Meeting Archive:
Get the Record Straight: OSHA's New Injury Recordkeeping E-Submission Rule


Meeting Description:

Get the Record Straight:

OSHA's New Injury Recordkeeping E-Submission Rule

 
Tuesday, June 7, 2016 at 1 PM ET
 
Presented by Eric J. Conn and Amanda R. Strainis-Walker

As the clock winds down on the Obama Administration, OSHA has been rushing out a series of proposed amendments to its Injury & Illness Recordkeeping regulations (29 C.F.R. Part 1904).  Among them is a new final rule to “Improve Tracking of Workplace Injuries and Illnesses,” which will require hundreds of thousands of employers to electronically submit their injury and illness logs (and in many instances, their detailed incident reports also) each year.  More importantly, for no apparent safety reason, OSHA intends to publish employers’ injury data and incident reports online.

Another rule working its way through the rulemaking process: “Continuing Duty to Maintain Up-to-Date and Accurate Injury & Illness Records,” would impose a continuing duty on employers to update and maintain accurate injury and illness logs for the entire five year period for which the current regulation requires employers to keep copies of their OSHA 300 logs and related forms. Essentially, this proposal extends OSHA’s statute of limitations period during which OSHA is allowed to bring an enforcement action alleging a violation of the recordkeeping standard from six months from the day of the recordable injury to five years.

Participants will learn the following:

  • Details of OSHA’s new final rule to require submission of injury and illness recordkeeping data
  • Requirements of OSHA’s proposed rule to extend its statute of limitations for recordkeeping violations
  • Potential impact of these two proposed recordkeeping rules
  • Status of rulemaking and the likelihood and timing for implementation
Details
Date: Tue, Jun 7, 2016
Time: 01:00 PM EDT
Duration: 1 hour 30 minutes
Host(s): Eric J. Conn and Amanda Strainis-Walker
 Presenter Information
Eric J. Conn
Speaker Photo

Eric J. Conn is a founding partner and Chair of the national OSHA • Workplace Safety Practice Group at the law firm Conn Maciel Carey PLLC, where he focuses his practice on all aspects of occupational safety & health law.  Mr. Conn represents employers in inspections, investigations and enforcement actions involving OSHA, the CSB, MSHA, EPA and state and local safety related agencies.  He also handles all aspects of OSHA litigation, from criminal prosecutions to appeals of citations. 

Mr. Conn also conducts and directs attorney-client privileged workplace safety audits, delivers safety training, and helps employers develop and implement compliant safety and health programs.  He writes and speaks extensively on safety & health law issues, including authoring chapters in multiple OSHA Treatises.


Amanda R. Strainis-Walker
Speaker Photo

Amanda R. Strainis-Walker is a partner with Conn Maciel Carey PLLC. She focuses on occupational safety and health (OSHA) law. Prior to private practice, she was a Presidential Appointee at the U.S. Department of Labor as a Special Assistant to the Assistant Secretary of Labor for OSHA, and then as an attorney in the Office of the U.S. Solicitor of Labor, where she advised her clients, OSHA and MSHA, on a diverse range of legal and regulatory issues.
 

For more information about our OSHA Practice Group, visit the OSHA Practice page on our website.  Also, check out our OSHA Defense Report blog.

 

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