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The Occupational Safety and Health Administration (OSHA) should consider the unintended consequences of a proposed revision to its injury and illness tracking and reporting requirements before issuing the final rule, ABC wrote in a set of comments submitted to the agency Oct. 28. 

Under the proposed revisions, companies would have to report to OSHA all work-related fatalities and in-patient hospitalizations within eight hours. Under the current regulations, only fatalities and in-patient hospitalizations of three or more employees must be reported in that timeframe. 

While offering general support for OSHA’s goals of identifying hazards and preventing injuries and fatalities in high-risk workplaces, ABC also pointed out that altering the number of employees that trigger reporting of in-patient hospitalizations from three employees to one will make it harder to determine which incidents are work related. 

While an incident that causes three or more employees to be hospitalized is likely to be work related, hospitalization of only one employee could be due to a variety of issues – both work related and not, ABC wrote. Such a policy would present new burdens with questionable benefit, and could lead to subsequent rulemakings and policies based on erroneous data. 

Because of the potential issues associated with the accuracy of work related data, a lack of evidence showing that the existing policy is ineffective, and the additional costs to employers the proposed revisions will undoubtedly cause, ABC asked OSHA to take a closer look at the unintended consequences of the proposed rule and take them into consideration when issuing the final rule.