This additional time is meant to facilitate comments received during a public meeting, where business groups and stakeholders expressed concern that employers may under-record employees’ injuries and illnesses by implementing policies to encourage the lack of reporting.
Despite the fact that workplace injuries and illnesses have declined since 1994, both funding and the number of OSHA inspections continue to increase each year.
NSCA signed onto original comments submitted by the Coalition for Workplace Safety with these key points arguing why increased reporting is not necessary:
- OSHA does not have the statutory authority to publicly disseminate the information the Agency plans to publish under this regulation
- It will result in confidential, sensitive, and proprietary business information being made public
- It will provide material for those who wish to mis-characterize employers
- The rule will result in fewer injuries being recorded rather than more injuries being recorded
- The electronic-only reporting requirement adds another burden to employers who are being forced to submit reports
- The proposal upends longstanding policies about recordkeeping with no justification or explanation
- OSHA’s cost and benefit estimates are entirely speculative and without any credibility
- OSHA should have conducted a small business review panel under SBREFA to understand better the impact this rule will have on small businesses
Fundamentally, this proposal will do nothing to improve workplace safety, while causing significant harm to employers through the public disclosure of information and data that has long been protected (and which employers go to great lengths to keep from being released into the public domain). As a result, the CWS and its members urge OSHA to withdraw this proposal.
Do you have additional comments that you would like to make regarding this proposed rule? Visit the Coalition for Workplace Safety or this rule summary for more information on the rule and to submit comments.
View the comments submitted by NSCA and the Coalition for Workplace Safety here: CWS Comments on OSHA Injury and Illness Electronic Reporting Rule