In June 2011, the U.S. Occupational Safety and Health Administration (OSHA) announced in a Notice of Proposed Rulemaking (NPRM) the agency’s plan to update requirements under its recordkeeping rule, including removing some partial exemptions for certain employers in order to increase the number of employers who will be covered under the rule.

More recently, at the end of September 2011, OSHA reopened the NPRM to extend the commentary period on revising its recordkeeping and reporting requirements for work-related injuries and illnesses. Employers and other entities interested in submitting comments on how the revised requirements might affect them had until this past Friday, Oct. 23, 2011, to do so. The proposal can now move forward to the final rule-making phase.

The proposed reporting requirement revises OSHA's current regulation that requires an employer to report to OSHA, within eight hours, all work-related fatalities and in-patient hospitalizations of three or more employees.  Under the revised proposal, employers would be required to report to OSHA any work-related fatalities and all in-patient hospitalizations within eight hours, as well as work-related amputations within 24 hours.  Reporting amputations is not required under current regulations.

OSHA is also proposing to update Appendix A of the recordkeeping rule (Part 1904 Subpart B) that lists industries partially exempt from the requirements to maintain work-related injury or illness logs. These industries received partial exemption because of their relatively low injury and illness rates.

The current list of industries is based on the Standard Industrial Classification (SIC) system. The North American Industry Classification System (NAICS) was introduced in 1997 to replace the SIC system for classifying establishments by industry. When OSHA first issued the recordkeeping rule in 2001, the agency used the old SIC code system because injury and illness data were not yet available based on the NAICS. With this data now available under the NAICS system, OSHA may now incorporate more precise industry classifications when the revised rule is published. Finally, OSHA is also updating Appendix A in response to a 2009 Government Accountability Office (GAO) report recommending that the agency update the coverage of the relevant recordkeeping requirements from the old SIC system to the newer NAICS.

With OSHA ramping up reporting requirements, now is a good time to procure a copy of Personnel Concepts' Injury and Illness Prevention Program to ensure your company stays in full compliance.