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OSHA launches new National Emphasis Program (NEP) on injury and illness recordkeeping

Starting in August, OSHA began inspections at employers’ establishments with low incident rates in historically high rate industries, including a sampling of construction firms. The program is in response to last year’s Congressional hearings on the perceived problem of injury and illness underreporting. While the program is limited to states under federal OSHA’s jurisdiction, state-plan OSHA programs are encouraged to conduct their own recordkeeping enforcement efforts.

The inspections will include a review of medical files for both occupational and non-occupational cases for 2007 and 2008, including 301 forms, Workers’ Compensation forms, absentee reports, and audiograms for a selected sample of employees. Compliance Officers will also interview employees and members of management to determine both whether the employer has an effective system in place for reporting injuries and whether incentive programs discourage employees from reporting new cases.

Employers should prepare for an OSHA recordkeeping inspection by:
Reviewing the 2007 & 2008 300 logs and 301 incident reports for accuracy.

Compare all OSHA recordkeeping forms with any Workers’ Compensation reports and claims.

Ensure that the record keepers have been properly trained.

Review safety incentive programs and injury and illness reporting procedures for any evidence that these protocols discourage the reporting of work-related injuries.