In 2012, the U.S. Court of Appeals for the District of Columbia held that the six-month statute of limitation contained in section 9(c) of the Occupational Safety and Health Act (OSH Act) precluded OSHA from issuing a citation against an employer for an alleged failure to record an injury or illness that occurred more than six months prior to the issuance of the citation. AKM LLC d/b/a Volks Constructors v. Sec’y of Labor, 675 F.3d 752 (D.C. Cir. 2012). OSHA subsequently attempted to circumvent the decision by proposing, and in December 2016 finalizing, the “Clarification of Employer's Continuing Obligation To Make and Maintain an Accurate Record of Each Recordable Injury and Illness,” informally known as the Volks Rule. On March 22, 2017, the Senate voted to adopt a House resolution nullifying the Volks Rule, and on April 3, 2017, President Trump signed the House resolution into law.