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TIA seeks comments on OSHA injury proposal

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The Tire Industry Association (TIA) is seeking comments from all segments of the tire industry regarding a proposal from the Occupational Safety and Health Administration (OSHA) to “Improve Tracking of Workplace Injuries and Illnesses,” in part by making the data available to the public.

During a recent informal public meeting and roundtable with OSHA in Washington D.C., organizations representing labor unions and industry groups spoke on the proposed rulemaking. TIA attended both of the meetings but did not make any public statements.

“If you read the summary of the proposed rule, it appears that OSHA is only interested in improving the collection of injury and illness data by establishing electronic reporting requirements,” remarked Roy Littlefield, TIA executive vice president.

“However, once you get deeper into the proposal, it becomes evident that the agency believes that public access to the data will somehow improve workplace safety. Now that we have a complete understanding of the proposed rule, we are asking everyone to either submit comments on their own or submit comments to TIA so they can be included with the association’s.”

TIA says currently, all employers with 11 or more employees must complete an Incident Report (Form 301) for each reportable injury and illness under 29 CFR 1904 and keep a record of all injuries in the Log of Work-Related Injuries and Illnesses (Form 300). Each year, every employer must use the information on those forms to complete the Summary of Work-Related Injuries and Illnesses (Form 300A).

These records are used by OSHA officials during inspections and the OSHA Data Initiative (ODI). The ODI is designed so that every employer with 20 or more employees in designated industries receives a survey once every three years, which is basically the information on Form 300A.

OSHA is proposing a change to the injury and illness reporting requirements starting with all employers covered by 29 CFR 1904 that have 250 or more employees. These large companies will have to electronically submit information for each establishment on a quarterly basis. Based on the language in the proposed rulemaking, OSHA is considering collecting the establishment-specific data from all three forms and making most of it public.

“We do not foresee any benefits of making injury and illness data accessible to the public and cannot understand why the Bureau of Labor Statistics is not allowed to release injury and illness data for privacy reasons yet those rules do not apply in this instance,” remarked Kevin Rohlwing, TIA senior vice president of training.

“OSHA’s mission is to set and enforce standards in addition to providing training, outreach, education and assistance, so the public access component of this proposal is not consistent with the goals of the agency. Making injury and illness data public will only contribute to under-reporting and create additional incentives for not reporting incidents at all.”

TIA says it believes the cost of gathering and entering the data is far more than estimated for all businesses with more than 20 employees. TIA is also seeking actual cost estimates from all affected businesses. Agency officials are accustomed to looking at data, which means TIA is totally dependent on the industry providing realistic cost estimates for the type of tracking, recordkeeping and entering of all injury and illness data.

Companies submitting comments on their own should provide a detailed cost analysis. Companies willing to provide TIA with a detailed or even general cost estimate should email it along with other comments to

TIA is also asking all affected businesses in the tire industry to either submit their own comments or provide TIA with a quote regarding the impact of this proposal. Quotes can be emailed to

The deadline for formal comments to OSHA is March 8, 2014. Therefore, TIA asks companies to submit quotes or comments to the association by Feb. 28, 2014.

For a copy of the official proposal as it appeared in the Federal Register, companies can use the following URL:

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