Janet Kopenhaver has a summary of OSHA’s proposed changes to record-keeping rules. The changes state that employers must make and maintain accurate records of work-related injuries and illnesses as an ongoing obligation. The duty to record an injury or illness continues for as long as the employer must keep records of the recordable injury or illness; the duty does not expire because the employer fails to create the necessary records when first required to do so. You can view the summary here:  OSHA Proposed Changes to Injury Reporting Rule 080715.