IEC Comments on OSHA’s Proposed Electronic Reporting Rule

IEC recently submitted comments and joined the comments of the Coalition for Workplace Safety to the Occupational Safety and Health Administration (OSHA) on a Notice of Proposed Rulemaking (NPRM) that proposes to eliminate the requirement for submission of some OSHA forms electronically but retain the requirement for the submission of others. In IEC’s statement, it supported the proposal to drop the requirement of employers with 250 or more employees to electronically submit Forms 300 and 301. However, IEC urged OSHA to also remove the requirement of submitting Form 300A. The NPRM proposes to retain this for establishments with 250 or more employees and those with 20-249 employees that are classified as being in a hazardous industry. In addition, IEC urged OSHA to drop the requirement of submitting Employment Identification Number and asked for additional clarification on post-accident drug testing and safety incentive programs.