The national emphasis program (NEP) is a recently issued strategy released by The federal Occupational Safety and Health Administration (OSHA). Last year, OSHA launched the NEP after studies found that many companies were underreporting or incorrectly reporting workplace-related injuries and illnesses.
The goal of the NEP is to crack down on the underreporting of occupational injuries and illnesses. Specifically, OSHA plans to target manufacturing companies, companies whose rates are significantly lower than the industry standard, and/or companies that have large worksites. Currently, the NEP pilot program is scheduled to run through February, 2012.
There can often be confusion among companies that utilize a temporary workforce on the reporting requirements: who should record the injuries, how they should be recorded, etc . To provide some general guidance, below are are few key points to keep in mind with regard to temporary employees:
The "Controlling Company"
Employers who supervise temporary employees at their work-site are required to maintain the OSHA 300 Logs for those employees. The controlling employer is often the company who uses the temporary workers because they direct the day-to-day work of the employee. Some companies prefer to sub-divide the OSHA 300 Log to provide separate listings of temporary workers and their own internal employees. However, the records must be maintained in one larger log for all recordkeeping purposes.
First Reports of Injury and OSHA 301 Forms
When the workers from a temporary service firm are under the day-to-day supervision of the controlling party (using firm), the entire OSHA injury and illness recordkeeping responsibility belongs to the using firm. This responsibility includes completion of an OSHA 301 Incident Report form, or an equivalent form, for each recordable injury or illness entered on the OSHA 300 Log. The agency that is supplying you workers should partner with your organization to ensure you receive the medical records and return to work updates necessary to complete your reports.
The record keeping requirements of OSHA are quite intricate. Please be sure to consult with your own human resources and legal team prior to implementing any new processes. This article is intended to provide a general framework for the reporting requirements of OSHA. To keep updated on reporting requirements, you can consult OSHA's website at www.osha.gov.
Midwest Staffing Group is dedicated to supporting our clients in complying with all federal, state and local laws. If you have any questions on the OSHA reporting guidelines, please be sure to contact your local branch office!