On June 7, 2016, Eric J. Conn and Amanda Strainis-Walker of Conn Maciel Carey’s national OSHA Practice presented a webinar regarding OSHA’s New Injury Recordkeeping Data Electronic Submission Rule as part of the Firm’s 2016 OSHA Webinar Series.
As the clock winds down on the Obama Administration, OSHA has been rushing out a series of proposed amendments to its Injury & Illness Recordkeeping regulations (29 C.F.R. Part 1904). Among them is a new final rule to “Improve Tracking of Workplace Injuries and Illnesses,” which will require hundreds of thousands of employers to electronically submit their injury and illness logs (and in many instances, their detailed incident reports also) each year. More importantly, for no apparent safety reason, OSHA intends to publish employers’ injury data and incident reports online.
Another rule working its way through the rulemaking process: “Continuing Duty to Maintain Up-to-Date and Accurate Injury & Illness Records,” would impose a continuing duty on employers to update and maintain
accurate injury and illness logs for the entire five year period for which the current regulation requires employers to keep copies of their OSHA 300 logs and related forms. Essentially, this proposal extends OSHA’s statute of limitations period during which OSHA is allowed to bring an enforcement action alleging a violation of the recordkeeping standard from six months from the day of the recordable injury to five years.
Participants in last week’s webinar learned the following:
- Details of OSHA’s new final rule to require submission of injury and illness recordkeeping data
- Requirements of OSHA’s proposed rule to extend its recordkeeping statute of limitations
- Potential impact of these two recordkeeping rules
- Timing for implementation of both rules
Here is a link to a recording of the webinar with slides and audio. If you missed any of our prior webinars in the 2016 or 2015 OSHA Webinar Series, here is a link Conn Maciel Carey’s Webinar Archive.
This was the sixth webinar event in Conn Maciel Carey’s 2016 OSHA Webinar Series. Plan to join us for the remaining complimentary monthly OSHA webinars. To register for all of the remaining webinars in the 2016 series, send an email to firstname.lastname@example.org, and we will take it from there.