Sunday, January 26, 2014

OSHA 300A Posting Required by February 1. Changes Coming for Recordkeeping.

This is your annual reminder that the Occupational Safety and Health Administration (OSHA) 300A injury and illness summary form is required to be posted from February 1 to April 30, 2014.  The 300A form is a summary of the information from the OSHA 300 injury and illness recordkeeping form.  You are not required to (nor should you) post the OSHA 300 form.  For more information on completing these forms visit OSHA's website at:

In addition, OSHA heard public comments from January 9-10, 2014 at the US Department of Labor in Washington DC.  OSHA held this meeting to give stakeholders the opportunity to remark on OSHA's proposed rule to amend recordkeeping regulations.  The amendment would require the electronic submission of injury and illness information to OSHA.  According to OSHA, the proposal would require electronic reporting by approximately 440,000 small companies (20+ employees) annually and larger companies (250+ employees), approximately 38,000 will need to submit injury and illness data on a quarterly basis.  This amendment does not add any new requirements; it just modifies an employer's obligation to submit these to OSHA.

These changes, according to OSHA, are necessary so that the government and researchers will have better access to data to encourage earlier abatement of hazards and improved programs to reduce workplace hazards and prevent injuries, illnesses, and fatalities.  OSHA also says that currently they only see 20 percent of the injury and illness data provided by employers.  Under the new system, they will see 50 percent of the data.

Needless to say, there are those who feel this is a good thing and there are those, many business representatives, who think well.......that public access to this data will encourage employers to underreport as a result of the potential negative impact on their businesses' reputations.  They are also concerned with liability.  Business representatives fear that posting injury and illness data online will open the business up to the pursuit of trial lawyers and unions.  Another concern of business representatives revolves around the costs associated with compliance, which can hurt business and job creation — especially the hiring of temporary workers.  Sounds like the usual business concerns, to us.

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