Oct 1, 2018· Comment from Bozek, C. Richard; Edison Electric Institute (EEI)· OSHA-2013-0023-2079
The Edison Electric Institute appreciates the opportunity to submit the attached comments in response to the proposed revisions to Tracking of Workplace Injuries and Illnesses, (83 Fed. Reg. 36,494) published by the Occupational Safety and Health Administration on July 30, 2018. The proposed revisions affect the Final Rule, entitled Improve Tracking of Workplace Injuries and Illnesses, 81 Fed. Reg. 29,623-94 (May 12, 2016), revised at 81 Fed. Reg. 31,854 (May 20, 2016).
Jul 14, 2017· Comment from Bozek, C. Richard; Edison Electric Institute (EEI)· OSHA-2013-0023-1899
Edison Electric Institute appreciates the opportunity to comment, and supports OSHA's proposal to extend the compliance date for submitting OSHA 300A forms electronically from July 1 to December 1, 2017 and also recommend a further delay in the compliance date should the portal not be available by August 1. EEI also recommends that OSHA reconsider its plans to publish electronically-submitted injury and illness records especially since OSHA has not provided quantifiable or otherwise supported reasoning that doing so would reduce workplace injuries and illness. Moreover, there remains the broader and unanswered question whether such dissemination is permissible under the Occupational Safety and Health Act. On a more practical level, the agency is aware of, but has not spoken to, whether it intends to require (and publish) the signature, title and phone number of company executives and all other company personnel that provide information to complete these forms. Publishing this type of personal information, especially without clearly stated reasoning on how it helps reduce workplace injuries and illness warrants a much more thorough discussion and may even have a chilling effect on reporting. For these reasons, EEI supports OSHA's proposal to extend the compliance date or submitting OSHA 300A forms electronically from July 1 to December 1, 2017 and reconsider these important matters.
See attached file(s)
Dec 5, 2013· Comment from Kelly, Charles ; Edison Electric Institute· OSHA-2013-0023-0074
I request to attend the public meeting as an observer. Contact information is as follows.
Charles J. Kelly
Director, Industry Human Resource Issues
Edison Electric Institute
701 Pennsylvania Ave, NW
Washington, DC 20004
ph) 202-508-5155
e-mail: ckelly@eei.org