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OSHA 1903.19AppA

Citation correction attestation form

15 Questions & Answers
10 Interpretations

Questions & Answers

Under 1903.19AppA (Citation correction attestation form), what is the purpose of this attestation form?

The attestation form documents which cited hazards have been corrected and who certifies that correction. The form in 1903.19AppA is a template employers can use to list the inspection number, the citation and item numbers, the date each violation was corrected, and the person or method that corrected it, followed by a signature attesting to the accuracy of the information.

Under 1903.19AppA, is the Appendix A attestation form mandatory to use?

No—the Appendix A template is nonmandatory guidance that employers may use but are not required to follow verbatim. The appendix itself states that Appendices A through C "provide information and nonmandatory guidelines to assist employers and employees" in complying with the requirements of the section; see 1903.19AppA.

Under 1903.19AppA, what specific information should be provided for each corrected citation item on the attestation form?

You should list the inspection number, the citation number and item number, the date the item was corrected, and who or what fixed the hazard. The template in 1903.19AppA shows fields for the 9-digit inspection number, citation and item identifiers, a correction date, and a brief note of how the hazard was corrected.

Under 1903.19AppA, who should sign the attestation form?

An employer or an authorized representative should sign the attestation to certify the accuracy of the correction information. The template ends with a place for a signature and a typed or printed name, which is the employer's attestation that the information is accurate per 1903.19AppA.

Under 1903.19AppA, can an employer list multiple citations and items on the same attestation form?

Yes—one attestation form may list multiple citation/item corrections as shown by the multiple entry lines in the Appendix A template. The sample form in 1903.19AppA includes several repeated lines for "Citation [insert #] and item [insert #] was corrected on [insert date] by:" so you can document multiple corrected items on a single page.

Under 1903.19AppA, where should the completed attestation form be sent?

Send the completed attestation to the Area Director at the OSHA Area Office listed on the citation. The form header directs delivery to the "Area Director U. S. Department of Labor – OSHA" and the address should match the Area Office shown on the original citation per 1903.19AppA.

Under 1903.19AppA, what does the wording "I attest that the information contained in this document is accurate" mean for employers?

It means the signer affirms that the dates and descriptions of corrections are true to the best of their knowledge and that they accept responsibility for the accuracy of the submission. The template concludes with this attestation and a signature block, so employers should complete it only after confirming the corrections described on the form are actually in place, as shown in 1903.19AppA.

Under 1903.19AppA, should an employer submit a correction attestation if the cited condition is currently under contest?

No—if a citation or item is properly under contest, the employer's abatement obligation for that specific item is generally suspended and the employer should not falsely attest that the item has been corrected. OSHA's policy explains that when an employer files a notice of contest, "the obligation for abatement of the specific condition(s) cited ... is suspended until the matter is adjudicated," and OSHA generally will not issue an additional citation for the exact same condition while it's under contest; see OSHA's letter on Policy on contesting citations and the Appendix template at 1903.19AppA.

Under 1903.19AppA, can the attestation form substitute for an on-site abatement verification by OSHA?

Sometimes—but not always; the attestation can serve as documentary proof of correction, but OSHA may still require an on-site follow-up inspection if the documentation is missing or inadequate. OSHA's enforcement guidance explains that employers are required to submit documentation that abatement has been achieved and that OSHA will only do an on-site inspection if the documentation is not submitted or is inadequate; see the Enhanced Enforcement Policy memo and the Appendix form in 1903.19AppA.

Under 1903.19AppA, what inspection number format should be entered on the attestation form?

Enter the 9-digit inspection number exactly as shown on the citation. The template specifies "Inspection Number [insert 9-digit #]," so use the complete nine-digit number from the OSHA citation when you fill out the form in 1903.19AppA.

Under 1903.19AppA, if corrections were performed over several dates, how should an employer record that on the attestation form?

Record the date each specific citation item was actually corrected on the line for that citation/item; if different parts of a single item were corrected on different dates, clearly show the final date that completes abatement or explain the phased corrections. The Appendix A template asks for "Citation ... was corrected on [insert date] by:" so provide the actual correction date for each listed citation item as shown in 1903.19AppA.

Under 1903.19AppA, is using the Appendix A template enough to meet OSHA's requirement to document abatement?

Using the Appendix A template can be sufficient documentary evidence of abatement, but the documentation must accurately describe the correction and be acceptable to OSHA, and OSHA may request additional evidence or an on-site verification if needed. Appendix A is a suggested form to assist compliance per 1903.19AppA, and OSHA's enforcement guidance notes that documentation is the usual method for verifying abatement unless it is inadequate, in which case OSHA may conduct a follow-up inspection (see the Enhanced Enforcement Policy).

Under 1903.19AppA, what should an employer do if they sign the attestation but later discover a correction was incomplete or reversed?

If you signed an attestation and later find the correction was incomplete, you should promptly notify the OSHA Area Office and provide updated, accurate documentation of the status and any further abatement steps. The Appendix A attestation requires an accurate statement of corrections per 1903.19AppA, and promptly correcting the record helps avoid enforcement problems or follow-up inspections as discussed in enforcement guidance such as the Enhanced Enforcement Policy.

Under 1903.19AppA, where on the citation can I find the Area Director's address to send the attestation?

The Area Director name and the address of the OSHA Area Office are printed on the citation itself, and the Appendix A header indicates you should address the attestation to that Area Director and office as shown on the citation; see 1903.19AppA.

Under 1903.19AppA, can an employer use this attestation form to document abatement for violations from multiple inspections?

Yes—if the template is used to list each relevant inspection number and the corresponding citation and item numbers, you can document corrections from more than one inspection on the same or separate forms as appropriate. The Appendix A layout begins with an "Inspection Number [insert 9-digit #]" header and then lists citation/item lines; you can complete separate forms or include multiple inspection entries consistent with 1903.19AppA.