What to expect from OSHA’s new emphasis on recordkeeping

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.