The final rule published today maintains the former rule’s partial exemption personalized name dory and crown royal regal apple tumbler for employers in all covered industries who have 10 or fewer employees. Under the final rule , an employer in any industry who employed
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work-related injury and illness cases must be entered onto the forms. Subpart C contains sections 1904.4 through 1904.29. The proposed rules also would lift the partial exemption for employers classified under SIC Code 7363 personalized name dory and crown royal regal apple tumbler . Those employers, among others, were exempted from injury and illness record keeping requirements in 1982 because they had low work place injury rates. The proposal to lift the exemption is based on reported increased injury rates for these employers. However, since records for the vast majority of staffing firm employees are maintained by the worksite employer as explained above, the practical effect of lifting the exemption for staffing firms would be to require them to maintain records for their home office clerical and administrative workers
for whom there is no evidence of increased work place illnesses or injuries. Hence, we urge OSHA to retain the partial exemption for SIC 7363. Injury and illness recordkeeping is the most basic step an employer must take in order to begin to address workplace hazards. Responsible employers recognize that injury and illness records are a useful tool for development of sound company safety and health programs. This information is also critical to the workers themselves, by raising awareness about how and where people are getting hurt, they in turn use this information to work to eliminate the causes of such injuries and illnesses. Therefore it is disturbing that in the proposed revised standard, there still exist industry exemptions for recordkeeping and reporting. Prior to 1983, all employers covered by OSHA with more than ten employees were required to maintain injury and illness records.