Bituminous Insurance Companies

Injury and Illness Data – Possible Changes to Collection and Transparency

Release Date: May 25, 2010

Generally speaking, nearly all safety and health and risk management professionals are interested in historical injury and illness data. Businesses are interested because a bad record can lead to regulatory inspections. The government-provided data is "too dated," according to many safety professionals. Questions have surfaced on why safety professionals can't get more current and accurate data. Those who desire better data should consider the following as an avenue to effect change.

The Department of Labor, Occupational Safety and Health Administration (OSHA) has published, in the Federal Register, an announcement of meetings to collect public comment on changes to injury reporting requirements.

[Docket No. OSHA–2010–0024] Modernization of OSHA's Injury and Illness Data Collection Process

ACTION: Stakeholder meetings and request for public comment.

SUMMARY: OSHA invites interested parties to participate in informal stakeholder meetings on the modernization of OSHA's injury and illness data collection system. OSHA encourages stakeholders who cannot participate to submit written comments. OSHA needs to gather information from stakeholders in order to be able to modify its current injury and illness recordkeeping regulation and develop a modernized recordkeeping system in ways that will help OSHA, employers, employees, researchers, and the public prevent workplace injuries and illnesses as well as, supporting President Obama’s Open Government Initiative, increase the ability of the public to easily find, download, and use the resulting dataset generated and held by the Federal Government. The informal discussions at the stakeholder meetings and the written comments from stakeholders will help give OSHA this information.

OSHA would like to gather information about a modernized electronic recordkeeping system from a wide range of interests to include: scope of the data collected, uses of the data collected, methods of data collection, and related economic impact.

In addition, OSHA is interested in answers to the following specific questions:

What recordkeeping data should the electronic recordkeeping system collect?
Would linking the recordkeeping data with other sources (e.g., medical records, workers’ compensation records) increase its usefulness and/or accuracy? If so, which sources? What potential technical and legal hurdles exist in linking to other data sources, and how might these be overcome?
Should the electronic recordkeeping system collect data from every employer under OSHA jurisdiction for every case, or should it be limited to a subset of employers and/ or cases, for example based on size, industry, incidence rate, occupation, or case severity?
What purposes could the collected recordkeeping data serve for OSHA as well as other users?
How could the collected data be used to make national or sector-specific estimates of injury and illness?
What would be the strengths and limitations of the collected data?
Would publishing data indicating the number of employees and number of employee hours worked at specific establishments disclose confidential commercial or trade secret information?
How can OSHA use state and other federal agency data collection experience in developing an electronic recordkeeping system?
How should OSHA design an effective quality assurance program for data entered into the electronic recordkeeping system?
Should data be collected on a flow basis or periodically, e.g., quarterly? What are the advantages and disadvantages of each approach to data collection?
What would be the benefits and disadvantages of implementing a new electronic recordkeeping system incrementally, e.g., starting with the largest employers or the most severe injuries?
What training and outreach will be necessary for employers to comply with the requirements of the electronic recordkeeping system?
How can OSHA ensure that small business employers are able to comply with the requirements of the electronic recordkeeping system?
What analytical tools could be developed and provided to employers to increase their ability to effectively use the injury and illness data?
How can OSHA improve the accuracy of recordkeeping data by encouraging reporting and recording of work-related injuries and illnesses and discouraging underreporting and underrecording of work-related injuries and illnesses?

DATES: The meeting dates are:

• May 25, 2010, 8:30 a.m. to 4:30 p.m., Washington, DC.

• June 3, 2010, 8:30 a.m. to 4:30 p.m., Chicago, IL.

Written comments must be submitted (postmarked, sent, or received) by June 18, 2010.

Additional information on meeting locations, registration for the meetings, or how to submit comments may be found at http://edocket.access.gpo.gov/2010/pdf/2010-10163.pdf.

The information contained in this publication was obtained from sources believed to be reliable. ISO Services Properties, Inc., its companies and employees make no guarantee of results and assume no liability in connection with either the information herein contained or the safety suggestions herein made. Moreover, it cannot be assumed that every acceptable safety procedure is contained herein or that abnormal or unusual circumstances may not warrant or require further or additional procedure.