The Tire Industry Association sent comments online to the Occupational Safety and Health Administration (OSHA) docket office, regarding a proposal from OSHA to “improve tracking workplace injuries and illnesses” by making the data available to the public.
The proposed rule would require “electronic” submission of injury and illness data from employers that are already required to maintain the information under existing OSHA regulations: 1) Establishments with 250 or more employees would be required to file data on a quarterly basis; 2) Establishments with 20 or more employees would be required to submit information from the OSHA annual summary form (form 300A) on an annual basis; and 3) Employers who receive notification from OSHA to submit specified information from their part 1904 injury and illness records. These electronic submissions would then be accessible to the public via the OSHA website.
“While TIA supports OSHA’s laudable goal of promoting safe and healthy working conditions for American workers, we would like to register our strong opposition to the rule as proposed and suggest that the agency withdraw this proposal,” said Kevin Rohlwing, TIA senior vice president of training.
TIA expressed concern with the methodology underlying the rule and the economic costs associated with compliance. OSHA estimated the additional economic costs of $183 per year for establishments with 250 or more employees. TIA reported that OSHA’s estimate was too low; TIA provided its own estimate of $2,064 as an additional economic cost for establishment under the new proposal.
In its comments, TIA also included answers to numerous questions that the agency has raised regarding the proposal. The full document can be viewed at www.tireindustry.org.
