National Roofing Legal Resource Center

Proposed changes to OSHA reporting regulation

NRCA filed comments with the Occupational Safety and Health Administration (OSHA) in response to proposed changes to its Improve Tracking of Workplace Injuries and Illnesses, which requires employers to submit injury and illness records electronically to the agency. In August, OSHA proposed amending the regulation to require all companies with 250 or more employees to electronically submit only information from their Form 300A to OSHA—eliminating the requirement to also submit Forms 300 and 301. The proposal does not change the requirement that firms in certain hazardous industries—including roofing—with between 20 and 249 employees annually submit their Form 300A electronically. NRCA's comments commended the agency for eliminating the requirement for companies with 250 or more employees to submit their Form 300 and Form 301 electronically, as this will remove the threat of possible disclosure of private employee information to third parties. However, the comments noted OSHA is still putting employers and employees at risk for improper disclosure of sensitive information by leaving in place the requirement to submit Form 300A for covered employers. NRCA believes OSHA should address ambiguity in the regulation's anti-discrimination provisions to clarify how the provision will be implemented and what employers must do to comply. View more information regarding the regulation by clicking here. You also can view more information in October's Safety Spotlight.


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