A proposed revision to OSHA's recordkeeping rules could require employers with multiple worksites to collect injury and illness information from each site for the regulatory agency. While the current law requires each worksite to collect its own data and submit it to OSHA as requested, the company-wide mandate would improve employer awareness oversight of workplace safety, the agency said.

A proposal from the Occupational Safety and Health Administration (OSHA) could require companies with as few as 50 employees at multiple worksites to submit company-wide illness and injury information under the agency's recordkeeping rules.

According to the Occupational Safety & Health Reporter, the mandate is included in the agency's proposed revision to regulations that dictate how and when employers must submit injury and illness reports.

The revision would shift the responsibility to report from individual "establishments" to a company-wide model, in which employers with multiple worksites would be responsible for collecting and submitting the data. Under the current rule, a retail store or warehouse, for example, is responsible for keeping its own injury and illness logs and providing them to OSHA upon request. The "enterprise-wide" proposal included in the Federal Register notice (78 Fed. Reg. 67,271) would require companies to collect logs of work-related injuries, or OSHA Form 300A data, from each of its stores, warehouses and the like, and submit the data for each establishment to OSHA upon the agency's request.

As mentioned above, the proposed change would apply to employers with as little as 50 employees across multiple worksites. The revision also requires employers in high-hazard industries with 20 or more workers to submit Form 300A information annually, the Reporter said.

Multiple issues – including how OSHA would define which companies would be required to collect the data, and how large employers would have to be to trigger the reporting requirement – will affect the mandate's future, and while the rule change is listed as an "alternative" within the agency's larger recordkeeping revision scheme, insiders say the proposal's potential is pertinent to interested parties.

Additional alternatives considered in OSHA's Federal Register filing include revising the quarterly submission requirements of data to either an annual or monthly submission requirement; phase-in requirements of electronic reporting; and adjusting the scope of establishments required to report data to the agency.

OSHA extended the written comment period for the proposed rule changes through March 8. The comment period was extended beyond the original deadline of February 6 at the request of the National Association of Homebuilders.