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“Responsible company official” was defined in the proposal vintage old cowboy you dont stop riding when you get old poster as “an owner of the company, the highest ranking company official working at the establishment,

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However, in the case of any change in ownership, the employer shall preserve those records, if any, of the prior ownership which are required to be kept under this part. vintage old cowboy you dont stop riding when you get old poster  These records shall be retained at each establishment to which they relate, for the period, or remainder thereof, required under § 1904.6. grees that a corporate official responsible for health and safety and the highest ranking company official at an establishment should certify that a good faith effort for proper recordkeeping has taken place, and the individual responsible for day-to-day OSHA recordkeeping should certify the accuracy and completeness of the log (Ex. ). he language of the certification is totally impractical and unreasonable in that it is written as a certification of absolute completeness

and accuracy. This creates such an unreasonably high standard that no one should legitimately be asked or required to sign it. As a general rule, we believe an individual would be expected to have significantly better knowledge of the information on his/her personal income tax return than on the OSHA Form 300; yet even the certification on the personal income tax return includes the language “to the best of my knowledge and belief.” This clause must be added to the certifying language. OSHA proposed to change the former rule’s certification requirements. In the proposed rule, OSHA proposed to require that a responsible company official certify to the accuracy and completeness of the Log and Summary. According to the proposal, that person would sign the summary to certify that “he or she has examined the OSHA Injury and Illness Log and Summary and that the entries on the form and the year-end summary are true, accurate, and complete” .