Recordkeeping

ORC Comments on OSHA Proposal on Recordkeeping for MSDs

ORC's comments in response to OSHA's Notice of Proposed Rulemaking to restore a column for recording of musculoskeletal disorders (MSD) on the OSHA 300 Log and other issues are attached below.

OSHA Extends Comment Period for Proposed Revision to Recordkeeping Rules

The Occupational Safety and Health Administration has extended the comment period on the proposed rule to revise the Occupational Injury and Illness Recording and Reporting (Recordkeeping) regulation to March 30, 2010.

OSHA published a proposed rule to revise its Recordkeeping regulation on January 29, 2010. The proposal would restore a column to the OSHA 300 Log that employers would use to record work-related musculoskeletal disorders (MSDs).

Recordkeeping: OSHA Proposes 300 Log Column and Guidance for Work-Related MSDs

On January 28, OSHA announced that it would publish a proposed rule to revise its Occupational Injury and Illness Recording and Reporting regulation (29 CFR 1904) to restore a column to the OSHA 300 Log that employers would use to record work-related musculoskeletal disorders (MSD). This proposed rule would require employers to place a check mark in the MSD column, instead of the column they currently mark, if a case is an MSD that meets the Recordkeeping regulation’s general recording requirements. The proposal appeared in the Federal Register on January 29, 2010 (see atta

OSHA Recordkeeping and H1N1 Influenza

On November 20, OSHA issued a Compliance Directive (CPL-02-02-075) establishing enforcement policies and providing instructions to its compliance officers for inspections designed to minimize high occupational exposure risk to the virus identified as 2009 H1N1 influenza among workers in healthcare and laboratory settings.  (See Directive at http://www.osha.gov/OshDoc/Directive_pdf/CPL_02_02-075.pdf.)  Included in the Directive is OSHA’s official interpretation of how to address H1N1 cases for recordability

GAO Report Finds Need for Improvements in OSHA's Records Audit Process

The General Accountability Office Report: In a recently issued report, Enhancing OSHA’s Records Audit Process Could Improve the Accuracy of Worker Injury and Illness Data, the Government Accountability Office (GAO) adds fuel to the current fire over alleged under reporting of occupational injuries and illness on the OSHA log.  Basically, GAO said that OSHA must step up auditing and enforcement efforts because employers had many incentives to under report injuries and illnesses.
 
GAO identified specific sources of bias that could discourage employ

Recordkeeping: OSHA Launches NEP to Crack Down on Underreporting

OSHA announced Oct. 1 it will begin a National Emphasis Program (NEP) on recordkeeping to identify and correct under-recorded and incorrectly recorded workplace injury and illness cases. The program took effect Sept. 30 and will expire in one year. It directs OSHA inspectors to scrutinize all injury and illness records during calendar years 2007 and 2008 for a sampling of employees at selected workplaces in historically high-risk industries. 

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.

Slide Presentation: "Recordkeeping Yet Again"

Slides to accompany April 14, 2009 teleconference are attached below. 

Obama's OSHA - Ready to Lead?

During his campaign for the presidency, Barack Obama made a number of pledges to "strengthen occupational safety and health" by increasing funding for OSHA inspections and training....

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