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.