As expected, OSHA says it wants to remove a requirement from its electronic recordkeeping rule.
Under the proposal, issued as a Notice of Proposed Rulemaking (NPRM), OSHA would eliminate the requirement to electronically submit information from Form 300 (Log of Work-Related Injuries and Illnesses) and Form 301 (Injury and Illness Incident Report) for establishments with 250 or more employees that are currently required to maintain injury and illness records.
OSHA says its proposal would better protect personal information that could be gleaned from the forms. Ending the requirement to submit the forms would increase privacy and reduce the burden on businesses when it comes to compliance with the current recordkeeping rule, according to OSHA.
Facilities would still be required to electronically submit information from Form 300A (Summary of Work-Related Injuries and Illnesses). Establishments with 20-240 employees are also required to electronically submit information from their Form 300A.
The injury and illness data electronically submitted from Form 300A gives OSHA a great deal of information to use in identifying high-hazard establishments for targeted enforcement, according to the agency.
OSHA says it’s not accepting Form 300 or 301 data and won’t enforce the deadlines for these two forms without further notice while this rulemaking process is underway. The agency’s electronic portal is collecting Form 300A data for calendar year 2017. Those submissions were due July 1, 2018, and any that are submitted now “will be marked late,” according to OSHA.
The comment period on the proposal is open for 60 days after the publication date (July 30, 2018) of the proposal. OSHA is only seeking comment on the proposed changes, not on any other part of its recordkeeping requirements.
