WSP warns of tighter OSHA Recordkeeping | 7th Jan 2011
Manufacturers, organizations with large worksites and employers with high injury rates are increasingly under the microscope of the Occupational Safety & Health Administration (OSHA) following recent changes to the recordkeeping program.
OSHA launched the Recordkeeping National Emphasis Program (NEP) in October 2009 and of nearly 200 inspections in the first 12 months, almost 50% revealed recordkeeping violations.
OSHA has now made adjustments to the targeting criteria and is focusing more intently on specific types of organizations as detailed above and the deadline has been extended to February 2012. Commenting on this situation, WSP's Process Safety expert, Patricia Cushman, CSP, said: "OSHA has gone on record to emphasize the importance of accurate injury and illness reporting in the workplace. OSHA inspections will enforce regulatory requirements if data is not reported accurately or they find it has been adversely influenced by improper management."
Common violations include:
- Omitting injuries from the OSHA 300 log
- Incorrectly classifying injuries and illnesses on the OSHA 300 log
- Incorrectly recording number of days away from work due to illness or injury on the OSHA 300 log
- Providing incentive programs that encourage non-reporting of illnesses or injuries
Assistant Secretary Michaels was quoted as saying: "The application of a robust management system is key to ensuring complete and accurate OSHA logs and preparing for a recordkeeping inspection."
In line with this directive, WSP recommends four high-level checks for employers:
- Review the 300 logs and 301 incident reports for accuracy
- Ensure that 300 logs reflect information from the 301 incident reports
- Compare all OSHA recordkeeping forms with any workers' compensation reports and claims
- Look at the safety incentive programs and injury and illness reporting procedures for any evidence that these protocols are discouraging employee reporting.
WSP offers a comprehensive portfolio of Health and Safety services to include OSHA Recordkeeping. We help ensure OSHA logs are complete and accurate and that our clients have a management system in place to keep it that way.
Contact: Patricia A. Cushman, CSP, Senior Project Director at WSP Environment & Energy, on:
or T. 1 860 434 7074