OSHA Recordkeeping National Emphasis Program
The Omnibus Appropriations Act of 2009 set aside $1 million to fund a one-year recordkeeping emphasis program including a recordkeeping enforcement initiative.
Inspections will involve a records review covering medical files, workers’ compensation documents, absentee reports, and OSHA Form 301 records for a selected sample of employees. In addition, compliance officers will interview recordkeepers, members of management, employees and health care providers. OSHA may also conduct a limited walk-around inspection to verify that the potential hazards present at the worksite are consistent with the types of injuries reported on the OSHA 300 log. Compliance officers also will inquire about the system an employer has for reporting injury and illness cases and whether any incentive program might affect the reporting of injuries and illnesses.
Frost Brown Todd has already seen an increased emphasis on recordkeeping and related enforcement proceedings. In anticipation of a possible recordkeeping inspection, employers should review the accuracy of their OSHA 300 logs and supporting documentation (e.g., OSHA 301 or its equivalent). Employers also should assess their system for reporting injuries and illnesses including the transmittal of medical information from health care providers to recordkeepers, and the training level of their recordkeepers.
If you have questions about OSHA’s recordkeeping National Emphasis Program or OSHA recordkeeping requirements in general, please contact Robert A. Dimling at (513) 651-6821, rdimling@fbtlaw.com, or Andrew R. Kaake at (513) 651-6953, akaake@fbtlaw.com.
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Attorney Spotlight
Deborah S. Adams is a member of Frost Brown Todd LLC and practices in the labor and employment law practice group. She represents management in the areas of employment discrimination and wrongful discharge.