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1996

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Subject:
From:
"Holly Lynch" <[log in to unmask]>
Date:
Tue, 23 Apr 1996 12:10:09 -0700
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On February 2, 1996, the U.S. Occupational Health and Safety Administration
proposed a new OSHA recordkeeping and reporting rule that OSHA claims will
simplify and improve the current recordkeeping process.  That rule was
published in the Federal Register at 61 FR 4030.

Although OSHA's objectives are worthy, IPC and other industry groups are
concerned that the proposed rule would not simplify the OSHA recordkeeping
process and would actually make federal OSHA information less credible and
accurate.

The proposed rule would make a number of changes to current OSHA recordkeeping
definitions.  For example, the current definition of "lost workdays" would be
replaced with a definition of "days away from work."  Under the proposed rule,
OSHA would not require employers to count holidays or weekend days in the "days
away from work"; however, OSHA is requesting comment on requiring employers to
count such days for simplification reasons.  In addition, OSHA is proposing
that the definition of "first aid" covr only specific treatments.  Under the
proposed rule, all else would constitute medical treatment and, therefore,
would be recordable.  The proposed rule would also add new year-end reporting
requirements on employers, decrease the records retention period from five to
three years, and require employers to update their injury and illnes records
during that period.

Industry is opposing a number of specific provisions of the proposed rule
including a proposal that would allow anyone access to personal employee
information.  Industry contends that such a change would allow personal ijury
attorneys and unions to gather information for ulterior motives.  In addition,
the proposed rule would make a number of symptoms recordable absent any
evidence that an injury/illness has occurred.

IPC will be submitting comments on behalf of the industry to OSHA by the May 2,
1996 deadline.  A draft of the comments will be due later this week.  If you
would like a copy of the proposed rule, please contact Star Summerfield at
IPC's Northbook, IL office.  Her e.mail is [log in to unmask]  If you would like a
copy of IPC's draft comments (or final -- if after the May 2nd deadline),
please contact Holly Lynch at IPC's Washington office.  Her e.mail is
HollyLynch @ipc.org     Also, if you have any questions, please contact Holly.
 Her phone number is (202) 638-6219.



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