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OSHA’s proposal to modernize recordkeeping: A no-brainer

December 5, 2011

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A proposed OSHA rule undergoing review at the Office of Management and Budget has the potential to change how OSHA conducts its work, how effective injury and illness prevention programs really are, and how the public perceives occupational injuries.

Details on the rule to modernize OSHA’s injury and illness reporting system are sparse, but it would change section 1904.41 of the Recording and Reporting Occupational Injuries and Illness Standard – which specifies the annual collection of employer injury and illness data – and establish electronic collection of that data.

This is pretty significant. By law, every employer with more than 10 employees must keep injury and illness records, but OSHA never sees most of these records. The agency can access records during an inspection, it can use the Bureau of Labor Statistics annual injury and illness survey, and OSHA has its own data collection. Through these means, the agency – at most – sees injury and illness data from less than 25 percent* of the 1.5 million establishments required to keep records. Additionally, some of the data collected – from BLS’ annual survey, for instance – is a year behind.

An electronic collection system could enable employers to fill out the proper forms in a timelier manner and then turn the data immediately over to OSHA (similar to requirements for fatalities and certain hospitalizations). This process would allow OSHA to see in real-time what injuries are occurring, where they’re occurring, and even how or why they’re occurring. In turn, the agency could then better focus its efforts in preventing injuries by being able to see developing trends and reacting to them quickly.

The public and nonprofit organizations also could benefit from this data. Instead of waiting for BLS’ annual reports for specific information about occupational injuries in a particular region or industry, it would be available and updated on a regular basis throughout the year. Businesses could look at this data and determine what types of injuries and illnesses are occurring in their industry, and implement plans to prevent such incidents at their own facilities.

Certainly, there are a lot of quirks to work out, including how much confidential information would be supplied to OSHA and the public. And the costs and time that is involved in using a new system (which I can’t imagine would be much more than the current system, considering employers already have to fill out these forms) is also a factor. I don’t see much controversy in this rule, at least not the type of controversy that comes with creating a completely new regulation for a hazard or updating a massive, decades-old law. Given how interconnected with, and reliant upon, our world has become with the Internet and social media, a rule to quickly provide pertinent data to people dedicated to preventing injuries and deaths seems like a no-brainer.


*According to OSHA, the agency collects injury and illness data from about 80,000 employers in “high-hazard” industries each year, and the BLS’ annual injury and illness survey is sent out to about 235,000 establishments. Employers are mandated to complete the surveys. Additionally, OSHA conducts about 41,000 inspections each year, nearly half of which the agency said were spurred by a death or serious injury. Adding these up accounts for 23.7 percent of the 1.5 million establishments required to keep records. Considering there is likely to be some overlap (an establishment could potentially be targeted by both OSHA and BLS), this figure is bound to be even smaller.

The opinions expressed in "Washington Wire" do not necessarily reflect those of the National Safety Council or affiliated local Chapters.

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