CWS comments on OSHA Proposed Revisions to Injury and Illness reporting reg submitted


Many U.S. Department of Labor issues that TCIA follows and is concerned with are mega issues affecting a broad swath of employers. OSHA’s proposed injury & illness reporting regulation is an example of where it made sense for TCIA to add it’s voice to a broader chorus of opposition. We signed on to comments crafted by the Coalition for Workplace Safety, or CWS, organized by the U.S. Chamber of Commerce.

The attached comments on OSHA’s proposed revisions to the injury and illness reporting regulation (Tracking of Workplace Injuries and Illnesses) were submitted in October, 2018. Also attached were the comments CWS submitted during the supplemental rulemaking that became the anti-retaliation provision as they were referenced in the primary comments. To summarize a lengthy document, CWS comments made the following points:

  • OSHA wants to retain collection of the 300A annual summaries which contain confidential business information but gives no indication of trying to protect this information from disclosure leaving employers concerned that these forms would be subject to FOIA requests (Public Citizen is already pursuing this) and that a future administration would not hesitate to release these forms;
  • OSHA wants to add EINs to these forms which seems unjustified and gives employers concerns that this sensitive information will be released inappropriately, even if EINs may be available from other sources;
  • OSHA has not addressed the many problems associated with the anti-retaliation provision that was added through a supplemental rulemaking;
  • Accordingly, the CWS urges OSHA to revise this proposal so that 300A annual summaries are not collected, and to address the many problems with the anti-retaliation provision.


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