CWS Files Comments on OSHA’s Injury & Illness Recordkeeping Rule

On June 30, CWS and 62 organizations submitted comments on OSHA’s proposed rule, Improve Tracking of Workplace Injuries and Illnesses.

In our comments, we express our deep concerns with the agency’s attempt to require electronic submission of employer summary data and individual employee injury and illness data. As we explained, “OSHA’s proposed rule does not serve to prevent employee injuries or illnesses in the workplace. Instead, … electronic submission and public posting of this data serves only to put employers at risk for improper disclosure, mischaracterization of the data and release of sensitive employer as well as employee information.” This rulemaking will result in smaller entities being at particular risk. Additionally, we explain that OSHA fails to provide “any evidence to show that its previous collection and disclosure of summary injury and illness data resulted in the ‘reduction of occupational injuries and illnesses’ which it predicts the current rulemaking will achieve.”