Monday, March 9, 2009

About Those Injury/Illness Numbers

Anyone who thinks the BLS injury and illness data are accurate, please let me know, so I can mock and ridicule you. Every one of us who have ever reviewed OSHA 300 logs (or OSHA 200 logs for us old farts) knows that there are all kinds of mistakes on the logs. Note that I said mistakes, not intentional omissions.

We all know the big cases, Landis Plastics ($640k worth in 1997) and Saw Pipes ($536k worth in 2001) to name but two, yet in over 20 years with the agency I have never found a company that intentionally left injuries off their 200/300 logs. Does that mean that companies don't hide injuries? Obviously not, in fact I think my situation is a bizarre statistical oddity. Conversely, I've never found a company that filled out their logs error free either. Kind of an interesting dichotomy, no?

In all of the inspections where I have done a detailed review of the injury/illness records, by far the most common mistake is misreporting the number days lost/restricted. Once in awhile, maybe once every 15 inspections or so, I might find an injury that wasn't recorded, but never intentionally (at least as far as I could prove). I've also probably found as many instances of over-recording as under-recording. Those of you who have found cases of underreporting, how many times have you found over-reporting? Track it some time and see if it doesn't come close to balancing out.

What am I suggesting? I guess I'm saying is that, while I think the lost/restricted days data is probably way under reported and not very reliable, the incidence rates are probably reasonably close. Why is this distinction so important, you may ask? Because much of our targeting is based on incidence rates and usually when we look at trends, we almost always look at incidence rate trends, not lost time trends.

As hard as it may be for some people to swallow, I think the drop in injury and ergonomic rates that Foulke, et. al., reported is probably real.


  1. When is the last time that OSHA issued a $500k citations that had to do with safety? All the high dollar citation have to do with record keeping instead.

    So what OSHA says is that we will give you a $70k willful for not properly sloping the trench walls, but if we find out it is not being properly recorded, you are subject to a $500k fine.

    Something wrong with this picture.

  2. I've run across employers who leave things off the log on purpose. Not that wide spread - the poulty industry is pretty bad. But in an overall sense, whether numbers are under or over reported are they more so now or would they be about the same under/over as in the past (consistent). Then the decreases would be real I think. The other factors are that workplaces I think are getting safer (if they weren't work comp, insurance carriers, and OSHA have pretty much been unimportant). Also how does the effect of the transition away from a manufacuring economy to a service economy affect the rates? More ergo, less 'injuries'? I'm sure there are other variables out there. Overall I think the rates are going down to a certain extent...

  3. This whole "rates controversy" is contrived. A) By challenging the trends/accuracy it gives the new Administration cover if rates shoot back up by blaming it on the accuracy of the numbers. B) Increasing fines/inspections/etc is merely a way for the union organizers to try and penetrate new workplaces. Its that simple.

  4. Did you drink the Kool Aid too? I suggest you check out a previous Pump Handle post on this subject and review the statistical analysis published in the technical literature:

    I suppose she (Chao)and those at OSHA who drank the Kool-Aid choose to ignore the empirical evidence that suggests that this substantial decline “corresponds directly with changes in OSHA recordkeeping rules.” [Friedman & Forst, 2007]

  5. You talk about injuries but not illnesses, probably because there is very little illness data.
    I noticed that the National Institute for Occupational Safety and Health (NIOSH) reports in 3 places on its website that about 55,000 workers die each year from workplace-related injuries and illnesses. I thought it must be a typo--an extra zero. The Bureau of Labor Statistics apparently doesn't report deaths from illnesses. OSHA recordkeeping rules don't require the recording of deaths or hospitalizations that occur more than 30 days after the initial injury or exposure on OSHA 300 forms, so I guess that's why illnesses like asbestosis don't get reported. Have you seen the 55,000 number, is it verifiable, and if it's true how come it's not news?

    Here are the NIOSH websites that show the 55,000 deaths per year statistic: