Recordkeeping NEP: OSHA Releases Details on Program Slated to Begin in August

OSHA is about to launch a year-long National Emphasis Program (NEP) of on-site inspections at several hundred facilities to review injury and illness records from 2007 and 2008. Details of the $1 million program were revealed at a July 15 meeting of the National Advisory Committee on Occupational Safety and Health by Dave Schmidt, an economist in OSHA’s Office of Statistical Analysis.

The NEP will target low injury and illness rate establishments of 40 or more employees in historically high rate industries, such as animal slaughtering, steel foundries, soft drink manufacturing and nursing homes. Inspections will have three main components:

1. Records review of a sample drawn from the 2007 employee roster
2. Interviews
3. Limited ‘walkaround.’

Mr. Schmidt explained that the records review would include all available records for each employee sampled, e.g. medical records, Workers’ Compensation, absentee records, audiograms and OSHA Form 301. In many cases OSHA will also look at the records of off-site clinics used by the targeted establishment.

The OSHA inspectors will interview the person responsible for recordkeeping, management, employees, and the health care provider. Mr. Schmidt provided details on how each of these interviews would be conducted. When interviewing management personnel, for example, OSHA will seek to identify and obtain written copies of policies concerning incentives and disincentive programs that could affect reporting cases. Managers will not have access to employee interviews.

Schmidt said OSHA is currently training CSHOs, expects to begin implementation of the NEP in August, and will complete it one year later. He identified four topics OSHA will be analyzing:

• Effectiveness of targeting
• Prevalence of under-recording
• Employer policy to discourage reporting
• Incentive programs.

A copy of Mr. Schmidt’s presentation is attached below.