As part of President Obama’s “Open Government Initiative,” the Occupational Safety & Health Administration (OSHA) has proposed a new rule that would require employers with more than 250 employees to publicly file their injury and illness logs on a quarterly basis. OSHA has also proposed that all employers in industries with high injury rates publicly file their injury and illness reports once a year.

Under OSHA’s current recordkeeping rules, most employers (except who are otherwise exempt from the rules) are required to record eligible incidents on an OSHA Form 300 and prepare annual summaries. Although some employers in industries with high injury rates have to submit their annual summaries to OSHA, most employers are only required to maintain the records and produce them to OSHA upon request.

OSHA believes that the new rule will increase government transparency and help the agency better hold employers accountable for workplace injuries. However, critics believe that the proposed rule would lead to unfair conclusions or judgments about a company or particular industry. Undoubtedly, it will lead to an increased burden on large employers.

The public has 90 days, through Feb. 6, 2014, to submit written comments on the proposed rule. On Jan. 9, 2014, OSHA will hold a public meeting on the proposed rule in Washington, D.C. Click here for OSHA’s press release announcing the proposed rule.

Employers that would be covered by the proposed rule, especially those with significant OSHA Form 300s, should consider whether they (or industry or trade groups to which they belong) want to comment on the rule. Those same employers should start considering how such a rule would affect them and their business, and how they plan to comply with the rule if it goes into effect. Commenting and planning now, will do a lot more than merely griping later.