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Occupational Injury & Illness Recordkeeping Proposed Rule

On March 30, OSHA issued a proposed rule to amend its occupational injury and illness recordkeeping regulation, 29 CFR 1904.41. The current regulation requires certain employers to electronically submit injury and illness information to OSHA.

In addition to reporting the Annual Summary of Work-Related Injuries and Illnesses (Form 300A), the proposed rule would require certain establishments in high-hazards industries to electronically submit additional information from their Log of Work-Related Injuries and Illnesses (Form 300), as well as their Injury and Illness Incident Report (Form 301).

The proposed rule would:

  • Eliminate the current requirement for all establishments with 250 or more employees in industries that are required to routinely keep OSHA and illness records, but not in a designated industry (listed in a proposed new Appendix B to subpart E), to electronically submit information from their Form 300A to OSHA annually.
  • Require instead, that employers with 100 or more employees in certain designated high-hazard industries (listed in proposed Appendix B to subpart E) electronically submit injury and illness information from their OSHA Forms 300, 301, and 300A annually. Note that these employers are already required to submit Form 300A, but the proposed requirement for the electronic submission of data from the 300 and 301 Forms would be new.
  • Update the classification system (in Appendix A and proposed Appendix B to subpart E) used to determine the list of designated industries covered by the electronic submission requirement. The updated Appendix A and proposed Appendix B would reflect the 2017 version of the North American Industry Classification System (NAICS), replacing the 2012 version.
  • Require establishments to include their company name when making electronic submissions to OSHA.

 

Establishments with 20 or more employees in certain designated high-hazard industries would continue to be required to electronically submit information from their OSHA Form 300A each year.

You can submit comments online about the proposed rule using Docket No. OSHA-2021-0006 on the Federal eRulemaking Portal. Comments must be submitted by May 31,2022. For additional information on the proposed amendments to the occupational injury and illness recordkeeping regulation and how they might impact your organization, please email us at info@safetypartnersinc.com. 

This blog was written by Beth Graham, Associate Director of Quality, Research, & Training at Safety Partners.

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