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The Occupational Safety and Health Administration (OSHA) has announced a final rule on the tracking of workplace injuries and illnesses that requires employers in high-hazard industries to electronically submit injury and illness information to OSHA on an annual basis. The final rule becomes effective on January 1, 2024, and requires businesses with 100 or more employees to submit information from their Form 300 (Log of Work-Related Injuries and Illnesses) and Form 301 (Injury and Illness Incident Report) to OSHA once a year. These are in addition to the required submission of Form 300A (Summary of Work-Related Injuries and Illnesses). Businesses in high-hazard industries with 20 or more employees will continue to be required to submit information from their Form 300A to OSHA once a year.
The recordkeeping requirements mandated by OSHA can pose significant cost burdens on employers and NLBMDA has serious concerns about how OSHA will protect the sensitive private and personal medical information contained in the Form 300 and Form 301. In 2022, NLBMDA submitted comments urging OSHA to withdraw the proposed rule and stressed that it puts the confidentiality and protection of sensitive employer and employee information at risk while creating duplicative, burdensome and costly recordkeeping requirements with no demonstrable benefits to workplace safety. The electronic submission of this data is a stark departure from prior OSHA positions on protecting sensitive information, and the agency intends to make much of the data it collects publicly available online.
NLBMDA members with questions may contact NLBMDA at membersupport@dealer.org.
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