When OSHA recently updated and expanded its injury and illness recordkeeping national emphasis program (NEP), it revised the questions compliance officers will ask during inspections. OSHA inspectors will interview employees, and they’ll ask:
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- Do you need to be accompanied by a supervisor to report injuries and illnesses?
- Are there prizes, rewards or bonuses to supervisors or managers that are linked to the number of injuries or illnesses recorded on the OSHA log?
- Are there demerit, punishment or disciplinary policies for reporting injuries or illnesses?
- Are there absenteeism policies that count absences due to work-related injuries as unexcused absences or assign demerits if a worker is absent due to a work-related injury?
- Is there post-injury drug testing for all or most work-related injuries and illnesses?
- Do you know of any employees who have been provided transportation so they could get into work because they were in a cast, on narcotic medication or for any other reason?
- Are you aware of any instances where an employee came into work the day they were having surgery, only to “clock in” and leave within the hour to go and have the surgery?
- Do you know of any employees who had an occupational injury and were given restricted work but just sit around because there is nothing for them to do that meets their restrictions?
- Have you ever been encouraged to report an injury or illness as a non work-related event or exposure to a medical provider?
- Are you aware of any instances where an employee did not receive appropriate medical treatment for a work-related injury or illness so that the injury or illness would not be recorded on the OSHA Log of Injury and Illness?
OSHA’s new directive, 10-02 (CPL 02), Injury and Illness Recordkeeping National Emphasis Program (RK NEP), issued on Feb. 19, 2010, replaces the previous directive, 09-08 (CPL 02), issued on Sept. 30, 2009. The updated RK NEP is set to expire in 2012.By J. J. Keller & Associates, Inc., the nation's leader in risk and regulatory management solutions since 1953. For more information, visit www.jjkeller.com