IWLA Joins CWS Comments on Proposed Injury/Illness Filing Requirements

IWLA joined comments filed by the Coalition for Workplace Safety (CWS) in response to the Occupational Safety and Health Administration’s (OSHA) notice of proposed rulemaking that  would require employers with 100 or more workers in certain industries to file additional workplace injury and illness reporting documents each year. The industries include warehousing, transportation, food production, manufacturing, health care, retail, and performing arts.

Under the proposed rule, covered businesses with 100 or more workers will have to file Form 300, 301, and 300A on an annual basis. Form 300, commonly called the OSHA log, lists every on-the-job illness or injury that requires more than first aid to treat or that leads to at least one day of missed work. Form 301 is a detailed report on each recordable injury or illness. Form 300A is an annual summary of a workplace’s injury and illness cases.

In comment, the CWS expressed deep concern with the agency’s attempt to require electronic submission of employer summary data and individual employee injury and illness data. CWS wrote that “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.”

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