RIMS is advising the risk management community to review and prepare for new rules regarding electronic recordkeeping of workplace injuries. The new rules, released by the Occupational Health and Safety Administration (“OSHA”), will take effect August 2016.

In 2014, RIMS issued an official comment letter on proposed OSHA rules regarding recordkeeping requirements for workplace injuries. RIMS said that although OSHA acknowledged its recommendations as noted in the final ruling, some of the concerns it raised were not addressed. RIMS said that it intends to continue to work with OSHA as it develops the final electronic reporting process.

RIMS's concerns regarding OSHA's new rules include:

- The cause of a workplace injury will be ambiguous, potentially creating misconceptions about an organization's workplace safety.

- Publishing employee injuries can increase litigation against an organization.

- Publishing employee injuries can be used against an organization by industry competitors.

- OSHA's web-based reporting application presents additional cyber exposures.

- Employers will, most likely, stop trending minor incidents to lower incident rates.

“Risk practitioners are always eager to implement new systems and processes to help streamline their programs and create more transparency for senior leadership and stakeholders,” said RIMS president Julie Pemberton. “RIMS appreciates the work that OSHA has done to make claims reporting more transparent but, like all new systems, there are challenges that risk professionals will need to overcome. We look forward to continuing our work with the agency to ensure that organizations' ability to effectively and efficiently manage risk are not compromised.”

The new reporting requirements will be phased in over two years with organizations with 250 or more employees in industries covered by the recordkeeping regulation. They will be required to submit information by July 2017 and again in July 2018. Beginning in 2019 and every year thereafter, the submission date will change to March 2. Organizations with 20-249 employees in certain high-risk industries must submit on a similar schedule.

Learn more: www.rims.org.

Victoria Spears

Victoria Spears

Victoria Prussen Spears is senior vice president of Meyerowitz Communications Inc., a law firm marketing communications consulting company. A graduate of Sarah Lawrence College and Brooklyn Law School, Ms. Spears was an attorney at a leading New York City law firm before joining Meyerowitz Communications. She may be contacted at [email protected].

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