You know that dream, where you’re somewhere in public and you suddenly realize you’re only half-dressed or even naked? A new proposal from OSHA outlined on a call with Dr. David Michaels today might have a lot of companies feeling that way.

OSHA is proposing a new rule, “Improve Tracking of Workplace Injuries and Illnesses,” which will amend its current recordkeeping regulations to require the nation’s 38,000 establishments with more than 250 employees (and that already are required to keep records) to electronically submit the records on a quarterly basis to OSHA. The 440,000 U.S. companies with more than 20 employees but fewer than 250 that are in certain industries with high injury and illness rates will be required to electronically submit their summary of work-related injuries and illnesses to OSHA once a year.

According to Michaels, “The proposal does not add any new requirement to keep records; it only modifies an employer’s obligation to transmit these records to OSHA.”

Since employers already are required to keep this data, what’s the big deal? Here’s the rub: OSHA plans to eventually post the data online. The agency believes that timely, establishment-specific injury and illness data will help it target its compliance assistance and enforcement resources more effectively by identifying workplaces where workers are at greater risk.

Michaels claimed the data the agency receives from employers under the proposed rule will not be used for enforcement purposes. However, he admitted that the agency, along with its state partners, only has enough compliance officers to inspect companies – on average – once every 100 years.

Amanda Wood, director of Labor and Employment Policy at the National Association of Manufacturers (NAM), said in an interview with EHS Today that public disclosure of injury and illness rates by company name won’t “further the end game to achieve safer workplaces.”

OSHA already has tools in place to improve workplace safety, added Wood – tools such as current injury and illness reporting requirements, the ability to inspect workplaces and the ability to work with employers on a consultative basis.

“These tools are present and they’re working,” she said. “Disclosing [specific injury and illness data] could lead to unfair characterizations of businesses by people who just see a statistic and don’t know the circumstances behind it."

“It’s about reputation,” added Matt Lavoie, senior director of media relations for NAM. “Reputation is currency for a company and it truly does matter and you can’t get an accurate picture from some numbers on a page.”

“Manufacturers have a No. 1 goal of safe workplaces and we want to work with OSHA in a collaborative manner,” said Wood. “We need best practices, not additional regulations, at this time.”

Michaels believes the new proposed reporting requirements will improve workplace safety: “Much of the [injury and illness] data never leaves the workplace, and we want to change that,” he said, adding the data will help the agency “better target” establishments with high injury rates and high rates of specific injuries, while allowing for “fewer inspections at employers with low rates of serious injuries.”

The announcement follows the Bureau of Labor Statistics’ release of its annual Occupational Injuries and Illnesses report, which estimates that 3 million workers were injured on the job in 2012.

“In some industries, one in 20 workers is injured. That should not be acceptable in the United States today,” said Michaels. “Three million injuries are 3 million too many. With the changes being proposed in this rule, employers, employees, the government and researchers will have better access to data that will encourage earlier abatement of hazards and result in improved programs to reduce workplace hazards and prevent injuries, illnesses and fatalities.”