An OSHA proposal would require construction firms with 100 or more employees to electronically submit on an annual basis their OSHA Form 300, OSHA Form 300A, and OSHA Form 301 without meaningful context regarding firms’ safety and health record, among other things.
On June 30, AGC along with more than 60 organizations took issue with OSHA’s proposed rule to expand the scope and revise the provisions of its “Improved Tracking of Workplace Injury and Illness” regulation. If finalized as proposed, the rule will require construction firms with 100 or more employees to electronically submit their OSHA Form 300 (log of work-related injuries and illnesses), OSHA Form 300A (summary of work-related injuries and illnesses), and OSHA Form 301 (injury and illness incident report) on an annual basis. For construction firms with 20 – 100 employees, the rule will require the annual submission of their OSHA Form 300A (summary of work-related injuries and illnesses).
The comments raise significant concerns with OSHA reverting to the requirements of the 2016 rule, making clear that publishing the data without any meaningful context regarding an employer’s safety and health record, or the efforts an employer takes to promote a safe and healthful work environment, does not accurately depict the effectiveness of an employer’s safety and health program. OSHA’s proposed rule does not serve to prevent employee injuries or illnesses in the workplace. Instead, electronic submission and public posting of this data serves only to put employers at risk for improper disclosure, mischaracterization of the data and release of sensitive employer as well as employee information.
Additionally, the comments highlight that OSHA fails to provide any evidence to show that its previous collection and disclosure of summary injury and illness data resulted in the reduction of occupational injuries and illnesses, which it predicts the current rulemaking will achieve. Based on the results of the 2016 rulemaking, AGC anticipates that the agency will finalize the current rule as proposed.
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