OSHA Starts NEP on Recordkeeping

Back in August of this year, Dave Schmidt, an economist in OSHA’s Office of Statistical Analysis, released details about OSHA’s $1 million, one year National Emphasis Program (NEP) for injury and illness recordkeeping at a National Advisory Committee on Occupational Safety and Health (NACOSH) meeting, and on Oct. 1, OSHA officially announced  that it was initiating this NEP.

The purpose of the NEP will be to protect workers by investigating certain employers for possibly under-recording workplace injuries and illnesses. The NEP will focus on industries with high injury and illness rates.

"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 will consist of three components: a records review, employee interviews and a limited safety and health inspection of the workplace.

1. Records review

  • Of ALL available records for each employee sampled (medical records, Workers’ Comp, absentee records, audiograms, etc.)
  • Of the OSHA 300 Log, 300A Summary and 301 Incident Report (or the equivalent) to verify accuracy

2. Interviews

  • With the recordkeeper, management, employees and health care providers
  • To find out about current incident recordkeeping processes
  • To determine whether incentive and disincentive programs might be set up in such a way that deters reporting

3. Limited safety and health inspection of the workplace

  • To determine if recorded incidences correlate with actual work environments
  • Will simultaneously address any observable safety violations

OSHA stated that this NEP will help the agency work with the Government Accountability Office (GAO) and the Bureau of Labor Statistics, which have both cited concerns about the accuracy of recorded workplace injury and illness estimates.

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