AIHA Urges OSHA Not to Rescind Tracking Requirement

Posted September 12, 2018

On Sept. 6, AIHA submitted comments to OSHA on its proposal to amend its recordkeeping regulation by rescinding the requirement for employers with 250 or more employees to electronically submit information from OSHA Forms 300 and 301. Form 300 is the log of work-related injuries and illnesses and Form 301 is the injury and illness incident report. A notice of the agency’s action in the Federal Register states that OSHA is amending its recordkeeping requirements “to protect sensitive worker information from potential disclosure under the Freedom of Information Act.”

AIHA’s comments include two recommendations: first, that OSHA should not rescind this requirement, and second, that the agency should temporarily suspend further action on this rulemaking until a study is conducted on the benefits of information collected from Forms 300 and 301. AIHA encourages OSHA to identify other means of protecting workers’ personally identifiable information. Download AIHA’s full comments as a PDF.