Regulatory review

NRCA advocates for the roofing industry during the Trump administration's review of OSHA regulations


As the Trump administration reviews many of the Occupational Safety and Health Administration (OSHA) regulations issued under the Obama administration, NRCA continues working to address roofing industry employers' concerns. Significant progress is being made to modify or clarify OSHA standards and reduce burdens on employers without compromising employee safety.

Workplace injuries and illnesses

In its Spring 2018 Regulatory Agenda, OSHA indicated it was considering revisions to its "Improve Tracking of Workplace Injuries and Illnesses" regulation. Issued in May 2016, the regulation requires employers to electronically submit workplace injury and illness records to OSHA. Companies that have 250 or more employees in high-hazard industries (including roofing) must electronically submit OSHA Forms 300, 300A and 301 annually; companies that have between 20 and 249 employees only are required to submit OSHA Form 300A annually. The regulation also requires employers to inform employees of their right to report workplace injuries and illnesses and prohibits discrimination against employees who do so.

NRCA and its members have had serious concerns with the regulation since it was first proposed in 2014. These concerns include the possible misuse of private employee information contained in submitted forms by third parties that potentially could gain access to them; new costs associated with the submittal requirements for employers without any discernible improvement in workplace safety; and significant ambiguity in the anti-discrimination provisions that could cause uncertainty and problems for employers and employees. NRCA outlined these concerns in comments filed with OSHA before the regulation was issued, and NRCA testified before the House of Representatives' Subcommittee on Workforce Protections, which has oversight authority over OSHA, to make Congress aware of NRCA members' views. Despite NRCA's efforts, OSHA issued the final regulation in 2016.