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STATEMENT: NRCA Expresses Concerns Regarding OSHA's Proposed Rule to Improve Tracking of Workplace Injuries and Illnesses

For Immediate Release CONTACT: Charlotte Norgaard
Date: Jan. 9, 2014 (847) 493-7548

STATEMENT: NRCA Expresses Concerns Regarding OSHA's Proposed Rule to Improve Tracking of Workplace Injuries and Illnesses

This statement is attributable to: William Good, Executive Vice President, National Roofing Contractors Association

In light of today's public hearing on the Occupational Safety and Health Administration's (OSHA) proposed rule to improve the tracking of workplace injuries and illnesses, the National Roofing Contractors Association (NRCA) has concerns regarding several items, assertions and potential implications in the new rule. NRCA is troubled that OSHA has not provided sufficient details regarding safeguards for the database required under the regulation to ensure that workers' personal information in records uploaded is secure as required under federal and state privacy laws.

No evidence has been presented by OSHA of its ability to use the information required to be uploaded in an efficient and effective manner to prevent injuries or illnesses, and it appears that the agency has not even considered the implications of unrestricted access to a database by those whose motivations have no connection to worker safety.

In addition, the benefits of this proposal, in NRCA's view are purely speculative and not supported by empirical data sufficient to justify the significant costs for its implementation.

As an example, OSHA states that compliance by companies in designated industries with 20 or more workers under the proposed rule will amount to $9 annually per establishment. The Bureau of Labor Statistics (BLS) reports that the mean hourly wage for an office clerk is $14.07 so that the time required to log in to the secured agency website, enter data directly or upload a file must be around 38 minutes for a worker performing the task at that wage. However if the task if performed by a human resource manager making the mean hourly wage of $52.69 as reported by BLS, the task would have to be performed in a little over 10 minutes to keep costs within the $9 OSHA estimate. With the construction industry trying to regain its footing after years of unfavorable economic conditions, a new, costly recordkeeping obligation that has no empirical benefits is not conducive to business or worker health.

While NRCA applauds the good intentions of the proposal, we feel that adding employer reporting burdens that promise unspecified and elusive benefits diverts valuable resources from proven risk management protocols that conclusively protect workers. NRCA respectfully suggests that OSHA withdraw this proposed regulation.

As always, NRCA remains willing to work with OSHA on alternative approaches to improving worker safety that have the potential to be effective and reflect input and collaboration with our employer members.


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