MSDSonline Environmental, Health & Safety Blog

OSHA’s Recordkeeping Rule, 29 CFR 1904, has been center stage in the EH&S world as of late. We’ve had the recent implementation of a national emphasis program (NEP) on recordkeeping due to a Government Accountability Office (GAO) study that revealed underreporting,  and now we have an OSHA proposal on the floor to revise future injury and illness recordkeeping requirements so that it’s easier to identify work-related musculoskeletal disorders (MSDs). 

The proposed rule aims to reinstate a column for recording MSDs onto the Log of Work-Related Injuries and Illnesses, Form 300. This same requirement was issued in 2001 but deleted before the final rule became effective. 

Reinstating an MSD column on the OSHA 300 Form “will improve the ability of workers and employers to identify and prevent work-related musculoskeletal disorders by providing simple and easily accessible information,” said Assistant Secretary of Labor for OSHA Dr. David Michaels.  “It will also improve the accuracy and completeness of national work-related injury and illness data.” Visit OSHA’s Web site to read the complete announcement.

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-MSDSonline Team-

OSHA’s “Recordkeeping Rule” continues to make headlines in the EH&S world.  The most recent news involves  a report released by the Government Accountability Office (GAO), which concludes that underreporting and inaccurate employer injury and illness data may be attributed to a number of factors, including worker intimidation, and that the Labor Department’s OSHA audit process for verifying employer injury and illness records, is flawed.

Brief Background About the Report
The Department of Labor (DOL) is required under the OSH Act of 1970 to collect and compile occupational injury and illness records, and the Government Accountability Office (GAO) was asked to determine two things: 1) whether or not the DOL verifies that employers are accurately recording employee workplace injuries and illnesses, and, if so, how adequately and 2) what factors may affect the accuracy of employer injury and illness records. The results of the report were released this month.

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Back in August of this year, Dave Schmidt, an economist in OSHA’s Office of Statistical Analysis, released details about OSHA’s $1 million, one year National Emphasis Program (NEP) for injury and illness recordkeeping at a National Advisory Committee on Occupational Safety and Health (NACOSH) meeting, and on Oct. 1, OSHA officially announced  that it was initiating this NEP.

The purpose of the NEP will be to protect workers by investigating certain employers for possibly under-recording workplace injuries and illnesses. The NEP will focus on industries with high injury and illness rates.

“Accurate and honest recordkeeping is vitally important to workers’ health and safety,” said acting Assistant Secretary of Labor for OSHA Jordan Barab. “This information is not only used by OSHA to determine which workplaces to inspect, but it is an important tool employers and workers can use to identify health and safety problems in their workplaces.”

The inspections will consist of three components: a records review, employee interviews and a limited safety and health inspection of the workplace.

1. Records review

• Of ALL available records for each employee sampled (medical records, Workers’ Comp, absentee records, audiograms, etc.)
• Of the OSHA 300 Log, 300A Summary and 301 Incident Report (or the equivalent) to verify accuracy

2. Interviews

• With the recordkeeper, management, employees and health care providers
• To find out about current incident recordkeeping processes
• To determine whether incentive and disincentive programs might be set up in such a way that deters reporting

3. Limited safety and health inspection of the workplace

• To determine if recorded incidences correlate with actual work environments
• Will simultaneously address any observable safety violations

OSHA stated that this NEP will help the agency work with the Government Accountability Office (GAO) and the Bureau of Labor Statistics, which have both cited concerns about the accuracy of recorded workplace injury and illness estimates.

Incident Management Assistance
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Call 1.888.362.2007 for more information or send  an inquiry via email.

Recent accusations that companies are underreporting workplace injuries, have captured the attention of OSHA and the Bureau of Labor Statistics. While neither agency has come across such cases, the claims have given them reason to place more scrutiny on the accuracy of recordkeeping logs and records.

Continue reading ‘OSHA’s Taking a Closer Look at Injury Records’

As a reminder, your company may be required to post an OSHA Form 300A.  This is a summary log of all work-related injuries and illnesses that occurred at your place of business in 2008.  The posting period is from February 1 through April 30, 2009.
 
This mandate is part of OSHA’s Recording and Reporting Occupational Injuries and Illnesses Standard, 29 CFR 1904.

Continue reading ‘OSHA Form 300A – Posting Date Approaching’