New requirements proposed by OSHA would make certain employers submit OSHA 300 injury and illness recordkeeping data electronically and would make some of the data public.
OSHA 300 record requirements for large establishments (250 or more employees)
Under the proposal published in the Federal Register on November 8, establishments with more than 250 employees that are already required to keep injury and illness records would electronically submit the OSHA 300 Log and OSHA 301 Incident Report records to OSHA on a quarterly basis. The OSHA 300A Summary would be submitted annually. The data with case characteristics and other additional details about incidents in the records would be stripped of personal, identifying information about individual employees.
OSHA estimates this requirement would eventually affect approximately 38,000 large establishments. OSHA plans to phase in the establishments required to submit records under the proposal, starting with high hazard establishments with a days away from work, restricted work activity, or job transfer (DART) rate of 2.0 or above. After the first phase, the agency proposes to assess the effectiveness, adequacy, and burden of the reporting requirements before expanding the requirement to all other establishments.
OSHA 300 record requirements for smaller establishments (20 or more employees)
Businesses with 20 or more employees at each establishment in designated industries with above-average injury and illness rates would be required to electronically submit the Summary of Work-Related Injuries and Illnesses (Form 300A) at each of their establishments to OSHA once a year. They would not be required to submit the OSHA 300 Log or 301 Incident Report.
OSHA would also require any employer who receives notification from OSHA to electronically submit information from their injury and illness records instead of sending paper copies of these records to OSHA or its designee.
OSHA wouldl provide a secure website for the data collection. Employers would register and be assigned a login and password.
In a press conference, OSHA chief David Michaels explained the proposed changes, which he emphasizes do not ask employers to keep additional records under Part 1904. Rather, the proposal asks businesses to transmit information from records they already keep to OSHA so the agency can more effectively allocate its compliance assistance and enforcement resources. Under the current system, OSHA never sees most of the injury and illness logs kept by employers.
How will electronic recordkeeping prevent injuries?
Michaels explained that with OSHA’s limited resources, inspections are not enough to protect workers. Employers need to identify and fix hazards on their own. OSHA says gathering data and making it public will help employers compare their performance against other workplaces in the same industry. The fact that employees can see and monitor the data will help keep their employers honest in their reporting, Michaels believes.
Also participating in the press conference was Paul O’Neill, former U.S. treasury secretary and former CEO of Alcoa. O’Neill called the OSHA proposal a “great initiative” that can help employers stay abreast of lessons learned from incidents and benchmark their performance. O’Neill believes that Alcoa’s real-time safety data reporting system has helped speed the pace of learning at the company and has contributed to its low injury rate.
According to OSHA, the cost of compliance would be $183 per year for affected workplaces with 250 or more workers and $9 per year for those with 20 or more employees. The agency is planning an informal public meeting on the proposal on January 9th, 2014, in Washington D.C.
Electronic OSHA 300 forms
Many companies already keep their OSHA 300 forms in electronic format. BLR subscribers can download an electronic copy of the OSHA 300 forms.