TIA opposes OSHA injury tracking proposal

Posted on March 10, 2014

The Tire Industry Association (TIA) cited methodology concerns and economic costs of a proposal by the Occupational Safety and Health Administration (OSHA) to make workplace injury and illness data available to the public in comments opposing the proposal.

In the comments on the proposed “Improve Tracking of Workplace Injuries and Illnesses” rule, TIA Senior Vice President of Training Kevin Rohlwing states, “while TIA supports OSHA’s laudable goal of promoting safe and healthy working conditions for American workers, we would like to register our strong opposition to the rule as proposed and suggest that the agency withdraw this proposal.”

TIA says the proposed rule would require electronic submission of injury and illness data from employers that are already required to maintain the information under existing OSHA regulations in three specific instances: 1) establishments with 250 or more employees would be required to file data on quarterly basis, 2) establishments with 20 or more employees would be required to submit information from the OSHA annual summary form (form 300A) on an annual basis and 3) employers who receive notification from OSHA to submit specified information from their Part 1904 injury and illness records.

These electronic submissions would then be accessible by the public via the OSHA website.

TIA says it expressed concern with the conceptual methodology underlying the rule and the economic costs associated with compliance. OSHA has estimated the additional economic costs of $183 per year for establishments with 250 or more employees. TIA believes this figure is significantly underestimated and provides its own estimate of $2,064 that was calculated based on data submitted from a TIA member. 

In its comments, TIA also included answers to numerous questions that the agency has raised regarding the proposal. The full document can be viewed at

Related Topics: Kevin Rohlwing, OSHA proposal, workplace injury and illness tracking

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