Although OSHA’s injury and illness recordkeeping and reporting rules may seem clear on their face, there are many nuances in the applicable standards that can create challenges to accurately making and maintaining those required records and reports. And the accuracy of injury and illness records could be becoming even more essential in light of the changes OSHA has proposed to the current e-recordkeeping rule, which would increase the availability and use of injury and illness data.
Already, e-recordkeeping data is collected by OSHA and used in developing and executing its Site-Specific Targeting (“SST”) Program based on an employer’s 300A Summary. Per the changes proposed in the current rulemaking effort, OSHA intends to expand who is required to submit recordkeeping data, what data is collected, and what data is shared with the public. This would result in more employers’ injury and illness data being under the microscope and incorporated into OSHA’s enforcement efforts. Indeed, as COVID-19 recordkeeping continues to drive up DART rates for a number of employers due to the need for COVID-19 positive employees to isolate, more may be pulled in OSHA’s SST Program. Thus, it is important for employers to understand the changes possibly to come in e-recordkeeping, as well as what those changes could mean in the context of evaluating and recording/reporting injuries and illnesses.
Participants in this webinar learned about:
- Why its more important than ever to get recordkeeping right
- Requirements for submission to OSHA under the current E-Recordkeeping Rule
- Enforcement efforts related to injury & illness recordkeeping
- Proposed changes to the E-Recordkeeping Rule & their impact
- Examples of recordkeeping challenges
- Evaluating cases of COVID-19 for recordability & reportability
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This was the 10th webinar event in Conn Maciel Carey LLP’s 2022 OSHA Webinar Series. Click here to view our full schedule and detailed program descriptions for all of the webinars scheduled for the 2022 OSHA Webinar Series.
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