Submitted by: Karyn Oyler, SPHR


OSHA initially launched a National Emphasis Programs (NEP) for OSHA Recordkeeping. The purpose of the program is to crack down on underreporting of occupational injuries and illnesses on the OSHA Form 300. OSHA plans to target and investigate 3 primary categories: companies whose injury reporting rates are significantly lower than the industry standard, companies with large worksites and manufacturing companies.

Initial Pilot Program:
The initial pilot program was for a 10-month period from October 1, 2009, through August 3, 2010. The program was suspended in July, but they have revised the program and are rolling out the next pilot program scheduled to run from September 28, 2010 through February 2012.

A Peer Analysis was completed for the initial pilot program. A total of 142 inspections were conducted in 27 states. The analysis reviews the scope of the investigations, the demographics and overview of violations. A copy of the Peer Analysis can be downloaded by following this link:

Revised Directive:
On September 28th, OSHA issued its revised directive for the NEP program. The directive number is 10-07 (CPL 02). According to the OSHA Notice, the significant changes in the program are the following:

  • The industry scope of the NEP is expanded to include industries listed on BLS table
    SNR02 for calendar years 2007 and 2008. The focus of the NEP will be on
    manufacturing industries.
  • The deletion criterion for establishments with recalculated DART rates greater than 4.2
    has been removed.
  • The injury and illness rate criterion for establishments in scope of the NEP is changed
    from a DART rate of 4.2 or less to a DART rate greater than 4.2 and less than 8.0.
  • CY 2008 ODI data is used for targeting list selection.
  • The period of records review is changed to focus on CY 2008 and CY 2009 records.

In addition to the NEP program, OSHA will be administering comprehensive training of its compliance staff to identify and correct violations of the recordkeeping regulation.

The entire OSHA Notice can be downloaded by following this link: