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On Oct. 14, ABC submitted comments to the Occupational Safety and Health Administration (OSHA) requesting that it withdraw a proposed rule and supplemental notice requiring employers to electronically submit detailed injury and illness records to the agency. For the first time, OSHA plans to make this information publically available on the Internet through a new searchable database, as well as use the data for enforcement purposes.

Under the proposed rule, OSHA would require establishments that have employed between 20 and 249 employees at any time in the previous calendar year electronically submit a form (OSHA Form 300A) on an annual basis. Establishments that employed 250 or more employees in the previous calendar year would be required to electronically submit the OSHA 300A form annually and submit the OSHA Forms 300 and 301 quarterly.

The supplemental notice of proposed rulemaking published August 14, 2014, comes in response to concerns expressed by stakeholders that the initial proposed rule could motivate employers to under-record their employees’ injuries and illnesses.

In its comments, ABC pointed out that the agency lacked any supporting evidence to justify the claim of underreporting due to employer policies that allegedly discourage reporting of injuries and illnesses. In addition, ABC criticized the proposal itself, citing OSHA’s decision to pose a series of questions for comment, rather than provide actual regulatory text to which stakeholders could respond.

The ABC-led Coalition for Workplace Safety, reiterated its position that OSHA should withdraw the proposed regulation, including the supplemental notice, stating there is no indication that the current recordkeeping requirements in place are ineffective.

To read ABC’s comments to OSHA, click here.

To read CWS’s comments to OSHA, click here.