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OSHARulemakingOSHA-2015-0006

Clarification of Employer's Continuing Obligation to Make and Maintain an Accurate Record of Each Recordable Injury and Illness

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Feb 23, 2021
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closed 3926d ago
National Association of Home Builders filings
2

Activity

National Association of Home Builders filed 2 comments on this docket between Sep 9, 2015 and Oct 28, 2015. 20 other organizations filed here. The comment window closed 3926d ago.

What National Association of Home Builders filed (2)

Oct 28, 2015· Comment from Watson, Felicia; National Association of Home Builders (NAHB)· OSHA-2015-0006-0017

On behalf of the more than 140,000 members of the National Association of Home Builders (NAHB), I am submitting the attached comments on the Occupational Safety and Health Administration's (OSHA or Agency) Notice of Proposed Rulemaking (NPRM) on the Clarification of Employer's Continuing Obligation To Make and Maintain an Accurate Record of Each Recordable Injury and Illness (Recordkeeping Clarification NPRM) that was published in the Federal Register on July 29, 2015. NAHB thanks OSHA for granting stakeholders an additional period of time to submit comments in this important matter. As an interested stakeholder in this regulatory activity, NAHB believes that OSHA's proposed "clarification" to the recordkeeping rule impermissibly expands Section 9(c) of the Occupational Safety and Health Act of 1970 (OSH Act), as well as flies in the face of the U.S. Court of Appeals for the D.C. Circuit decision in AKM LLC v. Secretary of Labor, 675 F.3d 752 (D.C. Cir. 2012) (hereafter Volks) and will, therefore, have a substantial adverse impact on regulated employers and small businesses, including home builders and specialty trade contractors. For the reasons outlined in the attached comment letter, NAHB opposes OSHA's proposal and requests the Agency to comply with Section 9 of the OSH Act and withdraw the proposed rule immediately.

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Sep 9, 2015· Comment from Matuga, Robert; National Association of Home Builders (NAHB)· OSHA-2015-0006-0004

On behalf of the more than 140,000 members of the National Association of Home Builders (NAHB), I respectfully request a 60 day extension of the current deadline for submitting written comments in response to the Occupational Safety and Health Administration's (OSHA) Notice of Proposed Rulemaking (Recordkeeping Clarification NPRM) on the Clarification of Employer's Continuing Obligation To Make and Maintain an Accurate Record of Each Recordable Injury and Illness that was published in the Federal Register on July 29, 2015 (80 Fed. Reg. 45,116). See attached letter.

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Abstract

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Co-filers (20)

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