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OSHA Extends its Recordkeeping National Emphasis Program

In 2010, OSHA announced that it was making changes to its Recordkeeping NEP, originally initiated in September 2009. The inspection program is designed to investigate whether, and to what extent, injuries and illnesses are being underreported by employers. The NEP specifically targets employers with low rate establishments operating in historically high rate industries. According to OSHA, the agency has inspected over 190 worksites as part of its Recordkeeping NEP, finding violations in about half of them.

Numerous foundries report being targeted under this NEP, with OSHA compliance officers in and out of their facilities for weeks. The changes to the Recordkeeping NEP include:

• Extension of the enforcement program until February 2012.
• If OSHA begins an inspection of an establishment and determines that the establishment falls outside the targeted industries identified in the NEP, compliance officers are now instructed to proceed with the inspection. Originally, compliance officers were instructed to stop the inspection if they identified that an establishment was not in fact in one of the targeted NAICS codes.
  
• Refocusing on large manufacturing sites.
  
• Expanding employee interview questionnaires to gather additional information on, among other things, recordkeeping policies and programs that may discourage the reports of injuries and illnesses.

In the three-year-old combustible dust NEP, nearly 9,100 violations have been found, although not all of them have been for dust violations. According to OSHA officials, initial penalties have totaled more than $19.5 million. OSHA's update and extension of the Recordkeeping NEP further shows how seriously the agency is taking allegations of underreporting of injuries and illnesses by employers. Metalcasters must continue to be vigilant in ensuring that their recordkeeping programs and practices are fully compliant with OSHA's rules.

For more information, contact Stephanie Salmon, Metalcasters Alliance for Government Affairs Washington Office, 202/842-4864 or ssalmon@afsinc.org.