In a recent meeting where the OSHA Area Director for West Virginia explained howOSHA’s National Emphasis Program on recordkeeping would be carried out in ourstate, it was made abundantly clear that the OSHA recordkeeping practices ofemployers will be under a much brighter spotlight by the agency going forwardthan many believed.

Attendees of the meeting wereadvised that there will be five specific inspections in the next 24 months whichfocus solely on recordkeeping. The targets will be those employers who have lowDART rates in high-injury-rate industries – like poultry processing andfoundries (his words, not ours). You can bet logging is up there as well. Forthose who don’t know what a DART rate is, it is days away fromwork, restrictions and transfers. All of those categories arelocated on the OSHA 300 log. Those employers with fewer than 40 employees orthose in VPP status will be targeted.

Also, these inspections are goingto be like none you’ve had before. The inspections will not just focus on your300 log and related injury reports. Inspectors will review absenteeism records,payroll records and payroll rosters, workers compensation records – evenavailable insurance records. And yes, they will have a Medical Access Order inhand before they step through your door. They will particularly focus on safetyincentives you may have, looking for the suppression of injury reporting throughsuch incentives. In depth interviews with employees will be undertaken on thesesubjects, with particular focus on interviewing the individual who keeps yourOSHA 300 log and their knowledge of their responsibilities, first aid personnel,your medical provider and others. And if your DART rate exceeds 4.2, that willgenerally merit a full inspection.

These will be serious, in-depthinspections, so employers are advised to be on alert. And the need is even moreacute considering some of OSHA’s other recent announcements that the agencyplans to increase penalty amounts for non-compliance. One last relevant tidbit –of the 250 inspections conducted by the OSHA Charleston Area Office sinceOctober of 2009, 200 have been cited for recordkeeping issues. Forewarned isforearmed.