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TIA seeks comment on OSHA injury, illness data proposal

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BOWIE, MD. (Feb. 6, 2014) — The Tire Industry Association (TIA) is asking its members and all other segments of the tire industry to comment on a proposed rule from the Occupational Safety and Health Administration (OSHA) that would make employers' injury and illness data available to the public.

OSHA published the document in the Nov. 8, 2013, Federal Register. "The purpose of this rulemaking is to improve workplace safety and health through the collection of useful, accessible, establishment-specific injury and illness data to which OSHA currently does not have direct, timely and systematic access," the proposal said.

However, TIA is concerned specifically about the changes to the protocol in which employers submit injury and illness data to the public, the association said.

Currently, companies with 11 or more employees must complete an incident report for every reportable injury or illness within their workplaces. They must file annual summaries of work-related injuries to OSHA, which the agency uses during inspections and to compile its OSHA Data Initiative (ODI).

The ODI is designed so that every employer in designated industries — including tire dealers and retreaders — receive a survey from OSHA once every three years, according to TIA.

OSHA is proposing that all companies with 250 or more employees be required to electronically submit quarterly injury and illness every quarter.

The agency is considering making most of this data public, and though it proposes to "scrub out" personal information to protect employees' privacy, it would not do the same for employers, TIA said.

Tire dealers, retreaders and other designated employers with 20 or more employees would be required to submit the annual summary of work-related injuries electronically, TIA said.

This would replace the current ODI—meaning that the reporting requirements for smaller employers would essentially triple, TIA said. "And like the companies with more than 250 employees, all of the information could be made available to the public," it said.

"Making injury and illness data public will only contribute to under-reporting and create additional incentives for not reporting incidents at all," said Kevin Rohlwing, TIA senior vice president of training.

TIA is interested in receiving comments from all sectors of the tire industry to prepare a unified industry submission to OSHA. The association particularly wants to see employers' estimates of the annual costs of compliance with the rule.

OSHA estimates that annual compliance costs will be $183 per year for employers with 250 or more employees, and $9 per year for those with 20 or more employees.

TIA, however, said it believes these estimates are much too low, especially for tire dealership chains with stores in multiple states.

March 8 is the deadline for formal comments to OSHA. TIA is asking interested parties from within the tire industry to submit their comments to the association by Feb. 28.

For a copy of the official proposal as it appeared in the Federal Register, companies can access the document here.

For a copy of the extension of the comment period and the information regarding the submission of comments, click here.

A copy of TIA's summary of the proposal and initial concerns is available by emailing

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