In May of 2016, OSHA revised the recordkeeping regulation requiring companies with 250 or more employees to submit information from OSHA Forms 300, 300A, and 301, electronically to OSHA annually. Additionally, companies in certain industries with 20-249 employees were required to only electronically submit information from only the OSHA Form 300A, which is the summary form. OSHA previously delayed the reporting deadline for electronic submission of the 300 and 301 Forms, and they noted in the notice of proposed rulemaking that they will not enforce the July 1, 2018 deadline for either form, while rulemaking is underway.
OSHA is now proposing to amend OSHA’s recordkeeping regulation and rescind the requirement that companies with 250 or more employees electronically submit information from the OSHA Forms 300 and 301, which are the individual injury/illness forms.
Why OSHA is Proposing This Change
OSHA is proposing this change to the 2016 rule in order to protect worker privacy. According to OSHA, the electronic submission of Forms 300 and 301 adds no clear enforcement benefits and significantly increases the risk to worker privacy. OSHA also notes that these forms could be subject to release under the Freedom of Information Act, which could result in workers being identified. Additionally, OSHA notes that the injury and illness data electronically submitted from Form 300A, provides OSHA with enough information to use in identifying high-hazard establishments for enforcement targeting. Based on the data collected from the 300A Form, OSHA has designed a targeted enforcement mechanism for industries experiencing higher rates of injuries and illnesses. There will be no changes to the OSHA 300A Form reporting requirements.
What This Could Mean for Business
According to OSHA, this proposed rule change has an estimated net cost savings of $8.2M.
Savings would come from the elimination of the need to track and report on additional information that is collected on Forms 300 and 301. This action is also consistent with President Trump’s Executive Order 13771 , which was issued in February 2017, with the goal of reducing regulations and controlling regulatory costs. OSHA argues that this proposal maintains safety and health protections for workers, while at the same time reduces the reporting burden on employers. OSHA encourages stakeholders to submit comments on this proposal.
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