OSHA has long been hampered by its difficulty in coordinating between different Federal Area Offices and State Plans. Inspections at companies or construction contractors with many locations tend to be viewed one work site at a time, other than for purposes of determining “repeat” classification.
I assume that system limitations are one of the reasons that neither the current administration or the previous one has yet really carried through on threats to aggressively follow-up on other locations of companies placed on OSHA’s Severe Violators Enforcement Program list. A lack of proper programs and a better data base has largely prevented any sort of systematic tracking of company trends and development of a corporate wide focus. OSHA did not have access to much more immediate data than do private employers doing establishment searches at http://www.osha.gov.
Since 2006, the DOL has spent about $70 million developing and rolling out a software and hardware system known as the OSHA Information System (OIS) which reportedly will increasingly allow OSHA managers and inspectors to compare inspection trends in different jurisdictions, better track potential repeat offenders, and update the nationwide system several times a day.
The implementation has been tough and even in May 2012, the DOl commented on problems in merging old data from the current system into the new OIS.
Because of the transitory nature of the business, construction employers have presented special challenges to OSHA and this system may make it easier for each Area Office and CSHO to determine whether a contractor has been cited or inspected before. Apparently, the old system maintained the inspection location and a mailing address, but not a business address. This omission especially affected responses to smaller or lesser known contractors working in multiple OSHA jurisdictions.
The new OIS also offers a way to sort through misspelled business names or names that are close to what compliance officer is searching for, features missing from the old system.
OSHA–DC gains more tools to track Area Office performance, such as by more accurately comparing the performance of Area Offices by looking at trends involving which violations were cited, the size of penalties, and how many violations on average were cited from inspections.
The system also allows the electronic storing of citations, inspection reports, photographs, and other case file material, which is a substantial improvement for CSHO’s.
OSHA hopes to expand the OIS to the 27 states and territory plans sometime in 2013, but that may be more complicated.
Alas, employers will not have access to OIS. The http://www.osha.gov site will now include additional inspection information that highlights why cases have not been closed, such as failure to pay fines or to complete abatement.
OIS is not the coming of “Big Brother,” but once Area Offices work out the kinks, the OIS system will make their jobs easier and will expose employers operating in multiple jurisdictions to more risk.