If luck doesn’t go your way and your company receives a recordkeeping inspection as part of OSHA’s new one-year National Emphasis Program (NEP) that has just started, the inspection will have three main components.

1) Records review of:

• All available records for each employee sampled (medical records, workers’ compensation records, absentee records, audiograms). Do not forget to insist that OSHA obtain a Medical Access Order before you release any records containing private medical information.
• The OSHA 300 log, 300A summary and 301 incident report (or the equivalent).

2) Interviews of:

• Employees, management, healthcare providers, etc.
• Management concerning the current recordkeeping process.
• Management concerning any incentive programs that may deter recording of injuries and/or illnesses.

3) Limited inspection walk-around:

• Investigate if recorded injuries and/or illnesses correlate with the actual work environment.
• Address and cite safety or health violations in plain view.

For further information on what to expect, refer to the post: Getting ready for an OSHA inspection.

If you need recordkeeping advice:

Employers may call me free of charge for a limited consultation about recordkeeping issues. Call me at (513) 317-5644.

This entry was posted on Tuesday, September 1st, 2009 at 8:56 pm and is filed under Enforcement, Recordkeeping. You can follow any responses to this entry through the RSS 2.0 feed. You can leave a response, or trackback from your own site.

3 Responses to “What to expect from OSHA’s new emphasis on recordkeeping”

1. Bob Sands says:

   September 2, 2009 at 9:07 pm

   Is the collection of real-time accident evidence/documentation (photos, video, audio etc.)a detrement or benefit to a company trying to comply with OSHA’s record keeping regulations. If we document our accidents heavily are we setting ourselves up for more scrutiny? Are there any existing or upcoming regulations that require us to gather such evidence documentation like photos/video etc.?
2. Mary says:

   September 3, 2009 at 8:00 am

   Does this NEP only apply to those establishments meeting the criteria? Or, can the inspection of any establishment be included under the NEP if the inspector believes the recordkeeping is not 100% compliant?
3. jim swartz says:

   September 13, 2009 at 11:17 am

   Jim…this is a great series of articles. It reflects the experience and quality of your approach to OSHA matters and safety. THX Jim Swartz