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Seventeen pages of detailed comments are attached.
To briefly summarize. We argue that workplace injury and illness records should be made more widely available because releasing these data has substantial potential individual, research, policy, and economic benefits. However, OSHA has a responsibility to apply best practices to manage data privacy and mitigate potential harms to individuals that might arise from data release.
The complexity, detail, richness, and emerging uses for data create significant uncertainties about the ability of traditional ‘anonymization’ and redaction methods and standards alone to protect the confidentiality of individuals. Generally, one size does not fit all, and tiered modes of access – including public access to privacy-protected data and vetted access to the full data collected – should be provided.
Such access requires thoughtful analysis with expert consultation to evaluate the sensitivity of the data collected and risks of re-identification and to design useful and safe release mechanisms.