Update About OSHA’s Electronic Recordkeeping Rule (Webinar Recording)

On September 8, 2021, Eric J. Conn, Lindsay A. DiSalvo, and Daniel C. Deacon, presented a webinar regarding an Update About OSHA’s Electronic Recordkeeping Rule.

OSHA’s E-Recordkeeping Rule has been challenged and criticized by stakeholders since its inception, with expectations that OSHA under a Trump Administration would significantly narrow or even rescind it. Despite issuing an amended rule, the Trump Administration did very little to narrow its impact on employers and nothing to alleviate concerns about the collection and publication of injury data.

OSHA is also actively enforcing both the recordkeeping and anti-retaliation elements of the rule, and OSHA even promulgated a site-specific targeting program (SST-16 Plan) based on employer 300A data collected under the E-Recordkeeping Rule. Even more enforcement of the rule is expected in 2021 as the Biden Administration takes the reins, and a new site-specific targeting plan has been announced. The Biden Administration is also highly likely to amend the Rule again to restore OSHA’s original intent to collect 300 log and 301 incident report level data.

During this webinar, participants learned about: Continue reading