Rich Fairfax, the director of OSHA's enforcement programs, said that last year OSHA performed 250 such inspections. While his plan to conduct more audits needs to be approved by other agency officials, Fairfax said, "I think it's going to happen."
OSHA's recordkeeping standard was revised in 2002 and one reason to tighten enforcement of the rule now, Fairfax explained, is that employers have had several years to adjust to the new requirements.
The original rationale for the audits of companies with extremely low rates in high-hazard industries was that if the numbers are valid it means the organizations have superb safety programs. In such cases, OSHA would want to encourage the companies to join the agency's Voluntary Protection Program or other cooperative programs reserved for organizations with exemplary safety records.
"If, on the other hand, we find they're cooking the books, we're going to go after them," Fairfax asserted.
A second reason the agency is concerned about the accuracy of records touches on the integrity of OSHA's Site Specific Targeting (SST) program, which targets facilities with high recorded rates of injuries and illnesses.
"If we're going to be basing our main targeting system for general industry on the SST, then we need to be doing all the checks we can to make sure the data are valid and accurate," Fairfax said.
In 2004, OSHA performed 1.6 percent fewer inspections than the year before, but total and serious violations rose 3 percent, while repeat violations jumped 10 percent and willful violations shot up 14 percent.
Fairfax said better targeting of high-hazard worksites was one reason OSHA was able to issue more violations even as inspections declined.
"We also spent a lot of time working with compliance officers in the [OSHA] regions on enhanced documentation and training," he added, "so we can put together a better legal case and not get hung up in trials."
Fairfax attributed the rise in repeat violations to a combination of factors, such as improved research on enforcement targets and OSHA's new enhanced enforcement program, which is designed to go after employers with a history of ignoring OSHA regulations.
Look for more OH.com stories in the coming weeks analyzing OSHA's enforcement activities in 2004 and looking ahead to what companies might expect this year from the agency.