OSHA Begins Its National Emphasis Program on Recordkeeping
By: LORI-ANN C. JONES
January 2010
On September 30, 2009, the Occupational Safety & Health Administration (OSHA) implemented its National Emphasis Program (NEP) on recordkeeping in an effort to identify and correct under-recorded and improperly recorded cases of workplace injuries and illnesses. The NEP is a federal program and is limited to states under federal OSHA jurisdiction; however, the NEP strongly encourages state OSHA programs to conduct their own recordkeeping initiatives.
Over the next 12 months, OSHA will conduct inspections at establishments with a low rate of recorded injuries and illnesses operating in industries with historically high rates of such incidents. Specifically, employers with 40 or more employees in the following industries, as well as a sample of construction firms, will fall within the scope of this NEP:
- Animal (except poultry) slaughtering
- Scheduled passenger air transportation
- Steel foundries (except investment)
- Other nonferrous foundries (except die-casting)
- Concrete pipe manufacturing
- Soft drink manufacturing
- Couriers
- Manufactured home (mobile home) manufacturing
- Rolling mill machinery and equipment manufacturing
- Iron foundries
- Nursing care facilities
- Fluid milk manufacturing
- Seafood canning
- Marine cargo handling
- Copper foundries (except die-casting)
- Bottled water manufacturing
- Refrigerated warehousing and storage
- Motor vehicle seating and interior trim manufacturing
- Pet and pet supplies stores
- Poultry processing
- Support activities for animal production
The inspection will include a comprehensive review by OSHA Compliance Officers of medical records, workers’ compensation records, insurance records, payroll/absentee records, company safety incident reports, company first-aid logs, alternate duty rosters, and disciplinary records pertaining to injuries and illnesses. The review of records will ensure that each recorded injury and/or illness is properly and accurately entered on the employer’s OSHA Form 300 and OSHA Form 301.
Inspections will also include interviews of employees, management, recordkeepers, and health care providers. The interviews of the employees and management will determine whether the company has policies that discourage employees from reporting injuries and illnesses, such as an incentive or disciplinary program that might influence recordkeeping. The recordkeeper’s knowledge of OSHA injury and illness recordkeeping requirements will also be assessed during the interview process. Finally, a limited walk-around inspection will be done of main areas of the establishment to determine any hazards consistent with recorded injuries and illnesses and to address any observable violations.
If any OSHA recordkeeping violations are identified, citations and penalties may be issued. To prepare for these inspections and to prevent citations, employers should:
- Ensure that the company has an effective system for reporting injuries and illnesses that does not discourage employees from reporting work-related injuries and illnesses.
- Review incidents of injuries and illnesses that occurred in 2007 and 2008 to ensure that there is an appropriate OSHA form for each.
- Ensure that the company’s recordkeepers are properly trained on OSHA’s recordkeeping requirements.
Takeaway
OSHA implemented a National Emphasis Program (NEP) on recordkeeping to identify and correct under-recorded and improperly recorded cases of workplace injuries and illnesses. To avoid and prevent OSHA citations and penalties, employers should ensure that the company has an effective system for reporting injuries and illnesses, review past incidents to ensure that each was recorded properly, and train the company’s recordkeepers on OSHA’s recordkeeping requirements.