CWS Submits Comments on OSHA Recordkeeping Rule

Washington, D.C. – On September 28, 2018, CWS submitted comments to the Occupational Safety and Health Administration on the agency’s proposed alterations to its 2016 rulemaking, Tracking of Workplace Injuries and Illnesses. The 2016 rulemaking had numerous fundamental flaws, and CWS therefore was very supportive of OSHA’s decision to revise the rule.

In our comments CWS supported OSHA’s decision to eliminate the requirement for certain establishments to submit Forms 300 and 301, but unfortunately, the agency’s revisions didn’t go far enough. CWS strongly urged OSHA to eliminate the filing of Form 300A as well, which put employers at risk for improper disclosure and release of sensitive employer information. Furthermore, CWS called on OSHA to rectify the myriad statutory and legal problems presented by the anti-retaliation provision included in the 2016 rulemaking.