NC State University MESH: Will OSHA's Recordkeeping Emphasis Target Your Company?

Will OSHA's Recordkeeping Emphasis Target Your Company?

What do Mobile Home Manufacturers, Nursing Homes and Marine Cargo Handlers have in common? They, along with 19 other industries, appear on OSHA’s list of industries being targeted for recordkeeping compliance.

In light of several studies suggesting that businesses may be under-reporting workplace injuries and illnesses, OSHA has announced plans to initiate a national emphasis program (NEP) on recordkeeping!In the press release, acting Assistant Secretary of Labor for OSHA Jordan Barab stated that “accurate and honest recordkeeping is vitally important to workers' health and safety” and indicated that OSHA’s plan involves (1) inspecting occupational injury and illness records prepared by businesses and (2) enforcing regulatory requirements when employers are found to be under-recording injuries and illnesses.

According to the directive released by OSHA, inspections will include a comprehensive records review, employee interviews, and a limited workplace inspection. Records that will be reviewed include medical records, worker’s compensation records, insurance reports, and payroll/absenteeism records. OSHA’s Compliance Officers will use information from these records and interviews with staff to independently construct Form 300 Log entries which will then be compared to the recordable case entries on the employers From 300 Log.

Are you confident of what gets recorded? Consider this: At a company-sponsored Pizza Party celebrating your company’s exemplary safety record, an employee burns the roof of his mouth on the hot cheese! Under OSHA 29 CFR 1904 is this a recordable injury? Submit your answers, thoughts and opinions below.

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