NCC Comments on Reporting Rule Delay Proposal
The NCC filed comments the week of July 10, 2017, supporting OSHA's decision to delay the implementation of a rule entitled ‘‘Improve Tracking of Workplace Injuries and Illnesses’’ under which certain employers were required to submit the information from their completed 2016 Form 300A to OSHA electronically. OSHA's proposal would push back implementation from July 1, 2017 to December 1, 2017. OSHA also announced its intention to issue a separate, future proposal to reconsider, revise or remove parts of the prior final rule, and the NCC will convey its concerns during that proposal stage of the rulemaking process.
July 13, 2017
Docket No. OSHA–2013–0023, Room N–3653
U.S. Department of Labor
200 Constitution Avenue NW.
Washington, DC 20210
RE: Docket No. OSHA–2013–0023: Improve Tracking of Workplace Injuries and Illnesses: Proposed Delay of Compliance Date
The National Cotton Council (NCC) is the central organization of the United States cotton industry. Its members include producers, ginners, cottonseed processors and merchandizers, merchants, cooperatives, warehousers and textile manufacturers. A majority of the industry is concentrated in 17 cotton-producing states stretching from California to Virginia. U.S. cotton producers cultivate between 9 and 12 million acres of cotton with production averaging 12 to 18 million 480-lb bales annually. The downstream manufacturers of cotton apparel and home furnishings are located in virtually every state. Farms and businesses directly involved in the production, distribution and processing of cotton employ more than 125,000 workers and produce direct business revenue of more than $21 billion. Annual cotton production is valued at more than $5.5 billion at the farm gate, the point at which the producer markets the crop. Accounting for the ripple effect of cotton through the broader economy, direct and indirect employment surpasses 280,000 workers with economic activity of almost $100 billion. In addition to the cotton fiber, cottonseed products are used for livestock feed, and cottonseed oil is used as an ingredient in food products as well as being a premium cooking oil.
On May 12, 2016, the Occupational Safety and Health Administration (OSHA) published a rule entitled ‘‘Improve Tracking of Workplace Injuries and Illnesses’’ with an effective date of January 1, 2017 for the final rule’s electronic reporting
requirements. The final rule set an initial deadline of July 1, 2017, as the date by which certain employers are required to submit the information from their completed 2016 Form 300A to OSHA electronically.
OSHA has now proposed to extend the initial submission deadline for 2016 Form 300A data to December 1, 2017, to provide the new administration an opportunity to review the new electronic reporting requirements prior to their implementation and allow affected entities sufficient time to familiarize themselves with the electronic reporting system, which will not be available until August 1.
NCC supports the decision to delay the implementation of the rule. With the system not yet being available and with concerns over some parts of the rule, NCC is pleased to see OSHA proposing a delay.
OSHA has also announced its intention to issue a separate, future proposal to reconsider, revise or remove parts of the prior final rule. NCC will convey its concerns during that proposal stage of the rulemaking process. If you have any questions, please don’t hesitate to contact me at 703-745-7805.
National Cotton Council