Comments on Occupational Injury and Illness Recording

On behalf of the Retail Industry Leaders Association (RILA), I would like to thank you for accepting our comments on the Occupational Safety and Health Administration’s (OSHA) Proposed Rulemaking for Injury and Illness Recording and Reporting Requirements--NAICS Update and Reporting Revisions. RILA’s comments will be limited to the Reporting Revisions of this proposed rule. While RILA recognizes the importance of reporting certain inpatient hospitalizations and amputations in helping the agency address serious work-related safety and health issues, the additional reporting requirements outlined in the proposed rulemaking are ambiguous and unrealistic, and would likely lead to a number of difficulties and challenges including over-reporting by retailers. These proposed revisions, if finalized, will result in the imposition of undue burdens on RILA members without any corresponding benefit to OSHA and its important mission.1 Specifically, RILA raises concerns with the following aspects of this proposed rule: (1) implications of lowering the threshold of in-patient hospitalization; (2) insufficient time for the collection of essential information; and (3) definition of amputations. We strongly believe the rule governing the reporting of inpatient hospitalizations in its current form is sufficient to enable OSHA to monitor serious workplace injuries and illnesses.