OSHA has to inspect workplaces in response to complaints and after incidents occur. But a big chunk of the OSHA enforcement strategy is planned inspections. Since the agency can’t show up at all workplaces, it targets sites that pose the highest risks—like companies with injury rates that are way above the norm for their particular industry.

But now abnormally low injury rates are also likely to land a company on the OSHA planned inspection list. There’s been a lingering suspicion that companies simply aren’t reporting illnesses and injuries. So on September 30, OSHA began implementing a new Recordkeeping National Emphasis Program (NEP) that targets OSHA Logs and injury reporting at companies with low rates of reported injuries.

To end up on the Recordkeeping NEP inspection list, a company must be in a high-risk industry and have a DART (Days Away Restricted and Job Transfer Rate of Injuries and Illnesses) of 4.2 or lower during 2007. High risk industries include (but aren’t limited to) animal slaughtering, poultry processing, steel foundries, soft drink manufacturing, couriers and nursing homes.

The Recordkeeping NEP inspection will consist of three components:

1. A records review in which OSHA inspectors look at medical, workers’ comp, absentee and other records for a sample of 2007 employees and verify that all illnesses and injuries are recorded on the OSHA 301;
2. Interviews with company recordkeeping officials, employees, managers and healthcare providers; and
3. A walkaround inspection of main operations areas.

To see the directive establishing the Recordkeeping NEP, see http://www.osha.gov/OshDoc/Directive_pdf/CPL_02_09-08.pdf. (Caveat: OSHA is apparently having troubles with its website. So I’m not 100% confident the link is going to work.)

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