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Office argues OSHA’s e-reporting rule is still too hard on small businesses

Letter outlines public comments from small business owners

Posted October 1, 2018

The Small Business Administration’s Office of Advocacy (Advocacy) filed a public comment letter with OSHA regarding OSHA’s proposed changes to its Tracking of Workplace Injuries and Illnesses rule. The proposed rule, published in the July 30 Federal Register, would amend OSHA’s recordkeeping and reporting regulations by rescinding the requirement that employers with 250 or more employees submit their OSHA 300 and 301 data to the Agency electronically, although they still would be required to submit their OSHA 300A summaries electronically.

The Advocacy’s public comment letter outlines issues raised by the group, and asks OSHA to:

  • Consider eliminating the requirement to submit the 300A data electronically.
  • Reassess its list of “designated” and “partially exempt” industries and consider further exemptions for industries with declining injury and illness rates.
  • Consider eliminating the provision or clearly defining the term “reasonable procedures” for reporting work-related injuries and illnesses.
  • Not require employers to include their Employer Identification Number (EIN) due to the potential for fraudulent use.

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