Note to Reviewer

April 30, 2013

MEMORANDUM FOR: Reviewer of OMB NO. 1220-0045

FROM: Matthew Gunter

Economist

Office of Safety, Health, and Working Conditions

Office Compensation and Working Conditions

Bureau of Labor Statistics

SUBJECT: Request for Non-substantive Change for conducting the Survey of Occupational Injuries and Illnesses data quality interviews on workplace injury and illness recordkeeping and reporting

Attached is a telephone questionnaire and introductory letter to be administered to a small subsample of recent Survey of Occupational Injuries and Illnesses (SOII) respondents in four states.

We plan on asking participants for their voluntary participation via an introductory letter. A telephone questionnaire, developed by BLS and its four State Partners in this study, will follow the letter. We hope to learn more about how employers report workplace injuries and illnesses to workers compensation programs and record injuries and illnesses on their SOII forms.

We plan on conducting this phone questionnaire from May 2013 to April 2014. We plan to conduct 3900 interviews spread among 4 participating states. The interviews are expected to last for no more than 30 minutes thus the maximum number of burden hours is estimated to be 1950 hours.

If you have any questions about this request, please contact Matthew Gunter at (202) 691-6211 or e-mail at gunter.matt@bls.gov.

Attachments

Attachment A – Introductory Letter

Attachment B – Telephone Questionnaire

1. Introduction and Purpose

National estimates of nonfatal workplace injuries and illnesses are currently generated by SOII, which is a comprehensive statistical program covering work-related injuries and illnesses in private industry and in State and local government. The survey information is unique and of great value to the safety and health community in allocating prevention resources among several hundred diverse industries and occupations, across which workers’ risks of injury and illness vary widely.

Some non-BLS research studies have reported that the SOII undercounts workplace injuries and illnesses are within the scope of the survey. Preliminary research by BLS with matched SOII-workers’ compensation data suggests that legitimate differences among data systems and limitations of the undercount research methodology account for some of the estimated undercount. There is also an indication that certain types of cases are less likely to be captured in the SOII, especially those that are more difficult to relate to the workplace and those with late onset or recognition. There is a need for more research to understand the way various employer practices might account for differences between SOII and workers’ compensation data.

The goal of this study is to use a telephone questionnaire to explore possible reasons for differences in reporting days away from work injury and illness cases between the SOII and State Workers’ Compensation claims data. Since SOII respondents are requested to complete the survey using Occupational Safety and Health Administration (OSHA) logs and supplemental reports, we focus on both OSHA forms and the SOII in our protocol.

2. Respondents

There will be an estimated 3,900 reporting units contacted for this study. All respondents will receive an introductory letter (Attachment A) prior to the phone interview asking for their voluntary participation and informing them of the purpose of the phone interview and the expected time burden. We expect the time burden to be 30 minutes, based on survey pretesting results.

The questionnaire (Attachment B) will be conducted via telephone interviews with SOII respondent establishments by four State Partners currently under a Cooperative Agreement with BLS in Minnesota, New York, Oregon, and Washington. Establishment respondents who recently completed the SOII will be randomly sampled per the usual SOII strata of industry, industry size class, and ownership within each state. The BLS State Partners will conduct the interviews, will review, analyze, and publish the results of the study, in coordination with BLS.

The following table shows the expected workload burden for the SOII phone interviews between May 2013 and April 2014.

Expected Workload Burden
Number of respondents (total)	3,900
Minnesota	800
New York	1,400
Oregon	1,200
Washington	500
Number of responses	3,900
Minutes needed for interview	30
Total Minutes	117,000
Total hours	1,950

The estimate of costs to respondents based on burden hours to participate in this survey is $35,568. This estimate is based on a mean hourly pay rate of $18.43 for "Human Resources Assistants, Except Payroll and Timekeeping" from the May 2012 release by the Occupational Employment Statistics program, and was multiplied by the 1,950 expected burden hours.

3. Confidentiality
   
   

Respondents will be informed as to the voluntary nature of the study. Information related to this study will not be released to the public in any way that would allow identification of individuals except as prescribed under the conditions of the Confidential Information Protection and Statistical Efficiency Act of 2002 (Title 5 of Public Law 107-347) and other applicable Federal laws.

4. Payments to Respondents

There are no payments made to the respondents for this survey.

Attachment A. Example introductory letter for participation

STATE OF WASHINGTON

DEPARTMENT OF LABOR AND INDUSTRIES

Insurance Services, SHARP, PO Box 44330, Olympia WA 98504-4330

The Department of Labor and Industries would like to thank you for your response to the [survey year] Bureau of Labor Statistics (BLS) Survey of Occupational Injuries and Illnesses. We appreciate your assistance in the collection of accurate information in the effort to make Washington’s workplaces safer and healthier.

The Safety and Health Assessment and Research for Prevention (SHARP) program at L&I is conducting interviews with businesses across the state to gather information about work-related injury and illness recordkeeping practices and policies for workplace safety. We would like to schedule a time to speak and discuss your thoughts and experiences with the BLS Survey, OSHA logs, and workers’ compensation claims. The one-time phone interview will last approximately thirty minutes. Your participation is entirely voluntary.

Although OSHA log recording practices are discussed, this is in no way an investigation, or audit. All information provided during the phone interview is confidential and will not be shared with anyone other than the research personnel and the US Bureau of Labor Statistics. Identifiers (your name, work address, or phone number) will not be included with your responses to the questions. If you do have questions about DOSH inspection or consultation services, we will be able to provide you with resources and refer you to a DOSH consultant. The information we collect will not be shared with DOSH inspection or consultation personnel.

These interviews are part of a larger study being conducted in multiple states in partnership with the United States Department of Labor Bureau of Labor Statistics. We hope you will participate in this study and help to refine efforts to accurately reflect the recordkeeping experiences of employers like yourself. We will contact you by telephone in about one week to discuss this research further and schedule a time to talk in greater detail. We thank you for your time and consideration.

Respectfully,

Sara Wuellner

Study Coordinator

The BLS, its employees, agents and partner statistical agencies will use the information you provide for statistical purposes only and will hold the information in confidence to the full extent permitted by law. In accordance with the Confidential Information Protection and Statistical Efficiency Act of 2002 (Title 5 of Public Law 107-347) and other applicable Federal laws, your responses will not be disclosed in identifiable form without your informed consent. 

This survey is being conducted under OMB Control Number 1220-0141.  This control number expires on February 28, 2015.  Without OMB approval and this number, we would not be able to conduct this study.

Attachment B. Telephone Questionnaire

Interviewer: ________

Date: ________

First, the caller establishes contact with the person who completes the SOII and makes sure it’s a good time to conduct the interview. Verify that the introductory letter was received. If it was not, read the statement in the box below before proceeding:

The BLS, its employees, agents and partner statistical agencies will use the information you provide for statistical purposes only and will hold the information in confidence to the full extent permitted by law. In accordance with the Confidential Information Protection and Statistical Efficiency Act of 2002 (Title 5 of Public Law 107-347) and other applicable Federal laws, your responses will not be disclosed in identifiable form without your informed consent. This survey is being conducted under OMB Control Number 1220-0141.

Thank you for agreeing to participate in our study of workplace injury and illness recordkeeping. We are talking with people about how companies gather, record, and use information about workplace injuries and illnesses. We will use the information you provide us to improve the national survey of injuries and illnesses. The information you provide us today is very important. You are part of a small randomly-selected sample of companies. Everything we discuss today is strictly confidential and your participation is voluntary. If at any point you don’t understand a question, feel free to ask for clarification. Do you have any questions for me before we get started?

COMPANY

Ok, first I have a few questions about your company and the business location identified for this survey:

1. The location we selected for this survey is (unit description and/or address). We show the (2011/2012) annual average employment at this location is (employment). Does that sound correct? YES NO, specify:

2. Are all the workers at (sampled unit description/address) or does this number include workers at other locations? SAMPLED UNIT DESCRIPTION/ADDRESS OTHER/MULTIPLE LOCATIONS

3. Do you have additional locations in [state name]? YES NO

4. Do you have locations in other states? YES NO

5. Does your company use temporary workers hired through a temp help agency? YES NO NOT NOW, BUT HAS IN PAST DK

   1. [IF YES] Are they normally supervised by staff within your company? YES NO DK

6. Does your company lease workers? YES NO NOT NOW, BUT HAS IN PAST DK

   1. [IF YES] Are they normally supervised by staff within your company? YES NO DK

7. Are any workers covered by a union or collective bargaining agreement? YES NO DK

   1. [IF YES] Approximately what percent of workers are covered?

LESS THAN 25% 25-49% 50-74% 75% OR MORE DK

8. Does your company compete or apply for contracts or subcontracts? YES NO DK

1. [IF YES] Are any of the following injury or illness measures included in any bid submissions or applications for contracts/subcontracts?

   1. OSHA total recordable injury rate or DART rate YES NO DK

   2. WC experience factor/modifier YES NO DK

   3. Do you include any other measures? YES NO DK Specify:_________________

1. Who provides workers’ compensation insurance for your company? (CHECK ONE) INDIVIDUAL SELF-INSURANCE GROUP SELF-INSURANCE STATE FUND/ASSIGNED RISK PLAN PRIVATE INSURANCE CO. LEASING CO. OTHER, specify: _________ DK

2. Does a Third Party Administrator assist with your company’s workers’ compensation claims management? YES NO DK

3. OPTIONAL: Do you have on-site medical staff available to treat injuries that require more than first aid? YES NO DK

4. OPTIONAL: Do you recommend a specific clinic, facility, or treatment provider to your employees? YES NO DK (not asking in MN)

EMPLOYEE ROLES

Now, let’s move on to the people who deal with workplace injury and illness reporting for this location:

13. First, I have a question about your role in workplace injury and illnesses reporting. Do you typically complete or assist with the:

    1. OSHA 300 log? YES NO

    2. Workers compensation claims? YES NO

    3. BLS survey of occupational injuries and illnesses? YES NO

    4. Any other injury or illness recordkeeping? YES NO

Specify: ___________________________________

5. WA) Do you have access to information about employees’ workers’ compensation claims? (worker name, date of injury, description of injury, time loss days) YES NO

14. Do other persons complete or assist with the:

    1. OSHA 300 log? YES NO DK

    2. Workers compensation claims? YES NO DK

    3. BLS survey of occupational injuries and illnesses? YES NO DK

    4. Any other injury or illness recordkeeping? YES NO DK

15. [IF YES on 14a]: Who has primary responsibility for completing the OSHA 300 log? CHECK ONE.

RESPONDENT

OTHER COMPANY SAFETY AND HEALTH EMPLOYEE, specify: _______________

TPA, OTHER EXTERNAL CLAIMS MGR

OTHER, specify: _________________________

1. [IF NOT TPA/EXTERNAL]: Are you/Is that individual located at the (sampled location) work site?

YES NO MOVES FROM SITE TO SITE

2. [WA only-if not answered above] Does that person have access to specific information about individual workers’ compensation claims? YES NO DK

16. Did you keep an OSHA log during (2011/2012)? YES NO DK

17. When you are not participating in the BLS survey, do you keep an OSHA log? YES NO DK

18. How long have you been an OSHA record keeper? ___________YEARS

19. Have/has (you/person with primary responsibility from 15) received formal training on OSHA recordkeeping, such as classes, seminars, or on-line courses? YES NO (GO TO Q22) DK (GO TO Q22)

20. [IF YES], When did (you/person with primary responsibility from 15) last receive OSHA recordkeeping training?

Within the past 12 months 1-3 years ago 4-5 years ago more than 5 years ago? DK

21. Who provided that OSHA recordkeeping training to (you/person with primary responsibility from 15)? (CHECK ONE)

COMPANY STAFF OSHA STATE/LOCAL GOVERNMENT AGENCY TPA/INSURANCE COMPANY/RETRO TRADE ASSOCIATION COLLEGE/UNIVERSITY PRIVATE COMPANY/CONSULTANT DK OTHER, specify:_________

INJURY REPORTING AND PROCESSING

Now I have a few questions on how your company keeps track of injuries:

22. What do you track your workplace injuries and illnesses on? (CHECK ALL THAT APPLY)

PAPER FORM

ELECTRONIC SPREADSHEET

SPECIALIZED INJURY SOFTWARE PROGRAM

OTHER, SPECIFY: _________________________

DON’T TRACK

DK

23. [IF INJURY SOFTWARE PROGRAM in Q22 above]:

1. What injuries/illnesses are entered into the program? (CHECK ONE) ALL INJURIES ALL WC CLAIMS CASES WITH MEDICAL CARE OSHA log OTHER, specify: __________________

2. Do (you/person with primary responsibility from 15) or does the program determine if an injury/illness is recordable on the OSHA log? YOU/OTHER PERSON PROGRAM

[IF PROGRAM determines recordability: ]

1. Do you ever over-ride the computer’s decision? Yes No

24. INTERVIEWER CHECKPOINT: CHECK BOX IF NO LOG IS KEPT IN Q16/17, THEN SKIP TO Q33

OSHA RECORDKEEPING

Now I have a few questions about OSHA recordkeeping.

25. How do you decide whether to record a worker injury on your OSHA log? (CHECK ALL THAT APPLY)

Specify:___________________________________________________

ALL INJURIES

ALL FILED WC CLAIMS

ALL ACCEPTED WC CLAIMS

ALL injuries and illnesses that require MEDICAL VISITS

FOLLOW OSHA CRITERIA

COMPUTER SOFTWARE DECIDES

OTHER, specify ___________________________

26. Where do you get the information needed to complete an OSHA log entry?: (CHECK ALL THAT APPLY) COMPANY REPORT COMPLETED BY EMPLOYEE/SUPERVISOR WC REPORT OF ACCIDENT OR OTHER CLAIM/INSURER INFORMATION (INCLUDING INFO FROM TPA) DOCTOR’S REPORT OTHER, specify

27. Do you get any information for the OSHA log from your [insurance company, TPA, or WC]?

YES NO

a. [IF YES] What information is provided (CHECK ALL THAT APPLY)?

DATE OF INJURY NUMBER OF DAYS AWAY FROM WORK INJURY TYPE WORKER NAME INJURY LOCATION TREATMENT LOCATION NONE

28. How long after the injury or illness do you record it on the OSHA log? (CHECK ONE) WITHIN 1 DAY OF INJURY WITHIN 1 WEEK OF INJURY WITHIN 1 MONTH OF INJURY END OF YEAR WHEN CLAIM DECISION IS MADE WHEN CLAIM IS FILED OTHER, specify:______

29. Where do you usually get the number of days away from work for the OSHA log? (CHECK ONE) PAYROLL DATA WC TIME LOSS DATA CALENDAR (PAPER OR COMPUTER) SUPERVISOR OTHER, specify: ________________

    1. Does the number of days away from work include all calendar days or is it limited to days of missed work or scheduled shifts? CHECK ONE. CALENDAR DAYS SCHEDULED SHIFTS/DAYS DK OTHER, specify: ________________

30) Now, I have a few questions on differences between the OSHA log and workers’ compensation reporting.

a. Have you ever put any cases on the OSHA log that are not workers’ compensation claims?

YES NO DK

1. [IF YES] Can you give me an example? ______________________

2. Have you ever put any cases on the OSHA log that are denied by your workers’ compensation carrier? YES NO DK NO DENIED CLAIMS

   1. [IF YES] Can you give me an example? ______________________

3. Have you ever had an accepted WC claim for your company that was not included on your OSHA log? YES NO DK

i [IF YES] Can you give me an example? ______________________

31. Have you ever added cases to a previous year’s OSHA log? YES NO

    1. [IF YES] Can you give me an example?

32. Have you ever updated the number of days away from work on a previous year’s log? YES NO

    1. [IF NO], why not? ___________________________

33. Have you ever been notified of an injury or illness occurrence at your company at a much later date? (if prompted by respondent: more than 3 months)

YES NO

1. [IF YES] What was the reason for late notification?

31. Have you used any of the following recordkeeping resources or contacts? (CHECK ALL THAT APPLY) OSHA state contact OSHA federal contact OSHA recordkeeping website BLS contact or hotline Insurer/TPA other, specify:_____________

SOII RECORDKEEPING

Now I have a few questions on the BLS Survey of Occupational Injuries and Illnesses.

31. Was (SURVEY YEAR) the first time you’ve personally completed the BLS Survey of Occupational Injuries and Illnesses? YES NO DID NOT COMPLETE SOII DK OTHER, specify

32. [IF MULTI-UNIT]: Are you responsible for completing the survey for any other company location? YES NO

33. How do you decide what cases to include on the BLS survey (CHECK ONE)?

SAME AS OSHA 300 LOG

ALL INJURIES

ALL FILED WC CLAIMS

ALL ACCEPTED WC CLAIMS

ALL injuries and illnesses requiring MEDICAL VISITS

FOLLOW OSHA CRITERIA

COMPUTER SOFTWARE DECIDES

OTHER, specify

31. Where do you get the injury and illness information needed to complete the BLS Survey? (CHECK ALL THAT APPLY) OSHA 300 LOG OSHA 301 FORM COMPANY REPORT COMPLETED BY EMPLOYEE/SUPERVISOR WC REPORT OF ACCIDENT OR OTHER CLAIM INFORMATION (INCLUDING INFO FROM TPA) DOCTOR’S REPORT OTHER SOURCE, specify: _____________

31. Are days away from work on the BLS survey the same as what was reported on the OSHA log?

YES NO

1. [IF NO] What information or source do you use to determine the number of days away from work for the BLS survey? (CHECK ONE) PAYROLL DATA WC TIME LOSS DATA CALENDAR (PAPER OR COMPUTER) OTHER, specify: ________________

31. Have you ever been notified of an injury or illness that was reported too late to include in the BLS survey?

YES NO DK

[IF YES] Can you give me an example? _____________

31. [IF YES IN Q5,] Would you ever include a temp agency worker on your:

    1. OSHA log? YES NO DK

    2. BLS survey? YES NO DK

32. [IF YES IN Q6,] Would you ever include a leased worker on your:

    1. OSHA Log YES NO DK

    2. BLS survey? YES NO DK

WORKPLACE PRACTICES AND RECORDING QUESTIONS

We’re almost done. We have a few more questions on your company’s workplace performance practices.

31. Does your company use any safety incentives or rewards? YES NO DK

1. [IF YES AND OPTIONAL] Can you tell me a little about your programs (general description, award/prize, and approximate value):_______________________________________________________________

2. How is safety performance measured for these programs? (CHECK ALL THAT APPLY) OSHA RECORDABLE CASES WC CLAIM ANY INJURY HAZARD IDENTIFICATION/MITIGATION OTHER, specify:

31. a. Are worker safety performance measures used in rating Your job performance?: YES NO DK

1. [IF YES] What is performance based on? (CHECK ALL THAT APPLY)

OSHA RECORDABLE CASES WC CLAIMS (TL CASES, CLAIM $, EXP. FACTOR)

OTHER:________

2. Are worker safety performance measures used in rating Frontline Supervisor job performance? YES NO DK

   1. [IF YES] What is performance based on?

OSHA RECORDABLE CASES WC CLAIMS (TL CASES, CLAIM $, EXP. FACTOR) OTHER:________

3. [IF MULTI-UNIT]: Are worker safety performance measures used to compare worksites?

YES NO DK

1. What is used to evaluate or compare worksites?

OSHA RECORDABLE CASES WC CLAIMS (TL CASES, CLAIM $, EXP. FACTOR) OTHER: ___________

31. Does your company have a policy or practice of disciplining workers for unsafe practices

YES NO DK

31. Does your company have a policy or practice of testing workers for alcohol or drugs after their involvement in injury-causing incidents (aside from any driving accidents)?

YES NO DK

31. What OSHA recordkeeping decisions would you make in the following situations:.

    1. An employee injured his ribs at work, and went to have an X-ray. The rib was not broken and he had no further medical care.

Is this an OSHA-recordable injury? YES NO DK

2. An employee cut his arm at work on Friday. His doctor recommended he take two days off from work. He was not scheduled to work the weekend, and he returned to work on Monday.

Is this an OSHA-recordable injury? YES NO DK

1. [IF YES] Would you record any days away from work? YES NO DK

2. [IF YES] How many? _______

1. A worker was engaged in horseplay at work while stacking some boxes of lutefisk and fell, resulting in days away from work.

Is this an OSHA-recordable injury? YES NO DK

4. A worker cut her thumb and had stitches, but did not miss any time away from work.

Is this an OSHA-recordable injury? YES NO DK

1. A week later, the same worker ended up missing 7 days when the thumb became infected. Would you: Record as new injury Update old injury Not record DK

31. OPTIONAL: Is there anything you would like to comment on that would add to my understanding of how your company tracks workplace injuries and illnesses?

Washington-specific questions

WA1) Are you or a co-worker employed as an Occupational Safety & Health professional?

Respondent Co-worker Both No-one DK

1. Is this person located on site (of the sampled establishment)?

Yes No MOVES FROM SITE TO SITE DK

WA2) [IF TEMP] You indicated earlier that your company uses temporary workers. I just have a few extra questions on that topic:

1. How often does your company use temp workers?

Daily Weekly Monthly Regularly throughout the year (<monthly, >once a year)

Once a year For special projects (<1/yr)

b. What is the maximum number of temporary workers that your company would use at one time?___________________

c. How often does the company hire temp workers on as permanent employees? Would you say

It’s the primary means of hiring permanent employees

Not the primary means of hiring permanents but do consider it on a case by case basis

Never

d. Are temp employees and new permanent employees assigned the same tasks? Yes No

i. [IF YES] What tasks do they usually do? __________________________________________

ii. [IF NO] How are their Tasks different? _____________________________________________

WA3) How likely would you be to use an electronic system for injury and illness recordkeeping that was compatible with OSHA recordkeeping regulations?

Very likely Likely Unlikely Very unlikely Already using such a system

a. [IF V. LIKELY OR LIKELY] Would you prefer a web-based application or a stand-alone program?

Web-based Stand-alone No Preference

WA4) Do you find the OSHA log useful? Yes No

a. [If yes] how is it useful?

Minnesota-specific questions

MN1) Have you had an outside safety consultant visit your facility within the past two years? Yes No DK

MN2) Does your facility collect information on near-misses? Yes No DK

MN3) Do you think your OSHA 300 log is an accurate indicator of worker safety at your facility? Yes No DK

Why? or Why not?

Ok, I think that covers it. Thank you so much for your time. Do you have any questions? If we have any questions, we might call you back briefly for a clarification.