OSHA will launch an injury and illness recordkeeping national emphasis program in August focusing on high-risk industries with low injury rates, Dave Schmidt, an economist in OSHA's Office of Statistical Analysis, told the National Advisory Committee on Occupational Safety Health July 15.

Authorized by the current fiscal year budget, the NEP will examine not only a company's records but also safety policies that discourage reporting, he said.

The Omnibus Appropriations Act of 2009 (P.L. 111-8) set aside $1 million for an OSHA “recordkeeping enforcement initiative on injury and illness reporting, addressing the apparent lack of completeness of the OSHA Log of Work-Related Injuries and Illnesses” (12 SNET 54, 4/14/09).

The emphasis program will select establishments with 40 or more employees that report low injury and illness rates in high-rate industries, such as animal slaughtering, nursing homes, soft drink manufacturing, and steel foundries, he said.

According to Schmidt, each inspection would involve the three following activities:

• interviews with employees, employee healthcare providers, management, and recordkeepers;

• a limited walk-around of main plant operation areas; and

• records review.

Baruch Fellner, an attorney with Gibson, Dunn, & Crutcher LLP, called the initiative a “misplaced priority” and said OSHA should devote its enforcement resources to safety and health hazards rather than a recordkeeping program.

Peg Seminario, AFL-CIO director of safety and health, told BNA July 20 that recent academic studies indicating underreporting justify the launching of the program. Schmidt told NACOSH agency recordkeeping audits have found between 10 percent and 20 percent of employers are underrecording.

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