OSHA, well past its infancy, but still learning how to count injuries and illnesses

Although it has been almost 50 years since the passage of the Occupational Safety and Health (OSH) Act in 1970, concerns continue about the adequacy of the nation’s occupational injury and illness surveillance system. Tracking of injuries and illnesses is a basic premise of prevention. Identification of industries and work groups with increased risk, determining which injuries and illnesses have the highest incidences, measuring trends over time, monitoring the effect of program activity, and ensuring that occupational injuries and illnesses receive their fair share of attention and resources depend on the ability to accurately and consistently measure the number and rate of injuries and illnesses. The importance of developing a tracking system for occupational injuries and illnesses was recognized in the original Occupational Safety and Health (OSH) Act of 1970, Pub. L. 91-596, 84 Stat 1590. The U.S. Secretary of Labor was authorized in Section 24 of the OSH Act to do the following: “(a) In order to further the purposes of this Act, the Secretary, in consultation with the Secretary of Health and Human Services, shall develop andmaintain an effective program of collection, compilation, and analysis of occupational safety and health statistics. Such program may cover all employments whether or not subject to any other provisions of this Act but shall not cover employments excluded by section 4 of the Act.” The employments excluded in Section 4 were workers covered by other federal agencies such as railroad and maritime workers and federal and state workers. The Secretary of Labor elected to delegate responsibility to collect, compile, and analyze occupational safety and health statistics to the Bureau of Labor Statistics (BLS) in the Department of Labor. Despite the authority in the OSH Act to cover all workers, BLS elected to base their data collection program on an employer-based survey and supplementary workers’ compensation data. The survey excludes the self-employed, workers on farms with 10 or fewer employees, private household workers, and Federal government workers (prior to 2008 all governmental workers were excluded). In the 1990’s, BLS dropped the supplementary workers’ compensation data, because it could only be obtained from a limited number of states. The BLS employer survey selects employers stratified by industries from the 44 states participating in the survey and sufficient employers from non-participating states to produce national estimates. State estimates are only provided for the participating states. Each case reported by an employer is weighted according to the stratified selection so as to allow extrapolation from the individual cases reported to a national estimate. Individual cases and weighting are maintained as confidential information. Because of criticisms of the program during the 1970’s and 1980’s, a Panel on Occupational Safety and Health Statistics was convened by the National Research Council and issued a report in 1987 titled “Counting Injuries and Illnesses in the Workplace: Proposals for a Better System [NRC, 1987].” There were six major conclusions of that report: (i) the BLS system was inadequate in providing OSHA with data to conduct an effective program to prevent workplace injuries and illnesses; (ii) OSHA has neither used the data provided to it nor recognized the need for data to manage its program; (iii) no modification of the BLS survey would enable it to measure the rate of occupational illnesses; (iv) no adequate evaluation of the BLS survey for occupational injuries had been conducted; (v) BLS collects only a small proportion of the data employers are required by OSHA to record on occupational injuries and illnesses; (vi) the number of occupational fatalities is unknown with estimates ranging from 3,740 to 11,700. This last conclusion Department of Medicine, College of Human Medicine,Michigan State University, East Lansing, Michigan Correspondence to: Kenneth D. Rosenman, MD, Professor of Medicine, Department of Medicine, College of Human Medicine, Michigan State University, 909 Fee Road, 117 West fee Road, East Lansing, MI 48824. E-mail: Rosenman@msu.edu