No new recordkeeping requirement is in the proposed rule, but many employers would face a new requirement to submit their injury and illness data to OSHA, which would remove personal identifiers and post it.

OSHA Proposes Major Recordkeeping Change

The key element of its new proposed rule is public disclosure of companies' injury and illness data.

OSHA Assistant Secretary Dr. David Michaels invited a safety heavyweight, former ALCOA CEO Paul O’Neill, to join him Nov. 7 when Michaels announced a potentially game-changing new proposed rule. It would require establishments with more than 250 employees that are already required to keep injury records to electronically submit them to OSHA on a quarterly basis and establishments with 20 or more employees in industries with high injury and illness rates to submit each year, electronically, their injury and illness logs. During the conference call, Michaels said OSHA will post the data online, once personally identifying information is removed, a plan O'Neill strongly endorsed.

O'Neill, who left the top post at ALCOA about 13 years ago, noted the company continues to post its injury and illness rate online in real time, something he instituted while there. (The company's site says as of Thursday, Nov. 7, 2013, at 20:00 Greenwich Mean Time, Alcoa's lost workday rate for 2013 was 0.083 and its 2013 days away plus restricted and job transfer rate was 0.341.) "I think this [OSHA proposed rule] is a great initiative," O'Neill said. "I hope it won't be too long until we take the step of suggesting to employers that they post their data in real time like ALCOA does."

Michaels said OSHA already collects injury and illness data from 80,000 U.S. employers and already posts the data from 60,000 of them online. He said the newly proposed submission requirements will enable employers to compare their safety records against peers and will allow workers to know the safety records of potential employers. Aggregating data across industries also will help researchers identify emerging hazards and patterns, Michaels said.

OSHA will hold a public meeting on the proposed rule Jan. 9 in Washington, D.C. OSHA is accepting public comments for 90 days, until Feb. 6., 2014.

Michaels announced the rule on the same day the Bureau of Labor Statistics released its estimate that there were almost 3 million nonfatal U.S. recordable workplace injuries and illnesses by private-industry employers in 2012, resulting in an incidence rate of 3.4 cases per 100 equivalent full-time workers, based on the BLS Survey of Occupational Injuries and Illnesses.

"Three million injuries are three million too many. We can and we must do better," Michaels said. "In some industries, more than one in 20 workers is injured annually."

OSHA has about 2,400 inspectors to cover millions of workplaces, and employers must find and fix their hazards whether or not OSHA inspects their premises, he added. Michaels called the proposed submission requirements "an effective, inexpensive, and non-prescriptive way" to encourage employers to do this.

American Industrial Hygiene Association President Barbara J. Dawson, CIH, CSP, released a statement supporting the proposal: "While much depends on the details of the proposed rule, AIHA supports OSHA's efforts to protect workers by making employee injury and illness records public, as this will more effectively prevent workplace accidents and illnesses. The proposal will increase the focus of senior managers on injury and illness data and encourage employers to do the right thing for their workers. We will closely review the proposed rule and seek input from our members and other stakeholders as we put together formal comments on the proposal."

Answering a reporter's question, Michaels said he's unsure how quickly the data would be posted after OSHA receives it.

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