Conclusion
While transparency in recordkeeping serves a valuable purpose, the Proposed Rulemaking is unreasonable and unnecessarily complicated. OSHA should specify how it will utilize any data it collects. OSHA should also abandon any consideration of enterprise-wide submissions.
For the reasons stated, INGAA respectfully suggests that OSHA modify the Proposed Rulemaking as follows:
- Eliminate the requirement for submissions of 300 Logs and 301 Reports,
- Maintain the proposed requirement that establishments with at least 20 employees and fall within a designated NAICS code be required to submit 300-A Summaries annually, but clarify the NAICS requirements,
- Maintain Annual Surveys of selected employers, which would allow OSHA to obtain supplemental data from specific industry sectors, and
- Agree to post the results of the submissions of the 300-A Summaries on OSHA’s website, without identifying the employers.
Related
Natural Gas & Power Industries’ Reliability Alliance:
Exploring Real-Life Challenges with Ensuring Natural Gas Availability for Power and Joint Industry Suggested Mitigation Strategies INGAA Comments on FERC NOPR on Cybersecurity Incentives for Electric Utilities INGAA Incident Reporting Comments INGAA API Petition for Consideration of Gas Transmission Final Rule
Exploring Real-Life Challenges with Ensuring Natural Gas Availability for Power and Joint Industry Suggested Mitigation Strategies INGAA Comments on FERC NOPR on Cybersecurity Incentives for Electric Utilities INGAA Incident Reporting Comments INGAA API Petition for Consideration of Gas Transmission Final Rule
