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First, the OSH Act does not impose absolutely strict liability on employers. personalized name ford motor company tumbler The controlling employer must make reasonable efforts to acquire necessary information in order to satisfy

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32 and the access statements on the new 300 and 301 forms. OSHA believes, based on the record evidence and its own extensive recordkeeping experience, personalized name ford motor company tumbler that posting the Summary is important to safety and health for all the reasons described above. Some of the suggested alternatives may be useful, and OSHA encourages employers to use any practices that they believe will enhance their own and employee awareness of safety and health issues, provided that they also comply fully with the final rule’s posting requirements. he most important change OSHA could make in recordkeeping rules would be to require employers to conduct an independent audit of the completeness of the record.

The purpose of the audit would be to determine that no case went unrecorded, and that no disabling injury or illness was mislabeled as non lost workday. Such requirements were not in the proposal, but are desperately needed. These workers should be evaluated just as any other worker. If a student or intern is working as an unpaid volunteer, he or she would not be an employee under the OSH Act and an injury or illness of that employee would not be entered into the Part 1904 records. If the worker is receiving compensation for services, and meets the common law test discussed earlier, then there is an employer-employee relationship for the purposes of OSHA recordkeeping. The employer in that relationship must evaluate any injury or illness at the establishment and enter it into the records if it meets the recording criteria. If Part 1904 records are inaccurate due to lack of reasonably reliable data about leased employees, there are ways for OSHA to address the problem.