OSHA Proposes Changes to
Electronic Record-keeping Rule
OSHA has proposed to remove the requirement for establishments to submit their 300 and 301 forms electronically in an effort to limit the possibility of injured employees’ personally identifiable information being made public. They will still require electronic submission of the 300A
OSHA also wants to require that employers include their Employer Identification Number (EIN) on their electronic 300A submissions.
July 30, 2018 – OSHA has formally published a Notice of Proposed Rulemaking aimed at taking a second look at the Improved Tracking of Workplace Injuries and Illness, also referred to as the Electronic Recordkeeping policy. The proposed rule change is to eliminate a requirement for companies to submit information from its electronic recordkeeping procedures.
The proposed rule eliminates the requirement to electronically submit information from OSHA Form 300 (Log of Work-Related Injuries and Illnesses) and OSHA Form 301 (Injury and Illness Incident Report) for establishments with 250 or more employees that are currently required to maintain injury and illness records. These establishments would instead only be required to electronically submit information from OSHA Form 300A (Summary of Work-Related Injuries and Illnesses).
The intent of this rule change would be to protect sensitive worker information from potential disclosure under the Freedom of Information Act (FOIA). OSHA has preliminarily determined that the risk of disclosure of this information, the costs to OSHA of collecting and using the information combined with the reporting burden on employers may be unjustified.
OSHA is seeking comment on this proposal, particularly on its impact on worker privacy, including the risks posed by exposing workers’ sensitive information to possible FOIA disclosure. In addition, OSHA is proposing to require covered employers to submit their Employer Identification Number (EIN) electronically along with their injury and illness data submission.
For more information as this proposal unfolds, check out sospes.com.
Whatever OSHA decides, we’re ready to help you submit electronically… learn more today!