OSHA Begins its National Emphasis Program to Check the Accuracy of Employer Injury and Illness Recordkeeping

The Occupational Safety and Health Administration (OSHA) announced that it has started its one-year national emphasis program (NEP) (pdf) on recordkeeping to assess the accuracy of injury and illness data recorded by employers. Under this program, OSHA inspectors will conduct audits of at most 50 employers with at least 40 employees. No more than five worksites will be targeted per OSHA region. Those selected will be employers in one of 21 named industries that have reported the highest rates of missed work, restricted work activity, or job transfers. Such industries include animal (except poultry) slaughtering, scheduled passenger air transportation, foundries, concrete pipe manufacturing, soft drink manufacturing, and couriers.

The audit will include a safety and health walkaround inspection of the workplace on the first day of the review. The compliance officers will examine the employees' records in order to identify occupational injuries and illnesses that may have occurred to those employees from 2007 to 2008. OSHA will then compare its findings to the records the employer provided to the agency to find any discrepancies. As part of the NEP, OSHA will review medical records, workers’ compensation records, insurance records, payroll/absentee records and, if available, company safety incident reports, company first-aid logs, alternate duty rosters, and disciplinary records pertaining to injuries and illnesses. The agency will also review records that are stored offsite. Additionally, the OSHA compliance officers will conduct interviews with employees, management, the record keepers, and medical staff. If recordkeeping violations are identified, the inspectors will propose citations and penalties.

Those employers that currently participate in OSHA’s Voluntary Protections Programs or Safety and Health Achievement Recognition Program (SHARP) will be exempt from the NEP.
 

Information contained in this publication is intended for informational purposes only and does not constitute legal advice or opinion, nor is it a substitute for the professional judgment of an attorney.