Blanchester Area Chamber of Commerce
Blanchester, OH 45107
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OSHA Announces Proposed Rule Change for Workplace Injuries and Illnesses

By Gary Hanson, President of
American Safety & Health Management Consultants, Inc.


Currently most employers with 10 or more employees are required to maintain the OSHA 300 Log and the 300A Summary. The 300A Summary has to be posted by February 1st of the following year and be posted until May 1st of that year. After that date it can be taken down and filed. Each affected company is required to maintain these records for at least five years. OSHA Compliance Officers are required to review the company OSHA records during an OSHA inspection.

Each year in the spring companies will receive a request to send in their OSHA Recordkeeping data to the Bureau of Labor Statistics (BLS). The BLS then complies the data for each NAIC Code. (North American Industrial Code.) They then post online during the fall the latest OSHA Incident Rates for each NAIC Code. Companies can pull this information up on the OSHA website to see how they compare with other companies in their NAIC Code. Also, OSHA develops their annual inspection list of companies who have a DART Rate higher than the National average for their Code. The DART Rate is all the Lost-Time cases and the Days of Restricted cases added together. Those companies with high DART Rates are subject to a full OSHA style inspection. On average in Ohio there are over 1200 companies each year who are subject to a DART type safety inspection.

November 7, 2013 OSHA issued a new proposed rule to require employers with more than 250 employees who are required to keep the records to electronically submit their records on a quarterly basis to OSHA. Companies with 20 or more employees in certain industries with high injury and illnesses rates will be required to submit their 300A Summary electronically on an annual basis.

This change is being proposed because there are over 3 million Occupational Injuries and Illnesses that are reported to the Bureau of Labor Statistics each year. The proposed changes according to Dr. David Michaels, the Assistant Secretary of Labor for OSHA, will provide better access to data for employers, employees and the government that will encourage earlier abatement of hazards. It also hopes that this will result in improved safety programs that will reduce workplace hazards and prevent injuries, illnesses and fatalities.

This proposal does not add any new additional recordkeeping requirement. It only modifies an employer's obligation to transmit these records to OSHA.

The public will have 90 days - through Feb. 6, 2014 to submit written comments on the proposed rule. On January 9, 2014, OSHA will hold a public meeting on the proposed rule in Washington, D. C.

OSHA plans to eventually put the data online as encouraged by President Obama's Open Government Initiative. This will help OSHA target resources more effectively by identifying workplaces where workers are at great risk. This will also allow other employers to compare their injury rate to others in the same industry according to OSHA.

This change if adopted would not take effect until January 1, 2015. It will provide OSHA quick results on injuries and illnesses taking place at the companies required to maintain the OSHA records. This will not result in increased inspections, but will change which companies get targeted in the future.

If you have any questions or need any assistance with your Safety Program, please give me a call at
1-800-356-1274.