The Tire Industry Association is seeking comments from all segments of the tire industry regarding a proposal from the Occupational Safety and Health Administration to “Improve Tracking of Workplace Injuries and Illnesses” in part by making the data available to the public.
During a recent informal public meeting with the agency in Washington D.C., organizations representing labor unions and industry groups spoke on the proposed rulemaking. TIA attended both of the meetings but did not make any public statements.
OSHA is proposing a change to the injury and illness reporting requirements starting with all employers covered by 29 CFR 1904 that have 250 or more employees. These large companies will have to electronically submit information for each establishment on a quarterly basis. Based on the language in the proposed rulemaking, OSHA is considering collecting the establishment-specific data from all three forms and making most of it public, according to the TIA.
The next major change to injury and illness reporting requires all businesses with 20 or more employees in designated industries (which includes tire dealers and retreaders) to electronically submit the annual summary Form 300A. This would replace the current ODI since all of the covered establishments with 20 or more employees would be submitting injury and illness data every year instead of approximately every three years. All of this information could be made available to the public, TIA said.
Employers with between 11 and 19 employees would still be required to use all three forms for identifying, tracking and summarizing workplace injuries and illnesses, but the information would not be submitted to OSHA unless the employer receives notification directly from the agency.
“We do not foresee any benefits of making injury and illness data accessible to the public and cannot understand why the Bureau of Labor Statistics is not allowed to release injury and illness data for privacy reasons, yet those rules do not apply in this instance,” said Kevin Rohlwing, TIA Senior vice president of training. “OSHA’s mission is to set and enforce standards in addition to providing training, outreach, education and assistance, so the public access component of this proposal is not consistent with the goals of the agency. Making injury and illness data public will only contribute to under-reporting and create additional incentives for not reporting incidents at all.”
OSHA estimates the total economic costs at $11.9 million per year, with costs of $183 per year for establishments with 250 or more employees and $9 per year for those with 20 or more employees. TIA would like to submit comments that include actual estimates from the tire industry so they can demonstrate how much OSHA underestimates the time and effort that will be associated with collecting and submitting data from companies with multiple locations.
Companies submitting comments on their own should provide a detailed cost analysis. Companies willing to provide TIA with a detailed or even general cost estimate should email it along with other comments to [email protected].
