The Independent Bakers Association (IBA) responded to the Occupational Safety and Health Administration (OSHA) request for input on improved recordkeeping collection on injury and illness data. It expressed concern that implementing mandatory electronic filing would introduce errors into and complicate the filing process and could result in extra expense to small businesses that do not possess the necessary equipment, manpower and training to file electronically.

The IBA also submitted the following comments:

• The only recordkeeping data that should be collected are those already collected for BLS, states and National Safety Council. 
• No other recordkeeping data should be linked because of possible problems that might arise. For example, access to medical files would have legal implications.
• Data should be collected only based on current recordkeeping requirements and if any changes were made that smaller businesses should be allowed greater flexibility.
• The data collected should be treated as statistical data and not as estimates.