As noted above, OSHA has begun an aggressive new program of enforcement of the OSHA Recordkeeping requirements.
 

U.S. Labor Department’s OSHA begins National Emphasis Program on recordkeeping to determine accuracy of worker injury and illness data WASHINGTON - The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) is initiating a national emphasis program (NEP) on recordkeeping to assess the accuracy of injury and illness data recorded by employers. The recordkeeping NEP involves inspecting occupational injury and illness records prepared by businesses and appropriately enforcing regulatory requirements when employers are found to be under-recording injuries and illnesses. ”

Accurate and honest recordkeeping is vitally important to workers’ health and safety,” said acting Assistant Secretary of Labor for OSHA Jordan Barab. “This information is not only used by OSHA to determine which workplaces to inspect, but it is an important tool employers and workers can use to identify health and safety problems in their workplaces.” The inspections include a records review, employee interviews, and a limited safety and health inspection of the workplace. The NEP will focus on selected industries with high injury and illness rates.

This directive is available at https://www.osha.gov/OshDoc/Directive_pdf/CPL_02_09-08.pdf. 

At the request of the Senate Committee on Health, Education, Labor and Pensions and the House Committee on Education and Labor, the Government Accountability Office (GAO) issued a study on the accuracy of employer injury and illness records. This NEP will help OSHA work cooperatively with the GAO. It also complements the Labor Department’s Bureau of Labor Statistics’ (BLS) efforts to investigate factors accounting for differences between the number of workplace injuries and illnesses estimated by BLS and those estimated by other data sources.

http://www.dol.gov/opa/media/press/osha/osha20090775.htm

To summarize the information above, OSHA plans to identify under-recording of occupational injuries and illnesses by doing statistical analysis to identify employers who report low injury/illness rates but which are in historically high rate industries. OSHA inspectors will also be giving careful scrutiny to recordkeeping during their normal on-site inspections.

POINT TO REMEMBER: Managers should make sure that the administrative personnel who maintain their accident records and OSHA log really understand what they are doing and record injuries and illnesses accurately.

For details, see the OSHA Recordkeeping Handbook, Section 1904.4 (Recording criteria) and Section 1904.5 (Determination of work-relatedness) here: 

http://osha.gov/recordkeeping/handbook/index.html

Everything you ever wanted to know about OSHA Recordkeeping and more (OSHA’s Recordkeeping gateway):

http://osha.gov/recordkeeping/index.html

Consult your RCI Loss Control Specialist if you have questions about determining work-relatedness.

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