b'ar, \'sCorner OS Record-l(eeping HAEnforcement By Gary Auman, Legal Counsel The Occupational Safety and H Administrealthation (OSH adopteda NationalEmphasisPA)rogram (NEP) to address deficiencies in compliance with record-keeping standards hese OSHA. T standards are found at Title 29 Code of Feder Regulations al 1904.0 e seq. The concern of OSHA focuses on-t. employers failing toreport all recordable injuries andillnesses, and whenthey doreport,they are not reporting accurately. Wh the industries that cause the concern ile NE is are the meat and poultry industries, thePnot limited to them. Several construction-oriented businesses have been inspected under thisTheNEP began October 1,2009, and expires September NEP. 30,2010. An OSHA compliance officer (CSH can use an NEP to estabO) lish p leto perform an inspection and to get ain the robab causefoot door. Enforcement inspections under the NEP have been identifying of several deficiencies in the record-keepingmany employers. Of course the major record-keeping issue typically deals with the completion of the OSHA 300 log. Here the questions focus on who must maintain a log, where the log must be maintained,when determining ifmeet these tests. This is import because, whatyouant must be recorded,and how to report restricted-duty days versusifwork throu h orite o ces and if they are some yough branc essatell ffilost-work days.distance from each other,may be required to maintainte youseparaFirst, construction is not an industry that is exempt from recordlogs for eachiness. buskeeping. Ifbusiness has employed 11 or moreduring yourpeople the calendar year, you are required to keep an OSHA 300 log, evenIfkeep one OSHA 300 log at your you if no injuries were sustained. One log must be maintained for eachbusiness headquarters, it must be readestablishment.Un 1904.46,anestablishment is defined as der follows:ily available to all employees and to any "Establishment. An establishment is aphysicalCSHO during an inspection. single location where business is conducted or whereIf you keep one OSHA 300 log at youriness headquarter it services or industrial operations are performed.bus s, Formust be r availableall employees and toCSHO during activities where employees do not work at aeadilytoany singlean inspection. Readily available is defined as being able to get the physical location, such as construction; transportation;information to an employee by the end of the business day after an communications, electric, gas and sanitary services;employee asks toit or to awithinrhours and similar operations, the establishment is representedreviewCSHOfou business by main or branch offices, terminals, stations, etc.,sonreq est of the per making au to review it. You should keep your thatOSHAlogs for at least 5 either supervise such activities orthe base from300years. areAnoth area of concernis recor lity. Without going into a which personnel carry out these activities."erdabilot of detail,need to record any in ryoccurs on the job. youju that An establishment caninclude more th one physical location.Therions you need to ask when determining reco ability anfou quest rd T can occur if three tests are met. First, youmust operate bothare: his locations as abusiness under common management. Second, Did the employee have an injury or singleillness? the locations have to be in close proximityeach o er. Third, you Is itrk toth wo related? must maintainset of business records for the locations. The Is it acase? onenew facts surrounding your circumstances may be takeninto accouDoes itgen recording criteria? ntmeeteral 4M idw est Valu esBusinessResource sNetw orking'