OSHA NEP: Under Recorded Injuries and Illnesses

Effective September 30, 2009, OSHA has begun a new National Emphasis Program (NEP) for inspecting the accuracy
of the Occupational Injury and Illness Recording and Reporting Requirements for low rate establishments in selected industries.

OSHA postulates 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.

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).

Industries included have a DART (days away, restrictions and transfers – based on the 200,000 hour benchmark) rate of 5.7 to 8.1 and include:

  • Animal slaughtering
  • Scheduled passenger air transportation
  • Steel foundries (except investment)
  • Other nonferrous foundries (except die-casting)
  • Concrete pipe manufacturing
  • Soft drink manufacturing
  • Couriers
  • Manufactured home (mobile home) manufacturing
  • Rolling mill machinery and equipment manufacturing
  • Iron foundries
  • Nursing care facilities
  • Fluid milk manufacturing
  • Seafood canning
  • Marine cargo handling
  • Copper foundries (except die-casting)
  • Bottled water manufacturing
  • Refrigerated warehousing and storage
  • Motor vehicle seating and interior trim manufacturing
  • Pet and pet supplies stores

It should be noted that if a company is an approved participant in OSHA’s Voluntary Protection Programs (VPP), or in OSHA Consultation’s Safety and Health Achievement Recognition Program (SHARP), it is to be deleted from the inspection list.

More information can be found HERE (Injury and Illness Recordkeeping National Empasis Program)