Today's blog post is from PJ Schoeny, product manager for MSDSonline's Incident Management Solution which helps customers manage their OSHA Recordkeeping, track near misses, and follow up incidents with corrective actions. Schoeny has been tracking the recent NPRM and talking to stakeholders via webinars he hosts on OSHA Recordkeeping. Below, PJ talks about the question he's hearing most, and what we know at this point.
OSHA issued their NPRM on Electronic Recordkeeping on Nov. 8, 2013. The most-scrutinized provision of the NPRM requires covered employers with 250+ employees to submit their OSHA 300 and 301 Forms each quarter. However, the number one question, which OSHA acknowledges, is how will that “250+” apply to organizations with multiple establishments. Currently, each establishment is required to maintain separate 300 and 301 Forms. However, by counting all employees throughout an “enterprise,” OSHA stands to garner more data than they would by only looking at individual establishments.
For example, an enterprise has 250 employees, or 50 employees at each of their 5 establishments. Separately, the establishments would not be required to submit under the proposed rule, but will OSHA ask the enterprise to submit instead? And in that case, who is responsible for submitting – the individual establishments where the forms are maintained, or the corporate enterprise? And could this result in duplicate submittals? And will it result in a change to the rule where 300 and 301 data is required to be gathered at the enterprise level?
There are a lot of questions – look to see some answers after the January 9th public hearing with OSHA in Washington D.C., or after the public comment period ends on February 6th. Be sure to check back on our blog on January 10, 2014 for an update on this important issue.