OSHA Mandates Recordkeeping for Team Building Event

Posted on April 24, 2009 by Brad Hammock

In a new letter of interpretation, OSHA has confirmed that injuries to employees sustained at off-site team-building events are recordable on OSHA logs, so long as the injuries also meet other general recording criteria (such as requiring medical treatment beyond first aid). Employers are encouraged to review their recordkeeping practices to ensure that they are complying with this interpretation of OSHA’s recordkeeping rule.

OSHA was asked whether an injury incurred while an employee was go-cart racing at an off-site team-building activity was “work-related” under OSHA’s rule. In the scenario presented to OSHA, employees were not required to participate in the go-cart racing or other team building events. However, they were required to attend an off-site meeting and luncheon. In OSHA’s view, the employee was at the go-cart facility as a condition of employment and thus was “in the work environment.” Any injury or illness that arises is therefore presumed to be work-related in the view of the Agency.

Employers often hold team-building events at locations outside the workplace. If injuries occur during these events, employers must record them on their OSHA logs, assuming the injuries meet other recordability criteria.

With OSHA developing a National Emphasis Program on recordkeeping, now is the time for employers to review their recordkeeping procedures and logs to ensure they are fully compliant.
 

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OSHA National Emphasis Programs Under Development

Posted on April 7, 2009 by Brad Hammock

Signaling its renewed focus on enforcement, OSHA has announced it is developing six new National Emphasis Programs (NEPs). NEPs focus OSHA’s resources on industries, hazards, and occupational injuries and illnesses that need additional targeted enforcement, in the Agency’s view.

OSHA’s Director of Enforcement Programs revealed the following industry-specific NEPs are in development:

 

  • Chemical plants – process safety management;
  • Primary metals;
  • Flavorings and diacetyl; and
  • Oil and gas well drilling.

Employers in these industries should expect additional inspections and take steps now to ensure their safety and health practices are fully compliant with OSHA requirements.

 

Even more employers, however, can anticipate increased scrutiny on account of OSHA’s recordkeeping initiative. As a result of questions raised by Congress and labor organizations that injuries and illnesses are underreported, OSHA announced it is developing a recordkeeping NEP. All employers who are required to keep OSHA injury and illness logs should review them now for accuracy, completeness, and appropriate certification.

 

Finally, OSHA is developing an NEP dealing with occupational asthma, a growing area of concern for OSHA and the National Institute for Occupational Safety and Health.

 

In a recent speech, newly confirmed Secretary of Labor Solis committed OSHA to increased enforcement. These NEPs will drive much of that enforcement in coming months. 

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