WASHINGTON — The Independent Bakers Association has asked the Occupational Safety and Health Administration not to make further changes to the recordkeeping process and for OSHA not to require electronic filing.

The I.B.A. made its case in formal comments submitted in response to OSHA’s request for input on improved recordkeeping collection on injury and illness data.

“I.B.A. is concerned with possible changes to OSHA injury and illness data collection method,” said Nicholas A. Pyle, president of the I.B.A. “I.B.A. is worried that any changes would only complicate the current filing procedures. Changing collection methods, such as requiring submission of forms electronically, will likely produce more flaws in reporting and require a monumental task to train businesses on proper record keeping.”

Mr. Pyle expressed particular concern that proposed changes would be especially deleterious to small business.

“They will require the most amount of extra training for any changes and will feel the brunt of the extra cost to move to the electronic reporting if required,” he said. “Smaller businesses also are more likely to have limited electronic capabilities, making electronic recordkeeping difficult. The only way that small business could be spared the impact of requiring electronic submission of records or other potential changes would be to ask the taxpayers for additional money to fund computers, training and additional employees for these small employers.”

Mr. Pyle said the only recordkeeping data that should be gathered are what already is done for the Bureau of Labor Statistics, states and the National Safety Council.

No other data should be linked because of possible problems that may arise such as legal implications associated with access to medical files.

The I.B.A. said that should any changes in recordkeeping be made, they should be crafted in a way to give smaller business greater flexibility.

OSHA has scheduled two meetings to discuss the potential recordkeeping changes. The first was set for May 25 in Washington, and the second will be held June 3 in Chicago.

Written comments must be submitted by June 18, 2010.

According to OSHA, it “needs to gather information from stakeholders in order to be able to modify its current injury and illness recordkeeping regulation and develop a modernized recordkeeping system in ways that will help OSHA, employers, employees, researchers, and the public prevent workplace injuries and illnesses as well as, supporting President Obama’s Open Government Initiative, increase the ability of the public to easily find, download, and use the resulting dataset generated and held by the federal government.”

Earlier, OSHA had proposed to revise its Occupational Injury and Illness Recording and Reporting (Recordkeeping) regulation to restore a column to the OSHA 300 Log that employers would use to record work-related musculoskeletal disorders (M.S.D.).

“The 2001 Recordkeeping final regulation included an M.S.D. column, but the requirement was deleted before the regulation became effective,” OSHA said. “This proposed rule would require employers to place a check mark in the M.S.D. column, instead of the column they currently mark, if a case is an MSD that meets the recordkeeping regulation's general recording requirements.”
The proposal was strongly opposed by the baking industry.