RISK INSIGHT: OSHA Proposed Rule for the Protection of PII

On July 27, 2018 the Department of Labor’s Occupational Safety and Health Administration (OSHA) issued a Notice of Proposed Rulemaking regarding the protection of Personally Identifiable Information (PII) that may be exposed through OSHA’s electronic record submission requirement.

The “Improve Tracking of Workplace Injuries and Illnesses” rule requires employers with more than 250 employees to submit Forms 300 and 301 regarding work-related injuries and illnesses electronically. The proposed rule eliminates this requirement and would only require employers to submit OSHA Form 300A which is a summary of work-related injuries and illnesses. Since this is a proposed rule, the update will need to follow the normal rulemaking process. That process will include developing the rulemaking record, developing the final rule, publishing the final rule and implementing the final rule.

The original deadline for submission was July 1, 2018. However, OSHA is not accepting Forms 300 and 301 and will not enforce any deadlines for submission of these forms while the rule-making process is underway. Employers should continue to submit Form 300A as required.

If you need additional assistance, have questions about OSHA recordkeeping please feel free to contact your M3 Account Executive or Risk Manager for more information.

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