OSHA Proposes to Revise its 2016 Electronic Recordkeeping Rule

Would Rescind E-Submittal of OSHA Forms 300 and 301
On July 27, the Occupational Safety and Health Administration (OSHA) issued a notice of proposed rulemaking to amend the 2016 recordkeeping rule. This proposal would rescind a requirement that contractors with 250 or more employees electronically submit detailed information from their OSHA Forms 300 (Log of Work-Related Injuries and Illnesses) and 301 (Injury and Illness Incident Report), a requirement from which smaller contractors were already exempted.
OSHA cited the need to protect sensitive worker information from disclosure under the Freedom of Information Act (FOIA), the cost to the agency to collect and utilize the information, and the burden on contractors to comply with the current rule as justification for the proposed amendments.
What the proposal does not address are the anti-retaliation interpretations related to safety incentive programs, disciplinary programs, and post-incident drug testing policies. These interpretations continue to be of concern and AGC will again submit comments strongly recommending the agency reconsider their position.
For more information please contact Kevin Cannon at (703) 837-5410 or [email protected].

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