited
condition exists, whether or not the employer also has particular
knowledge that the cited condition violates the Act. See, e.g.,
Secretary v. Shaw Constr., Inc., 6 BNA OSHC 1341 (Rev. Comm'n 1978)
(finding employer in violation of trenching standard where employer
knew trench was not sloped, even though employer was unsure which
OSHA standard applied to the trench). Recordkeeping violations are
no different from other OSH Act violations in this respect.
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A. Description of Revisions
1. Section 1904.0--Purpose
OSHA received no comments on the proposed changes to Sec. 1904.0
and has adopted the provision as proposed. OSHA has revised this
section to clarify and emphasize employers' ongoing duties to make and
maintain accurate records of each and every recordable injury and
illness under part 1904. The revised language reflects the longstanding
requirement for employers to provide their injury and illness records
to certain government representatives and to employees and former
employees and their representatives. The additions to the regulatory
text include language reiterating that recordkeeping requirements are
important in helping OSHA achieve its mission of providing safe and
healthful working conditions for the nation's workers. OSHA also added
a new sentence at the end of this section to explain that records will
be considered ``accurate'' if correct and complete records are made and
maintained for each and every recordable injury and illness in
accordance with the provisions of part 1904. This concept is not new,
as the requirement for employers to maintain accurate records is
derived directly from the OSH Act, 29 U.S.C. 657(c)(2).
2. Subpart C--Making and Maintaining Accurate Records, Recordkeeping
Forms, and Recording Criteria
OSHA proposed to amend the title of this Subpart to better reflect
the content of revised Sec. Sec. 1904.4 and 1904.29, which address
employers' duties to make and maintain accurate records, as well as
recordkeeping forms and criteria. OSHA received no comments on this
proposed change and has adopted the change as proposed.
3. Paragraph (a) of Sec. 1904.4--Basic Requirement
OSHA received no comments on the proposed changes to Sec.
1904.4(a) and has adopted the changes as proposed. OSHA has revised
this paragraph to reiterate the requirement that employers make and
maintain accurate records of every injury and illness that meets the
recording criteria in paragraphs (a)(1) through (3) of Sec. 1904.4.
The prior version of paragraph (a), which required employers to
``record'' injuries and illnesses, was less explicit in expressing
OSHA's intent that employers both create and keep accurate records. The
revised language confirms that an employer's duty includes both
creating and preserving accurate records of recordable injuries and
illnesses. To be accurate, these records must be correct and complete.
The revised language also reflects more closely the language of the OSH
Act at 29 U.S.C. 657(c)(1) and (2). OSHA did not propose to change, and
is not changing, the recording criteria in paragraphs (a)(1) through
(3) of existing Sec. 1904.4.
4. Note to Paragraph (a) of Sec. 1904.4
OSHA proposed to add a note to Sec. 1904.4(a) to clarify the
Secretary's longstanding position that the duty to make and maintain
accurate injury and illness records continues throughout the entire
record-retention period set out in Sec. 1904.33(a). This retention
period runs for five years from the end of the calendar year that the
records cover. An employer who fails to create a required record during
the seven-day grace period provided for in Sec. 1904.29(b)(3) must
still create the record so long as the retention period has not
elapsed.
Given this ongoing duty, OSHA may issue recordkeeping citations to
employers that have incomplete or otherwise inaccurate records at any
point during the retention period, and, under the six-month statute of
limitations set out in 29 U.S.C. 658(c), for up to six months
thereafter.
OSHA received a number of comments about its proposal to specify
that the recordkeeping duty is a continuing one. These comments are
addressed in Section II.B, Legal Authority, above. For the reasons
stated there, OSHA has adopted the changes as proposed.
5. Paragraph (b)(3) of Sec. 1904.29--How quickly must each injury or
illness be recorded?
OSHA proposed to revise paragraph (b)(3) of Sec. 1904.29. The
paragraph, as proposed and adopted in this final rule, states OSHA's
longstanding requirement that each and every recordable injury and
illness must be recorded on both the OSHA 300 Log for that year and a
301 Incident Report within seven calendar days of when the employer
receives information that the injury or illness occurred. OSHA is
making minor wording changes to the first sentence of paragraph (b)(3),
and the remainder of paragraph (b)(3), as proposed and adopted, is
designed to make clear that employers who fail to record as required
within seven days are not then relieved of the obligation to record.
Thus, the obligation to record continues until the five-year retention
period in Sec. 1904.33(a) has ended.
North America's Building Trades Unions suggested that OSHA's use of
the word ``deadline'' to refer to the end of the seven-day reporting
period might cause confusion about whether the obligation continues
after the ``deadline'' is missed. Ex. 0025. OSHA agrees and is removing
this word in the final rule. OSHA has always interpreted the seven-day
recording period as a grace period when an employer can gather
information on an injury or illness without fear of being cited by OSHA
for a failure to record. Similarly, OSHA has always interpreted the
obligation to record as continuing throughout the record retention
period. The amendments to this paragraph simply clarify OSHA's long-
held positions.
Other comments disagreeing with OSHA's proposal to specify that the
recordkeeping duty is a continuing one are addressed in Section II.B,
Legal Authority, above. For the reasons stated there, OSHA has adopted
the remainder of the provision as proposed.
6. Section 1904.32--Year-End Review and Annual Summary
OSHA proposed to amend the title of this section to more accurately
describe the topics covered by Sec. 1904.32, which include an
employer's year-end review of records. OSHA received no comments on
this proposed change and has adopted the change as proposed.
7. Paragraph (a) of Sec. 1904.32--Basic Requirement
OSHA received no comments on the proposed changes to Sec.
1904.32(a) and has adopted the changes as proposed. OSHA has revised
paragraph (a)(1) of Sec. 1904.32 to make clear that employers must
examine each year's OSHA 300 Log at the end of the year to ensure that
each and every recordable injury and illness is recorded on the Log,
and that each entry is accurate. If an employer discovers, during this
review, that an injury or illness is missing or that any aspect of an
entry is inaccurate, the employer must correct the deficiency.
OSHA has added a new paragraph (paragraph (a)(2)) to Sec. 1904.32.
This paragraph provides that after reviewing and verifying the Log
entries under Sec. 1904.32(a)(1), employers must verify that all
entries on the Log are accurately recorded on OSHA 301 Incident
Reports. Paragraph (a)(2) clarifies that if an employer discovers,
during the Sec. 1904.32(a)(1) review, that an injury or illness was
initially left off of the OSHA 300 Log, the employer must both add it
to the log and create an accurate Incident Report for that injury or
illness.
OSHA is moving the language from paragraph (a)(2) in Sec. 1904.32
to paragraph (a)(3) in the same section. OSHA is adding a clause to
that paragraph to explain that the annual summary should be created
only after an employer verifies the accuracy of the Log. This language
is for clarification purposes only and does not add any new compliance
requirements. OSHA is also renumbering paragraphs (a)(3) and (4) of
Sec. 1904.32 as paragraphs (a)(4) and (5), respectively. OSHA did not
propose to make, and is not making, any substantive changes to these
provisions.
The specific tasks required of employers under Sec. 1904.32(a)--to
conduct a year-end review of the Log, and to prepare, certify, and post
the annual summary--are in addition to the duties described elsewhere
in part 1904, and do not supersede or modify them. These other duties
include the fundamental continuing obligation for employers to ensure
that Logs are accurate and complete and that all recordable cases are
included on them. The specific steps required under Sec. 1904.32(a)
are supplementary tasks designed to help ensure that employers are
maintaining accurate records. These supplementary tasks are to be
performed at specified times (at the end of each calendar year, and
from February 1 to April 30 for posting). Failure to perform one of
these supplementary tasks by the required date or during the required
time period is a violation of Sec. 1904.32 that may be cited during
the following six months. See Volks II, 675 F.3d at 761-62 (concurring
opinion).
8. Paragraph (b)(1) of Sec. 1904.32--How extensively do I have to
review the OSHA 300 Log at the end of the year?
OSHA received no comments on the proposed changes to paragraph
(b)(1) of Sec. 1904.32 has adopted the changes as proposed. OSHA is
amending paragraph (b)(1) of Sec. 1904.32 to reflect the revisions to
Sec. 1904.32(a)(1). The changes to paragraph (b)(1) reiterate that
employers must review the Log and its entries sufficiently to verify
that all recordable injuries and illnesses for the relevant year are
entered, and that those entries are accurate. In addition, OSHA is
making one minor, non-substantive change to the heading of paragraph
(b)(1).
9. Section 1904.33--Retention and Maintenance of Accurate Records
OSHA proposed to update the title of this section to more
accurately reflect the obligations described in Sec. 1904.33. OSHA
received no comments on this proposed change and has adopted the change
as proposed.
10. Paragraph (b)(1) of Sec. 1904.33--Other than the obligation
identified in Sec. 1904.32, do I have further recording duties with
respect to OSHA 300 Logs and 301 Incident Reports during the five-year
retention period?
OSHA proposed to amend the heading for this paragraph to reflect
that employers have recording duties with respect to Incident Reports,
as well as OSHA 300 Logs, during the five-year retention period. OSHA
also proposed to amend the text of paragraph (b)(1) of Sec. 1904.33 to
provide an introduction to the paragraphs that follow.
OSHA proposed to add paragraphs (b)(1)(i) through (iii) to Sec.
1904.33 to provide further guidance to employers on the duties to
update Log entries and Incident Reports. Proposed paragraph (b)(1)(i)
was designed to clarify employers' duties to make and keep OSHA 300 Log
entries for each and every recordable injury and illness that occurs
during the year to which the Log relates. There must also be an
associated Incident Report for each illness and
injury recorded on the Log. As the proposed language made explicit,
these duties continue until the five-year retention period ends; thus,
an employer may be required to make an entry on the OSHA Log or fill
out an Incident Report for an illness or injury that occurred several
years ago, if the employer either just learned of the incident or
failed initially to record as required upon learning of the incident.
Proposed paragraph (b)(1)(ii) addressed changes that must be made
to OSHA Logs throughout the retention period. As emphasized throughout
this rule, employers' OSHA 300 Logs must be accurate. This means that
if an employer discovers that any aspect of a previously-recorded case
(such as the classification, description, or outcome of the case) has
changed, or that a case was recorded incorrectly at the outset, the
employer must amend the entry to reflect the new or corrected
information.
Proposed paragraph (b)(1)(iii) reiterated the requirement in
paragraph (b)(1)(i) that there must be an Incident Report for each and
every recordable injury and illness. The primary purpose of proposed
paragraph (b)(1)(iii) was to explain that employers are not required to
update or correct existing Incident Reports during the retention
period. This principle was previously stated in Sec. 1904.33(b)(3).
OSHA received a number of comments questioning its assertion that
the proposed changes to paragraph (b)(1) of Sec. 1904.33 would not
require anything new of employers. These comments are addressed below
and in Section II.B, Legal Authority, above. The proposed language was
intended not to change, but rather to state more clearly, what was
already required under the recordkeeping rules. The prior recordkeeping
rules provided that during the five-year retention period, the employer
must update the Logs to include newly discovered recordable injuries
and illnesses and to show changes that occurred in previously recorded
cases. They did not explicitly state the employer's continuing duty to
record cases it initially failed to record as required. Judge Garland's
concurring opinion in Volks II concluded that the regulation was not
worded explicitly enough to create a continuing obligation to record
all such cases, as compared with newly discovered cases. Volks II, 675
F.3d at 760-61.
At the time OSHA amended the recordkeeping rules in 2001, it was
well-established law in the Commission that employers had a continuing
duty to record these previously unrecorded injuries and illnesses on
their Logs. See Gen. Dynamics, 15 BNA OSHC 2122; Johnson Controls, 15
BNA OSHC 2132. Nothing in the 2001 rulemaking suggested that OSHA had
any intention of changing this fundamental requirement. The 2001
recordkeeping regulations required employers to promptly record cases
on the 300 Log, and, throughout the five-year retention period, to add
to the Log newly discovered cases even if they occurred some time ago.
These rules did not assume noncompliance; in other words, the rules did
not explicitly state what an employer must do if it failed to record a
case that was recordable. But by stating in the 2001 regulations that
newly discovered cases should be recorded, the Secretary did not intend
to signify that other cases the employer had learned about need not be
recorded.
The 2001 regulations also stated that employers were not required
to ``update'' Form 301 Incident Reports. In Volks II, Judge Garland
read this to mean that employers do not have to create a form at all,
once the initial seven-day recording period is over. See Volks II, 675
F.3d at 760-61 (concurring opinion). That was not the Secretary's
intention. The intent was to distinguish between the Log, which
employers must update to reflect new and changed information, and the
301 Form, which employers do not need to update. (The Secretary
explained that although updating the Log would provide useful, accurate
information, updating Incident Reports would not enhance the
information in the employer's records sufficiently to warrant the
additional burden that would be associated with such a requirement. See
66 FR at 6050, January 19, 2001.) That OSHA did not require employers
to update Incident Reports did not mean employers were not required to
create the forms in the first place. The language in the final rule
clarifies this.
For the reasons stated above and in Section II.B, Legal Authority,
OSHA has adopted the proposed revisions to Sec. 1904.33(b)(1) without
change.
11. Paragraph (b)(2) of Sec. 1904.33--Do I have to make additions or
corrections to the annual summary during the five-year retention
period?
OSHA proposed minor changes to paragraph (b)(2) of Sec. 1904.33.
These proposed changes were not substantive. The recordkeeping rules do
not require employers to update or make changes to annual summaries
during the five-year retention period. OSHA received no comments on the
proposed changes to Sec. 1904.33(b)(2) and has adopted the changes as
proposed.
12. Paragraph (b)(3) of Sec. 1904.33
OSHA proposed to delete paragraph (b)(3) from Sec. 1904.33 and
move it, in slightly modified form, to paragraph (b)(1)(iii) in Sec.
1904.33. OSHA received no comments on this proposed change to the
regulatory text and has adopted the change as proposed.
13. Section 1904.34--Change in Business Ownership
Commenter Nabors Drilling USA observed that the language in the
proposed rule might create confusion about the obligations of a new
owner regarding the accuracy of the previous owner's injury logs. Ex.
0010. To eliminate any potential confusion, OSHA is adding a sentence
at the end of Sec. 1904.34 to clarify that when a business changes
ownership, the new owner is not responsible for recording work-related
injuries and illnesses that occurred before the change in ownership.
14. Paragraph (b)(2) of Sec. 1904.35--Do I have to give my employees
and their representatives access to the OSHA injury and illness
records?
Paragraph (b)(2) of Sec. 1904.35 addresses employee access to
records created under part 1904. OSHA proposed only one minor change to
this paragraph--the addition of the word ``accurate'' to describe the
records to which employees, former employees, and their representatives
must be given access. Accurate records are described in Sec. 1904.0.
OSHA received no comments on this proposed change to the regulatory
text and has adopted the change as proposed.
15. Paragraph (b)(2)(iii) of Sec. 1904.35--If an employee or
representative asks for access to the OSHA 300 Log, when do I have to
provide it?
In paragraph (b)(2)(iii) of Sec. 1904.35, OSHA proposed to add the
term ``accurate'' to describe the OSHA 300 Logs to which employees,
former employees, and their representatives must be given access.
Accurate records are described in Sec. 1904.0. Records are required so
they can be used, and records must be accurate if they are to serve
this purpose. The duty to provide an accurate record upon request
arises when the request is made, not before, so the six-month statute
of limitations does not begin to run until the request is made.
Nabors Drilling USA asked whether the change to Sec. 1904.35
creates a private right of action by employees, former employees, and
their representatives to pursue claims over recordkeeping. Ex. 0010. It
does not. OSHA received no
other comments on the proposed change to Sec. 1904.35 and has adopted
the change as proposed.
16. Subpart E--Reporting Accurate Fatality, Injury, and Illness
Information to the Government
OSHA proposed to revise the title of Subpart E to more precisely
reflect the requirement in the Subpart that government representatives
be given access to accurate fatality, injury, and illness information.
OSHA received no comments on this proposed change and has adopted the
change as proposed.
17. Section 1904.40--Providing Accurate Records to Government
Representatives
OSHA proposed to revise the title of Sec. 1904.40 to reflect the
changes to paragraph (a) of that section. OSHA received no comments on
this proposed change and has adopted the change as proposed.
18. Paragraph (a) of Sec. 1904.40--Basic Requirement
OSHA proposed to add the term ``accurate'' to paragraph (a) of
Sec. 1904.40 to reflect OSHA's longstanding expectation that employers
provide government representatives with accurate records upon request.
OSHA also proposed some non-substantive wording changes to this
paragraph.
Nabors Drilling USA suggested that OSHA revisit the four-business-
hour timeframe in which employers must provide requested records to
government representatives. Ex. 0010. This suggestion is beyond the
scope of this rulemaking because this final rule only clarifies, and
does not change, existing obligations. OSHA received no other comments
on its proposed changes to Sec. 1904.40(a) and has adopted the changes
as proposed.
IV. State Plans
The 28 States and U.S. Territories with their own OSHA-approved
occupational safety and health plans must adopt a rule comparable to
the amendments that Federal OSHA is promulgating to 29 CFR part 1904 in
this final rule. The States and U.S. Territories with OSHA-approved
occupational safety and health plans covering private employers and
State and local government employees are: Alaska, Arizona, California,
Hawaii, Indiana, Iowa, Kentucky, Maryland, Michigan, Minnesota, Nevada,
New Mexico, North Carolina, Oregon, Puerto Rico, South Carolina,
Tennessee, Utah, Vermont, Virginia, Washington, and Wyoming. In
addition, six States and U.S. Territories have OSHA-approved State
plans that apply to State and local government employees only:
Connecticut, Illinois, Maine, New Jersey, New York, and the Virgin
Islands.
Under 29 CFR 1952.4(a), States with approved occupational safety
and health plans under section 18 of the OSH Act (29 U.S.C. 667) must
adopt recordkeeping and reporting regulations that are ``substantially
identical'' to those set forth in 29 CFR part 1904. State plans'
recording and reporting requirements for determining which injuries and
illnesses must be recorded, and how they will be recorded, must be the
same as the Federal requirements. 29 CFR 1952.4(a). State plans may
promulgate injury or illness recording and reporting requirements that
are more stringent than, or supplemental to, 29 CFR part 1904, after
consulting with, and obtaining approval from, Federal OSHA. Id.
State plans may not grant variances from injury and illness
recording and reporting requirements for private sector employers; any
such variances must be granted by Federal OSHA. 29 CFR 1952.4(b). And a
State may grant such a variance for a State or local government entity
only after obtaining Federal OSHA approval. Id.
V. Final Economic Analysis
These revisions to OSHA's recordkeeping rules do not constitute an
economically significant regulatory action under Executive Order 12866.
(See 58 FR 51735, September 30, 1993). Executive Order 12866 requires
regulatory agencies to conduct an economic analysis for significant
rules. A rule is economically significant under Executive Order 12866
if it will have an annual effect on the economy of $100 million or
more. This rule does not satisfy that criterion; as explained later in
this preamble, neither the benefits nor the costs of the rule equal or
exceed $100 million. OSHA has also determined that this rule does not
meet the definition of a major rule under the Congressional Review
provisions of the Small Business Regulatory Enforcement Fairness Act
(SBREFA). See 5 U.S.C. 804(2).\13\
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\13\ Nor does this rule present a ``novel legal issue''
rendering it a significant regulatory action, as the Coalition for
Workplace Safety suggests. Ex. 0013. The commenter states that the
final rule presents such a novel legal issue because OSHA is
``us[ing] a rule to overturn a U.S. Court of Appeals decision.'' As
explained above in Legal Authority, Section II.B.4, OSHA does not
agree with this characterization of the rulemaking. This rule is
intended simply to clarify the meaning of the recordkeeping
regulations following the Volks II decision, and the decision does
not deprive OSHA of authority to promulgate this rule.
---------------------------------------------------------------------------
The Regulatory Flexibility Act of 1980, as amended by SBREFA in
1996, requires OSHA to determine whether its regulatory actions will
have a significant impact on a substantial number of small entities.
See 5 U.S.C. 601 et seq. OSHA's analysis indicates that the final rule
will not have such an impact.
This final rule simply reiterates and clarifies employers' existing
obligations to record work-related injuries and illnesses. This rule
does not require employers to make records of any injuries or illnesses
for which records were not already required. Nor does the rule impose
any new requirement that employers reconsider or reassess records once
they have been made; employers remain subject to the existing
requirement that they ensure the accuracy and completeness of their 300
Logs. OSHA estimated the costs of these requirements as part of the
final recordkeeping rule issued in January of 2001, see 66 FR 6081-
6120, January 19, 2001. The revisions contained in this final rule
impose no new cost burden because they do not require employers to do
anything new.
A number of commenters stated their belief that the final rule will
impose additional costs because it requires employers to reassess, or
``think about,'' each record of a workplace injury or illness
repeatedly over the course of five full years. Exs. 0008, 0010, 0012,
0013, 0020, 0021, 0026, 0027. The National Federation of Independent
Businesses estimated, ``conservatively,'' that this rule will cost the
economy $1,933,710,222 over five years, assuming each employer has one
``unrecorded or partially-recorded injury.'' \14\ Ex. 0014. This
concern is misplaced. An employer's obligations remain the same as they
have always been under the recordkeeping rules: To record workplace
injuries and illnesses within seven days of when it learns of them and
to maintain the records for five years. The final rule does not contain
any new requirement to review or reassess existing records over the
course of the maintenance period (see Section III, SUMMARY AND
EXPLANATION, above); it simply
makes clear that if an employer fails to record an injury or illness
within seven days of learning about it, it is not relieved of the
requirement to have and keep an accurate record of all recordable
injuries and illnesses for the duration of five years. Because the
final rule imposes no new requirement for review of records, there are
no additional costs involved for the time it would take to conduct such
review. Moreover, there is no evidence in the record that employers
have ever incurred meaningful costs (let alone costs on the level of
those described by the National Federation of Independent Businesses)
for regularly reassessing or ``thinking about'' their records--either
in the many years before the Volks II decision when OSHA was enforcing
recordkeeping requirements in a manner consistent with the
clarification contained in this final rule, or after the decision, when
it is undisputed that the Secretary may cite an employer for a failure-
to-record at any time within the six-month period following a
violation. Therefore, there is no reason to think employers will incur
such costs now.
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\14\ To arrive at this number, the commenter assumed that
``daily reconsideration'' would take one minute per day per
unrecorded or partially recorded injury or illness, and then
multiplied one minute per day by 365 days per year by five years
(minus seven days for the regulatory grace period) by an estimated
1,365,985 covered businesses by $46.72 per hour. Ex. 0014. In
addition to assuming a requirement for daily reconsideration that
the rule does not impose, this calculation does not account for the
fact that concerns about reassessment will apply to only a subset of
all recordkeeping cases. See discussion in Section III, SUMMARY AND
EXPLANATION, above.
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Even if these revisions to OSHA's recordkeeping rules would result
in some costs beyond those OSHA estimated in 2001, any such costs would
be nominal. According to OSHA's 2016 request to the Office of
Management and Budget for an extension of the approval of the
information collection requirements in the recordkeeping rules, an
estimated 1.99 million injuries and illnesses must be recorded on OSHA
logs each year. See http://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=201604-1218-002.\15\ Although OSHA accounted for the
costs associated with full recordkeeping compliance as part of the 2001
rulemaking, and finds that this rulemaking will impose no additional
costs on employers, OSHA will assume, for the sake of this analysis,
that this rule will lead to the recording of a small number of
recordable cases (one percent of all recordable cases) that would not
have been recorded previously. In other words, OSHA will calculate the
costs that would be imposed even if an additional 19,900 injuries and
illnesses will be recorded as a result of the final rule. (OSHA took
the same approach in its preliminary economic analysis, although there
OSHA referred to this as an assumption involving a one-percent rate of
noncompliance. OSHA believes the terminology it used in the proposal
led to some confusion, so it has clarified its approach for purposes of
this final rule.) \16\ OSHA also will examine a sensitivity analysis of
the results assuming that this rule will lead to the recording of an
even larger number of cases (5 percent of recordable injuries and
illnesses).
---------------------------------------------------------------------------
\15\ The National Association of Manufacturers objected that BLS
estimates of recordable injuries are larger than OSHA's estimate of
the total injuries that must be recorded. Ex. 0026. This is correct,
but not all employers are required to record their injuries. See 29
CFR 1904.1, 2 (describing exemptions for employers with 10 or fewer
employees and those in certain industries). OSHA only uses BLS
recordable injury estimates for those industries required to record
injuries.
\16\ Nabors Drilling USA commented that if OSHA is correct that
99% of employers already fully comply with the recordkeeping
requirements, this final rule serves no purpose. Ex. 0010. As
explained above, however, OSHA is not suggesting that 99% of
employers are in full compliance with OSHA recordkeeping
requirements. In any event, unlike most OSHA rulemakings, this final
rule is not intended to change employers' behavior, but rather is
designed to clarify OSHA's requirements. Thus, the current rate of
recordkeeping compliance is unrelated to the need for this final
rule.
---------------------------------------------------------------------------
The National Association of Manufacturers questioned OSHA's
preliminary economic analysis, suggesting that OSHA's one-percent and
five-percent assumptions were too low. Ex. 0026. OSHA believes,
however, that the true costs associated with this final rule are zero,
and is using the one-percent and five-percent assumptions simply to
demonstrate that even if this rule leads to the recording of some
additional injuries and illnesses, any costs incurred by employers as a
result will be minimal.
In 2014, OSHA prepared a Final Economic Analysis for a final rule
addressing the industries entitled to a partial exemption from
recordkeeping requirements and the reporting of injuries and fatalities
to OSHA. In that analysis, OSHA estimated that it takes .38 of an hour
to record an injury or illness on all required OSHA forms, taking into
account requirements for providing access to records. See 79 FR 56130,
56165 (September 18, 2014). And according to the 2016 Information
Collection Request (ICR), the average hourly rate for an Occupational
Health and Safety Specialist (Standard Occupational Classification code
29-9011) is estimated to be $48.78 (which includes a 43% addition for
benefits). See http://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=201604-1218-002. This means that the total estimated
cost of preparing OSHA records is $18.54 per injury or illness. The
American Society of Safety Engineers and the National Association of
Manufacturers questioned these estimates of time and cost as too low.
Exs. 0019, 0026. OSHA stands by these estimates, however, as they have
been developed carefully through multiple notice and comment
rulemakings and Paperwork Reduction Act notices. Those who believe OSHA
underestimated these values are failing to recognize that not all costs
of investigating an accident are attributable to OSHA's recordkeeping
requirements. Much of the same information has to be collected for
workers' compensation purposes. To avoid overlapping paperwork, OSHA
allows, and many employers take advantage of, the option to use
equivalent workers' compensation forms in place of OSHA's recordkeeping
forms. See 29 CFR 1904.29(a), (b)(4).
Thus, if 19,900 cases will be recorded as a result of the final
rule, the total cost associated with this regulatory action will be
19,900 times $18.54, or approximately $368,946 per year. And if OSHA
makes the even more conservative assumption that 5 percent of 1.99
million injuries and illnesses (99,500) would be recorded as a result
of the final rule, the total estimated cost of the rule, across all
affected employers, would be under $1.85 million per year. Even this
hypothetical cost would only exist if employers are not currently
complying fully with the existing rule, but increase their compliance
as a result of this clarification.
Just as there are no (or minimal) new costs associated with this
rule, the rule will result in no new economic benefits. OSHA believes
the revisions to the recordkeeping rules are technologically feasible
because they do not require employers to perform any actions that they
were not already performing under existing requirements. And because
the rule does not impose any significant new compliance costs, OSHA
deems it economically feasible.
VI. Regulatory Flexibility Certification
In accordance with the Regulatory Flexibility Act, 5 U.S.C. 601 et
seq. (as amended), OSHA examined the regulatory requirements of the
final rule to determine if they would have a significant economic
impact on a substantial number of small entities. As indicated in
Section V, Final Economic Analysis, earlier in this preamble, the rule
is expected to have no effect, or at most a nominal effect, on
compliance costs and regulatory burden for employers, whether large or
small. Accordingly, OSHA certifies that the rule will not have a
significant economic impact on a substantial number of small entities.
VII. Environmental Impact Assessment
OSHA has reviewed the final rule in accordance with the
requirements of the National Environmental Policy Act
(NEPA) (42 U.S.C. 4321 et seq.), the regulations of the Council on
Environmental Quality (40 CFR parts 1500 through 1508), and the
Department of Labor's NEPA procedures (29 CFR part 11). OSHA finds that
the revisions included in the rule will have no major negative impact
on air, water, or soil quality, plant or animal life, the use of land
or other aspects of the environment. And recordkeeping and reporting
requirements normally qualify for categorical exclusion from NEPA
requirements in any event. See 29 CFR 11.10(a).
VIII. Federalism
OSHA reviewed this final rule in accordance with the most recent
Executive Order on Federalism (Executive Order 13132, 64 FR 43255,
August 10, 1999). This Executive Order requires that Federal agencies,
to the extent possible, refrain from limiting State policy options,
consult with States prior to taking any actions that would restrict
State policy options, and take such actions only when clear
constitutional authority exists and the problem is national in scope.
Executive Order 13132 provides for preemption of State law only with
the expressed consent of Congress. Any such preemption must be limited
to the extent possible. Because this rulemaking action involves a
regulation that is not an occupational safety and health standard under
section 6 of the OSH Act, it does not preempt State law. See 29 U.S.C.
667(a). The effect of a final rule on states and territories with OSHA-
approved occupational safety and health plans is discussed previously
in Section IV, State Plans.
IX. Unfunded Mandates
OSHA cannot enforce compliance with its regulations or standards on
``any State or political subdivision of a State.'' 29 U.S.C. 652(5).
Under voluntary agreement with OSHA, some States enforce compliance
with their State standards on public sector entities, and these
agreements specify that these State standards must be equivalent to
OSHA standards. But the final rule does not involve any unfunded
mandates being imposed on any State or local government entity.
Moreover, as discussed previously, OSHA estimates that there are no, or
minimal, compliance costs associated with the rule. Therefore, this
rule will not impose a Federal mandate on the private sector in excess
of $100 million in expenditures in any one year. Thus, OSHA certifies
that this final rule is not a significant regulatory action within the
meaning of Section 202 of the Unfunded Mandates Reform Act (2 U.S.C.
1532).
X. Consultation and Coordination With Indian Tribal Governments
OSHA reviewed this rule in accordance with Executive Order 13175
(65 FR 67249, November 6, 2000) and determined that it does not have
``tribal implications'' as defined in that order. The rule does not
have substantial direct effects on one or more Indian tribes, on the
relationship between the Federal government and Indian tribes, or on
the distribution of power and responsibilities between the Federal
government and Indian tribes.
XI. Office of Management and Budget Review Under the Paperwork
Reduction Act of 1995
The Paperwork Reduction Act of 1995 (PRA) (44 U.S.C. 3501 et seq.)
and OMB regulations (5 CFR part 1320) require agencies to obtain
approval from OMB before conducting any collection of information. The
PRA defines a ``collection of information'' as ``the obtaining, causing
to be obtained, soliciting, or requiring the disclosure to third
parties or the public of facts or opinions by or for an agency
regardless of form or format'' (44 U.S.C. 3502(3)(A)).
OSHA's existing recordkeeping forms consist of the OSHA 300 Log,
the 300A Summary, and the 301 Incident Report. These forms are
contained in the Information Collection Request (ICR) titled 29 CFR
part 1904, Recording and Reporting Occupational Injuries and Illnesses,
which OMB approved under OMB Control Number 1218-0176 (expiration date
01/31/2018).
In accordance with the PRA, OSHA solicited public comments on the
July 29, 2015 proposed rule. The proposed rule also invited the public
to submit comments to OMB and OSHA on the proposed collections of
information with regard to the following:
Whether the proposed collections of information are
necessary for the proper performance of the Agency's functions,
including whether the information is useful;
The accuracy of OSHA's estimate of the burden (time and
cost) of the collections of information, including the validity of the
methodology and assumptions used;
The quality, utility, and clarity of the information
collected; and
Ways to minimize the compliance burden on employers, for
example, by using automated or other technological techniques for
collecting and transmitting information.
Because the proposal simply reiterated and clarified employers'
existing obligations to record and maintain work-related injuries and
illnesses and did not add any new collection of information, the Agency
maintained the existing burden hour and cost estimates in the Recording
and Reporting Occupational Injuries and Illnesses Information
Collection Request. The Department also submitted this ICR to OMB for
review in accordance with 44 U.S.C. 3507(d) on July 29, 2015. On
October 7, 2015, OMB withheld approval of the revised ICR and issued a
Notice of Action (NOA) stating that prior to publication of the final
rule, the agency should provide a summary of any comments related to
the information collection and their response, including any changes
made to the ICR as a result of comments. In addition, the agency must
enter the correct burden estimates (see http://www.reginfo.gov/public/do/DownloadNOA?requestID=266192).
The final rule adds no new compliance obligations. The rule simply
reiterates and clarifies employers' existing obligations to record
work-related injuries and illnesses; it does not require employers to
make records of any injuries or illnesses for which records were not
already required. Nor does the rule impose any new requirement that
employers reconsider or reassess records once they have been made;
employers remain subject to the existing requirement that they ensure
the accuracy and completeness of their 300 Logs. These revisions impose
no new cost burden because they do not require employers to do anything
new. The Department of Labor has submitted a final ICR to OMB
maintaining the existing burden hours and cost estimates. A copy of
this ICR is available at http://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=201610-1218-003. OSHA will publish a separate notice
in the Federal Register that will announce OMB results of that review.
OSHA notes that a Federal agency cannot conduct or sponsor a collection
of information unless it is approved by OMB under the PRA, and the
collection of information notice displays a currently valid OMB control
number (44 U.S.C. 3507(a)(3)). Also, notwithstanding any other
provision of law, no employer shall be subject to penalty for failing
to comply with a collection of information if the collection of
information does not display a currently valid OMB control number (44
U.S.C. 3512).
OSHA received comments relating to the estimated time necessary to
meet the paperwork requirements of the proposed changes published in
the July
29, 2015 proposed rule. A number of commenters stated their belief that
the rule will impose additional costs because it requires employers to
reassess, or ``think about,'' each record of a workplace injury or
illness repeatedly over the course of five full years. Ex. 0008, 0010,
0012, 0013, 0020, 0021, 0026, 0027. This concern is misplaced. An
employer's obligations remain the same as they are under the existing
rule: To record workplace injuries and illnesses within seven days of
when it learns of them and to maintain accurate records for five years.
The final rule does not contain any new requirement to review or
reassess existing records over the course of the maintenance period; it
simply makes clear that if an employer fails to record an injury or
illness within seven days of learning about it, it is not relieved of
the requirement to have and keep an accurate record of all recordable
injuries and illnesses for the duration of five years. Because the
final rule imposes no new requirement for review of records, there are
no additional costs involved for the time it would take to conduct such
review.
OSHA estimates that it takes .38 of an hour to record an injury or
illness on all required OSHA forms, taking into account requirements
for providing access to records. The average hourly rate for an
Occupational Health and Safety Specialist (Standard Occupational
Classification code 29-9011) is estimated to be $48.78 (which includes
a 43% addition for benefits). This means that the total estimated cost
of preparing OSHA records is $18.54 per injury or illness. The American
Society of Safety Engineers and the National Association of
Manufacturers questioned these estimates of time and cost as too low.
Exs. 0019, 0026. OSHA stands by these estimates, however, as they have
been developed carefully through multiple notice and comment
rulemakings and Paperwork Reduction Act notices. Not all costs of
investigating an accident are attributable to OSHA's recordkeeping
requirements. Much of the same information has to be collected for
workers' compensation purposes. To avoid overlapping paperwork, OSHA
allows, and many employers take advantage of, the option to use
equivalent workers' compensation forms in place of OSHA's recordkeeping
forms. See 29 CFR 1904.29(a), (b)(4).
As required by 5 CFR 1320.5(a)(1)(iv) and 1320.8(d)(2), the
following paragraphs provide information about this ICR.
1. Title: 29 CFR part 1904 Recording and Reporting Occupational
Injuries and Illnesses.
2. Number of respondents: Approximately 640,000 employers with
1,300,000 establishments are regularly required to maintain the forms.
3. Frequency of responses: Annually.
4. Number of responses: Approximately 1.99 million injury and
illness cases are recorded on the OSHA forms.
5. Average time per response: Time required completing and
maintaining an entry (other than a needlestick) on the OSHA Form 300
ranges from 5 minutes to 30 minutes and averages 14 minutes. Time
required completing an entry on the OSHA 301 averages 22 minutes. OSHA
estimates 40% of recordable cases are recorded on form 301.
6. Estimated total burden hours: The final rule adds no new
compliance obligations and does not require employers to make records
of any injuries or illnesses for which records are not currently
required to be made. The current total burden hours for the
recordkeeping (part 1904) ICR are 2,525,458.
7. Estimated costs (capital-operation and maintenance): There are
no capital costs for the proposed information collection.
List of Subjects in 29 CFR Part 1904
Health statistics, Occupational safety and health, Safety,
Reporting and recordkeeping requirements, State plans.
Authority and Signature
This document was prepared under the direction of David Michaels,
Ph.D., MPH, Assistant Secretary of Labor for Occupational Safety and
Health, U.S. Department of Labor. It is issued pursuant to 29 U.S.C.
657, 673; 5 U.S.C. 553; and Secretary of Labor's Order No. 1-2012 (77
FR 3912, January 25, 2012).
David Michaels,
Assistant Secretary of Labor for Occupational Safety and Health.
Accordingly, the Occupational Safety and Health Administration
amends part 1904 of title 29 of the Code of Federal Regulations as
follows:
PART 1904--RECORDING AND REPORTING OCCUPATIONAL INJURIES AND
ILLNESSES
0
1. Revise the authority citation for part 1904 to read as follows:
Authority: 29 U.S.C. 657, 658, 660, 666, 669, 673, Secretary of
Labor's Order No. 3-2000 (65 FR 50017), or 1-2012 (77 FR 3912), and
5 U.S.C. 553.
0
2. Revise Sec. 1904.0 to read as follows:
Sec. 1904.0 Purpose.
The purpose of this rule (part 1904) is to require employers to
make and maintain accurate records of and report work-related
fatalities, injuries, and illnesses, and to make such records available
to the Government and to employees and their representatives so that
they can be used to secure safe and healthful working conditions. For
purposes of this part, accurate records are records of each and every
recordable injury and illness that are made and maintained in
accordance with the requirements of this part.
Note to Sec. 1904.0: Recording or reporting a work-related
injury, illness, or fatality does not mean that the employer or
employee was at fault, that an OSHA rule has been violated, or that
the employee is eligible for workers' compensation or other
benefits.
Subpart C--Making and Maintaining Accurate Records, Recordkeeping
Forms, and Recording Criteria
0
3. Revise the heading of subpart C to read as set forth above.
0
4. In Sec. 1904.4, revise paragraph (a) introductory text and add a
note to Sec. 1904.4(a) to read as follows:
Sec. 1904.4 Recording criteria.
(a) Basic requirement. Each employer required by this part to keep
records of fatalities, injuries, and illnesses must, in accordance with
the requirements of this part, make and maintain an accurate record of
each and every fatality, injury, and illness that:
* * * * *
Note to Sec. 1904.4(a): This obligation to make and maintain an
accurate record of each and every recordable fatality, injury, and
illness continues throughout the entire record retention period
described in Sec. 1904.33.
* * * * *
0
5. Revise Sec. 1904.29(b)(3) to read as follows:
Sec. 1904.29 Forms.
* * * * *
(b) * * *
(3) How quickly must each injury or illness be recorded? You must
enter each and every recordable injury or illness on the OSHA 300 Log
and on a 301 Incident Report within seven (7) calendar days of
receiving information that the recordable injury or illness occurred. A
failure to record within seven days does not extinguish your continuing
obligation to make a record of the injury or illness and to maintain
accurate records of all recordable injuries and illnesses in accordance
with the requirements of this part. This obligation continues
throughout the entire record retention period described in Sec.
1904.33. See Sec. Sec. 1904.4(a); 1904.32(a)(1); 1904.33(b)(1); and
1904.40(a).
* * * * *
0
6. Revise the heading and paragraphs (a) and (b)(1) of Sec. 1904.32 to
read as follows:
Sec. 1904.32 Year-end review and annual summary.
(a) Basic requirement. At the end of each calendar year, you must:
(1) Review that year's OSHA 300 Log to verify that it contains
accurate entries for all recordable injuries and illnesses that
occurred during the year, and make any additions or corrections
necessary to ensure its accuracy;
(2) Verify that each injury and illness recorded on the 300 Log,
including any injuries and illnesses added to the Log following your
year-end review pursuant to paragraph (a)(1) of this section, is
accurately recorded on a corresponding 301 Incident Report form;
(3) After you have verified the accuracy of the Log, create an
annual summary of injuries and illnesses recorded on the Log;
(4) Certify the summary; and
(5) Post the summary.
(b) * * *
(1) How extensively do I have to review the OSHA 300 Log at the end
of the year? You must review the Log and its entries as extensively as
necessary to verify that all recordable injuries and illnesses that
occurred during the year are entered and that the Log and its entries
are accurate.
* * * * *
0
7. Revise the heading and paragraph (b) of Sec. 1904.33 to read as
follows:
Sec. 1904.33 Retention and maintenance of accurate records.
* * * * *
(b) Implementation--(1) Other than the obligation identified in
Sec. 1904.32, do I have further recording duties with respect to the
OSHA 300 Logs and 301 Incident Reports during the five-year retention
period? You must make the following additions and corrections to the
OSHA Log and Incident Reports during the five-year retention period:
(i) The OSHA Logs must contain entries for all recordable injuries
and illnesses that occurred during the calendar year to which each Log
relates. In addition, each and every recordable injury and illness must
be recorded on an Incident Report. This means that if a recordable case
occurred and you failed to record it on the Log for the year in which
the injury or illness occurred, and/or on an Incident Report, you are
under a continuing obligation to record the case on the Log and/or
Incident Report during the five-year retention period for that Log and/
or Incident Report;
(ii) You must also make any additions and corrections to the OSHA
Log that are necessary to accurately reflect any changes that have
occurred with respect to previously recorded injuries and illnesses.
Thus, if the classification, description, or outcome of a previously
recorded case changes, you must remove or line out the original entry
and enter the new information; and
(iii) You must have an Incident Report for each and every
recordable injury and illness; however, you are not required to make
additions or corrections to Incident Reports during the five-year
retention period.
(2) Do I have to make additions or corrections to the annual
summary during the five-year retention period? You are not required to
make additions or corrections to the annual summaries during the five-
year retention period.
0
8. Revise Sec. 1904.34 to read as follows:
Sec. 1904.34 Change in business ownership.
If your business changes ownership, you are responsible for
recording and reporting work-related injuries and illnesses only for
that period of the year during which you owned the establishment. You
must transfer the Part 1904 records to the new owner. The new owner
must save all records of the establishment kept by the prior owner, as
required by Sec. 1904.33, but need not update or correct the records
of the prior owner. The new owner is not responsible for recording and
reporting work-related injuries and illnesses that occurred before the
new owner took ownership of the establishment.
0
9. Revise paragraphs (b)(2) introductory text and (b)(2)(iii) of Sec.
1904.35 to read as follows:
Sec. 1904.35 Employee involvement.
* * * * *
(b) * * *
(2) Do I have to give my employees and their representatives access
to the OSHA injury and illness records? Yes, your employees, former
employees, their personal representatives, and their authorized
employee representatives have the right to access accurate OSHA injury
and illness records, with some limitations, as discussed below.
* * * * *
(iii) If an employee or representative asks for access to the OSHA
300 Log, when do I have to provide it? When an employee, former
employee, personal representative, or authorized employee
representative asks for copies of your current or stored OSHA 300
Log(s) for an establishment the employee or former employee has worked
in, you must give the requester a copy of the relevant and accurate
OSHA 300 Log(s) by the end of the next business day.
* * * * *
Subpart E--Reporting Accurate Fatality, Injury, and Illness
Information to the Government
0
10. Revise the heading of subpart E to read as set forth above.
0
11. Revise the heading and paragraph (a) of Sec. 1904.40 to read as
follows:
Sec. 1904.40 Providing accurate records to government
representatives.
(a) Basic requirement. When an authorized government representative
requests the records you keep under part 1904, you must provide
accurate records, or copies thereof, within four (4) business hours of
the request.
* * * * *
[FR Doc. 2016-30410 Filed 12-16-16; 8:45 am]
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