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SAFETY / OSHA - 10/05/09

OSHA issues new NEP in response to under-recording of workplace injuries

In an effort to identify and correct under-recorded and incorrectly recorded workplace injuries, OSHA has issued a new National Emphasis Program (NEP) establishing enforcement procedures to inspect the accuracy of the occupational injury and illness recording and reporting requirements for low rate establishments in selected industries. This NEP also complements the Bureau of Labor Statistics' efforts to investigate factors accounting for differences in the number of workplace injuries and illnesses estimated by the BLS and other data sources. The directive establishing the NEP is available here: http://www.osha.gov/OshDoc/Directive_pdf/CPL_02_09-08.pdf

Recently, several academic studies have asserted varying degrees of under-recording of workplace injuries and illnesses on the OSHA Form 300; ( e.g., Boden L.I., Ozonoff A. Capture-Recapture Estimates of Nonfatal Workplace Injuries and Illnesses, 2008 and Rosenman K.D. How Much Work-Related Injury and Illness is Missed By the Current National Surveillance System, 2006). At the request of the Senate Committee on Health, Education, Labor and Pensions and the House Committee on Education and Labor, the Government Accountability Office (GAO) initiated a study on the accuracy of employer injury and illness records.

OSHA believes the most likely places where under-recorded injuries and illnesses may exist would be low rate establishments operating in historically high rate industries. The NEP will pilot test OSHA's ability to effectively target establishments to identify under-recording of occupational injuries and illnesses.

"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."

This NEP is one component of OSHA's effort to address the issue of inaccurate recording of occupational injuries and illnesses. In addition to this NEP, OSHA will address the issue through comprehensive training of its compliance staff to identify and correct violations of the recordkeeping regulation. OSHA will also develop other enforcement and quality assurance programs to address the recordkeeping issue in establishments and industries outside the scope of this NEP ( e.g., the construction industry, Partnerships, VPP and SHARP establishments).

The NEP is effective from September 30, 2009 through September 30, 2010.

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