On January 7, 2002, the Occupational Safety and Health Administration (OSHA) issued a compliance directive outlining how it will conduct audits to ensure that employers are complying with the Agency’s new illness and injury recordkeeping rule. The rule took effect on January 1, but pursuant to a settlement agreement with the National Association of Manufacturers (NAM), OSHA will not issue any citations until May.
The directive, “Audit and Verification Program of 2000 Occupational Injury and Illness Rule” (CPL 2-01), establishes a program and the procedures by which OSHA will conduct audits to verify the accuracy of the data employers submit to the Agency. OSHA considers onsite audits of employer injury and illness records a key method of verifying the accuracy of data submitted for the OSHA Data Initiative (ODI) established in 1995, and for estimating the extent of employer compliance with OSHA recordkeeping requirements.
The directive includes a sample letter to be sent to employers that outlines OSHA’s legal authority to access various records, including medical records, to determine the accuracy of illness and injury reporting. OSHA has created a website that employers may use to obtain information about the new recordkeeping rule at http://www.osha-slc.gov/recordkeeping/index.html . The site contains copies of the new reporting forms, advice to employers, fact sheets, and answers to frequently asked questions. The compliance directive is available on OSHA’s website at http://www.osha-slc.gov/OshDoc/Directive_data/CPL_2_2002-01.html .
