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OSHA Recordkeeping 2016

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Business Insurance reported on the White House approved of an OSHA request to move forward with their proposal to mandate electronic reporting of occupational injuries and illnesses.

When initially presented in 2013, businesses reacted strongly to the OSHA proposal, citing not only increased cost, but the exposure of personal health information regarding those employees who became injured or ill at work. OSHA estimates that the cost in the first year to American business is $11.9 million while the U. S. Chamber of Commerce estimates the cost to be nearly 100 times that much. 

U.S. businesses, do you have an electronic system that will assure that you can comply with electronic accident reporting requirements?

For the vast majority of employers, sadly, the answer is no. Most businesses that are subject to OSHA regulation will have to rely on third parties to report their injury and illness information to regulators. Insurance carrier and TPA services will have to fill that void, leaving employers without the opportunity to review, correct and properly classify injury reports.

We all know that the initial first reports of injury/illness can be short on detailed information, or have information that is the result of conjecture or best guess estimates made at the time of the incident by well-intentioned supervisors. In many cases, detailed information may be completely missing until inquiries are made by safety professionals, claim adjusters or others, after the crush of the initial response has been completed. Is this the information employers want reported to OSHA, and ultimately, made public? Probably not!

Accuracy and detail are important to provide the full and accurate story of any occupational injury or illness situation. Are your incident notification, investigation and reporting processes ready for OSHA and public scrutiny? If the answer is no, it is probably time to get those challenges resolved before the new electronic reporting requirements become enforceable OSHA standards!

A summary of the OSHA proposal, from the OSHA web site:

OSHA is proposing to amend its recordkeeping regulations to add requirements for the electronic submission of injury and illness information employers are already required to keep under OSHA's regulations for recording and reporting occupational injuries and illnesses. This proposed rule would amend the regulation on the annual OSHA injury and illness survey of ten or more employers to add three new electronic reporting requirements. First, OSHA will require establishments that are required to keep injury and illness records under OSHA's regulations for recording and reporting occupational injuries and illnesses, and that had 250 or more employees in the previous year, to electronically submit information from these records to OSHA or OSHA's designee on a quarterly basis. Second, OSHA will require establishments that are required to keep injury and illness records under OSHA's regulations for recording and reporting occupational injuries and illnesses, had 20 or more employees in the previous year, and are in certain designated industries to electronically submit the information from the OSHA annual summary form (Form 300A) to OSHA or OSHA's designee on an annual basis. The second submission requirement will replace OSHA's annual   injury and illness survey, authorized by the current version of the regulation. Third, OSHA will require all employers who receive notification from OSHA to electronically submit specified information from their Part 1904 injury and illness records to OSHA or OSHA's designee.

Jeff_Gehrke_headshot.jpgJeff Gehrke is Ventiv's Chief Risk Technology Evangelist. Contact Jeff at Jeff.Gehrke@ventivtech.com or ++1.720.445.9531. Connect with Jeff on LinkedIn: https://www.linkedin.com/in/jeffjgehrke 

 

 

The Definitive Guide to a RMIS

May 24, 2016

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