What concerns pros is not submitting records electronically. Or making company injury/illness records public even. Little known provisions of the rule aim to prevent employers from bullying or intimating workers from reporting injuries. Pros are concerned that safety incentive programs may be deemed by OSHA compliance officers as suppressing injuries in order to win awards.
And pros are concerned that OSHA's warning about using post-injury drug testing without probable cause could result in confusion over when drug testing is permissible and when it is considered a form of intimidation or retaliation against a "bad" employee.
OSHA has created headaches with this rule for safety professionals, said one attendee. There will be many citations contested, going through the OSH Review Commission, he predicted.