GAO 

United States Government Accountability Office

Report to Congressional Requesters

WORKPLACE 

SAFETY AND 

HEALTH 

Enhancing OSHA’s 

Records Audit Process 

Could Improve the 

Accuracy of Worker 

Injury and Illness Data

October 2009 

GAO-10-10 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

October 2009

WORKPLACE SAFETY AND HEALTH

Enhancing OSHA’s Records Audit Process Could 

Improve the Accuracy of Worker Injury and Illness

Highlights of GAO-10-10, a report to Data 

congressional requesters 

Under the Occupational Safety and 

Health Act of 1970, the Department 

of Labor’s (DOL) Occupational 

Safety and Health Administration 

(OSHA) is responsible for 

protecting the safety and health of 

the nation’s workers. The act 

requires DOL to collect and 

compile work-related injury and 

illness data. GAO was asked to 

determine (1) whether DOL verifies 

that employers are accurately 

recording workers’ injuries and 

illnesses and, if so, the adequacy of 

these efforts, and (2) what factors 

may affect the accuracy of 

employers’ injury and illness 

records. GAO analyzed OSHA’s 

audits of employers’ injury and 

illness records, interviewed 

inspectors who conducted the 

audits, surveyed occupational 

safety and health practitioners, and 

obtained the views of various 

stakeholders regarding factors that 

may affect the accuracy of the data. 

What GAO Recommends

GAO is recommending that the 

Secretary of Labor direct OSHA to 

(1) require inspectors to interview 

workers during records audits, and 

substitute other workers when 

those initially selected are 

unavailable; (2) minimize the time 

between the date injuries and 

illnesses are recorded by 

employers and the date they are 

audited; (3) update the list of high 

hazard industries used to select 

worksites for records audits; and 

(4) increase education and training 

to help employers better 

understand the recordkeeping 

requirements. OSHA agreed with 

these recommendations. 

DOL verifies some of the workplace injury and illness data it collects from 

employers through OSHA’s audits of employers’ records, but these efforts may 

not be adequate. OSHA overlooks information from workers about injuries 

and illnesses because it does not routinely interview them as part of its 

records audits. OSHA annually audits the records of a representative sample 

of about 250 of the approximately 130,000 worksites in the high hazard 

industries it surveys to verify the accuracy of the data on injuries and illnesses 

recorded by employers. However, OSHA does not always require inspectors to 

interview workers about injuries and illnesses—the only source of data not 

provided by employers—which could assist them in evaluating the accuracy 

of the records. In addition, some OSHA inspectors reported they rarely learn 

about injuries and illnesses from workers since the records audits are 

conducted about 2 years after incidents are recorded. Moreover, many 

workers are no longer employed at the worksite and therefore cannot be 

interviewed. OSHA also does not review the accuracy of injury and illness 

records for worksites in eight high hazard industries because it has not 

updated the industry codes used to identify these industries since 2002. OSHA 

officials told GAO they have not updated the industry codes because it would 

require a regulatory change that is not currently an agency priority. The 

Bureau of Labor Statistics (BLS) also collects data on work-related injuries 

and illnesses recorded by employers through its annual Survey of 

Occupational Injuries and Illnesses (SOII), but it does not verify the accuracy 

of the data. Although BLS is not required to verify the accuracy of the SOII 

data, it has recognized several limitations in the data, such as its limited 

scope, and has taken or is planning several actions to improve the quality and 

completeness of the SOII. 

According to stakeholders interviewed and the occupational health 

practitioners GAO surveyed, many factors affect the accuracy of employers’ 

injury and illness data, including disincentives that may discourage workers 

from reporting work-related injuries and illnesses to their employers and 

disincentives that may discourage employers from recording them. For 

example, workers may not report a work-related injury or illness because they 

fear job loss or other disciplinary action, or fear jeopardizing rewards based 

on having low injury and illness rates. In addition, employers may not record 

injuries or illnesses because they are afraid of increasing their workers’ 

compensation costs or jeopardizing their chances of winning contract bids for 

new work. Disincentives for reporting and recording injuries and illnesses can 

result in pressure on occupational health practitioners from employers or 

workers to provide insufficient medical treatment that avoids the need to 

record the injury or illness. From its survey of U.S. health practitioners, GAO 

found that over a third of them had been subjected to such pressure. In 

addition, stakeholders and the survey results indicated that other factors may 

affect the accuracy of employers’ injury and illness data, including a lack of 

understanding of OSHA’s recordkeeping requirements by individuals 

responsible for recording injuries and illnesses. 

View GAO-10-10 or key components.

For more information, contact Revae Moran 

(202) 512-7215 or moranr@gao.gov. 
Page i GAO-10-10 

Contents 

Letter 1

Background 3 

DOL Verifies the Injury and Illness Data in the ODI, but OSHA Does 

Not Always Collect Information from Workers, and Excludes 

Certain Industries 11 

Occupational Safety and Health Practitioners and Stakeholders 

Cited Worker and Employer Disincentives as Primary Factors 

That May Affect the Accuracy of Injury and Illness Data 17 

Conclusions 22 

Recommendations for Executive Action 23 

Agency Comments and Our Evaluation 23 

Appendix I Scope and Methodology 26 

Appendix II Survey Instrument for Occupational Health 

Practitioners 38 

Appendix III Selected Questionnaire Results 49 

Appendix IV OSHA’s Forms for Recording Work-Related 

Injuries and Illnesses 53 

Appendix V High Hazard Industries Included in ODI Universe 

as of August 2009 65 

Appendix VI Comments from the Department of Labor 66 

Appendix VII GAO Contact and Staff Acknowledgments 68 

 Workplace Safety and Health 
Related GAO Products 69 

Tables 

Table 1: Number of Inspections Conducted by OSHA, Fiscal Years 

2003-2007 5 

Table 2: Number of Records Audits by Type of Industry, 2003-2005 9 

Table 3: Industries That Would be High Hazard if OSHA Updated 

Its ODI Universe 14 

Table 4: Disposition of Health Practitioner Sample 30 

Figures 

Figure 1: DOL’s Annual Occupational Injury and Illness Surveys 6 

Figure 2: Number and Rate of Injuries and Illnesses in the United 

States, 1990-2007 7 

Figure 3: Number of Worksites Audited by Size, 2003-2005 9 

Figure 4: Timeline for Collecting and Auditing Employers’ Injury 

and Illness Records 13 

Figure 5: Pressure From Workers to Downplay Injuries and 

Illnesses and Awareness of Incentive Programs 20 

Figure 6: Reported Impact of Misinterpretation of Recordkeeping 

Requirements on Record Accuracy 21 

Figure 7: Industries in Which the Majority of Workers Treated by 

Practitioner Respondents Were Employed in 2008 31 

Figure 8: Number of Years Respondents Had Treated Workers 32 

Figure 9: Number of Workers Treated by Respondents in 2008 32 

Figure 10: Practitioners’ Opinions on the Efficacy of Safety 

Incentive Programs 49 

Figure 11: Worker and Company Official Behavior Related to 

Reporting Injuries or Illnesses in 2008 50 

Figure 12: Impact of Various Factors on Accuracy of Employers’ 

Injury and Illness Logs 51 

Figure 13: Frequency of Experiencing Various Requests From 

Workers or Company Officials in 2008 52 

Page ii GAO-10-10 Workplace Safety and Health
Abbreviations 

BLS Bureau of Labor Statistics 

DART days away from work, restricted activity, or job transfer 

DOL Department of Labor 

LWDII lost workday injury and illness (rate) 

NAICS North American Industry Classification System 

NEISS National Electronic Injury Surveillance System 

NIOSH National Institute for Occupational Safety and Health 

ODI OSHA Data Initiative 

OSHA Occupational Safety and Health Administration 

OSH Act Occupational Safety and Health Act of 1970 

SIC Standard Industrial Classification 

SOII Survey of Occupational Injuries and Illnesses 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

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necessary if you wish to reproduce this material separately. 

Page iii GAO-10-10 Workplace Safety and Health
Page 1 GAO-10-10 

United States Government Accountability Office

Washington, DC 20548 

 

October 15, 2009 

Congressional Requesters: 

In 2007, there were approximately 4 million cases in which workers in the 

United States were injured or became ill as a result of unsafe or unhealthy 

working conditions, and more than 5,600 workers died as a result of their 

injuries, according to data reported by the Department of Labor’s (DOL) 

Bureau of Labor Statistics (BLS). The rate of nonfatal occupational 

injuries and illnesses (hereafter referred to as injuries and illnesses) 

among private sector employers as reported by BLS in 2007 has generally 

declined since 1992; the rate of worker fatalities decreased from 1992 to 

2001, and has remained relatively constant since 2002. Under the 

Occupational Safety and Health Act of 1970 (OSH Act), DOL’s 

Occupational Safety and Health Administration (OSHA) is responsible for 

protecting the safety and health of the nation’s workers. The OSH Act 

requires DOL to collect and compile accurate statistics on worker injuries 

and illnesses. One of two sources of these statistics is BLS’s Survey of 

Occupational Injuries and Illnesses (SOII), which provides nationwide 

data on workers’ injuries and illnesses in most industries. The other is 

OSHA’s survey of selected employers’ injury and illness records called the 

OSHA Data Initiative (ODI), which provides injury and illness data for 

workers in high hazard industries. The OSH Act and DOL regulations 

require employers with more than 10 employees to record other than 

minor injuries and illnesses on logs maintained at each worksite. However, 

83 percent of all employers are generally not required to record workrelated injuries and illnesses, either because the employers are too small 

(have fewer than 11 employees) or because they are in industries with 

historically low rates of injuries and illnesses and have thus been 

exempted by OSHA from recording injuries and illnesses. 

At your request, we reviewed DOL’s efforts to ensure that injuries and 

illnesses are properly recorded by employers. Specifically, you asked us to 

determine (1) whether DOL verifies that employers are accurately 

recording workers’ injuries and illnesses and, if so, the adequacy of these 

efforts, and (2) what factors may affect the accuracy of employers’ injury 

and illness records. To address our first objective, we interviewed DOL 

officials to determine the types of verification efforts the agency conducts 

for the data collected in its SOII and ODI surveys, and the agency 

components responsible for these efforts. We also reviewed relevant laws 

and regulations. After determining that OSHA verifies the ODI data it 

collects through onsite audits of selected employers’ injury and illness 

 Workplace Safety and Health 
 

records (records audits), we interviewed OSHA headquarters officials and 

collected relevant documentation regarding the agency’s audit procedures. 

We analyzed data from records audits conducted by OSHA from 2005 to 

2007 of employers’ calendar year 2003, 2004, and 2005 injury and illness 

records (the most recent data available).1

 We were not able to 

independently verify the injury and illness data audited by OSHA because 

we do not have access to the injury and illness records of private 

employers. To better understand OSHA’s records audit procedures, we 

interviewed OSHA regional administrators and area directors, as well as 

inspectors who conducted the audits in each of OSHA’s 10 regions, 

including inspectors with various levels of audit experience, to obtain a 

range of perspectives. To address our second objective, we interviewed 

OSHA and BLS officials; experts, including academics and researchers; 

labor representatives and worker advocates; and representatives from an 

employer association, and surveyed a representative sample of 

occupational health practitioners in the United States. We selected experts 

based on the depth of their experience and the extent to which their work 

had been cited by other experts, among other criteria. We selected labor 

representatives and worker advocacy organizations based on the number 

of workers and types of industries they represented. Our survey of 

occupational health practitioners included occupational physicians, 

occupational physician assistants, and nurse practitioners specializing in 

occupational health. We independently selected a random sample of each 

of the three groups, resulting in a sample of 409 of the 1,941 physicians; 

396 of the 1,246 physician assistants; and 382 of the 861 nurse 

practitioners, for a total representative sample of 1,187 of the 4,048 

occupational health practitioners. We identified these groups from 

information obtained from a firm that manages data on members of 

professional medical organizations. Our survey yielded a response rate 

that allowed us to generalize our results to the total population of the 

three groups. All estimates we report from the survey results have a 

margin of error of plus or minus 7 percentage points or less at the 95 

percent confidence level. A more detailed description of our scope and 

methodology is provided in appendix I. A copy of the instrument we used 

to survey health practitioners is provided in appendix II. Additional 

findings from our survey are provided in appendix III. 

 

1

Hereafter, all years cited in this report are calendar years unless otherwise noted. Records 

audits are almost always conducted 2 calendar years after the target data year. Of the 753 

records audits that were conducted for 2003-2005 records, 99.7 percent were conducted in 

2005-2007; two records audits were conducted in January and February of 2008. 

Page 2 GAO-10-10 Workplace Safety and Health
 

We conducted this performance audit from August 2008 through October 

2009 in accordance with generally accepted government auditing 

standards. These standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. 

Under the OSH Act, OSHA is responsible for protecting the safety and 

health of the nation’s workers. The agency helps ensure the safety and 

health of over 112.5 million private sector workers in approximately 8.6 

million worksites in the United States by setting and enforcing safety and 

health standards, rules, and regulations, and inspecting worksites to 

ensure employer compliance. OSHA helps to ensure safe and healthy 

working conditions for workers through its 11 national office directorates 

and 10 regional offices. The national office directorates include the 

Directorate of Enforcement Programs, which provides guidance to OSHA 

inspectors on how to enforce safety and health regulations and standards 

and how employers are to comply with them, and the Directorate of 

Evaluation and Analysis, which establishes policies and analyzes safety 

and health data. OSHA directly enforces safety and health regulations and 

standards in about half the states; the remaining states have each been 

granted authority by OSHA to set and enforce their own workplace safety 

and health standards for worksites under a state plan approved by OSHA 

(state-plan states).2

Background 

The OSH Act requires nonexempt employers to prepare and maintain 

records of injuries and illnesses sustained by their workers and make them 

 

2

In these states, the state standards must be at least as effective as the federal standards. 

See 29 U.S.C. § 667(c)(2). Most of the state-plan states cover public and private sector 

worksites. However, four states (Connecticut, New Jersey, New York, and the Virgin 

Islands) cover public sector (state and local government) worksites only; private sector 

worksites are covered by federal OSHA. Under the Occupational Safety and Health Act of 

1970, “state” is defined to include the District of Columbia, Puerto Rico, the Virgin Islands, 

American Samoa, Guam, and the Trust Territory of the Pacific Islands. See 29 U.S.C. § 

652(7). 

Page 3 GAO-10-10 Workplace Safety and Health
 

available to OSHA.3 The primary record employers are required to 

maintain is OSHA’s Form 300 Log of Work-Related Injuries and Illnesses 

(see app. IV). For each work-related injury and illness that requires 

medical treatment other than first aid, the employer is required to record 

the worker’s name; the date; a brief description of the injury or illness; and 

the number of days the worker was away from work, assigned to 

restricted duties, or transferred to another job as a result of the injury or 

illness. Employers are also required to describe each injury and illness on 

the Injuries and Illnesses Incident Report (OSHA’s Form 301). About 1.5 

million employers with more than 10 employees—representing about 17 

percent of the approximately 8.6 million private sector worksites and an 

estimated 53 million employees covered by OSHA—must keep such 

records. OSHA has established definitions and recordkeeping guidelines to 

assist employers in determining which injuries and illnesses must be 

recorded in their injury and illness logs. Injuries and illnesses serious 

enough to be recorded include those that result in lost work time, medical 

treatment other than first aid, restriction of work, loss of consciousness, 

or transfer to another job. OSHA requires employers to post summaries of 

their logs annually at each worksite and to provide them to OSHA and BLS 

if requested. OSHA’s recordkeeping standards, which took effect in 

January 2002, were intended to simplify the recordkeeping rules and forms 

used to record injuries and illnesses.4

OSHA also promotes workplace safety and health by targeting industries 

and employers with the highest number of workplace injuries and illnesses 

for inspection. OSHA does this through both programmed (scheduled) 

inspections and unprogrammed (unscheduled) inspections conducted by 

inspectors in area offices throughout its 10 U.S. regions. OSHA places the 

highest priority on unprogrammed inspections initiated in response to 

fatality investigations, formal complaints, referrals, and other situations 

that could pose a risk to the safety and health of workers. OSHA gives a 

lower priority to programmed inspections, which include those selected 

by OSHA through its Site-Specific Targeting program, which it uses to 

 

3

Generally, in addition to employers with 10 or fewer employees, DOL’s regulations exempt 

worksites in specific low hazard retail, service, finance, insurance, or real estate industries 

from OSHA’s recordkeeping requirements. However, all employers must report to OSHA 

any workplace incident that results in a fatality or the hospitalization of three or more 

employees. In addition, employers are required to respond to the OSHA and BLS surveys 

even if they are otherwise exempt from OSHA’s recordkeeping requirements. 

4

66 Fed. Reg. 5916. 

Page 4 GAO-10-10 Workplace Safety and Health
 

target high hazard worksites for inspection.5 Table 1 shows the number of 

programmed and unprogrammed inspections OSHA conducted from fiscal 

years 2003 through 2007. 

Table 1: Number of Inspections Conducted by OSHA, Fiscal Years 2003-2007 

Number of inspections FY 2003 % FY 2004 % FY 2005 % FY 2006 % FY 2007 %

Total inspections 39,778 100 39,112 100 39,828 100 38,537 100 39,323 100

Programmed inspections 22,436 56 21,576 55 21,404 54 21,506 56 23,035 59

Unprogrammed inspections 17,342 44 17,536 45 18,424 46 17,031 44 16,288 41

Fatality investigations 1,021 1,060 1,114 1,081 1,043

Complaints 7,969 8,062 7,716 7,376 7,055

Referrals 4,472 4,585 4,787 5,019 5,007

Other 3,880 3,829 4,807 3,555 3,183

Source: GAO based on OSHA data. 

BLS’s SOII includes injury and illness data from employers’ logs for about 

241,000 worksites; the ODI survey includes data from about 80,000 

worksites in high hazard industries.6

 The SOII is a coordinated federalstate effort that estimates the number of workplace injuries and illnesses 

that occur at worksites in most industries in the United States. Because 

the data come from OSHA logs, the injuries and illnesses counted by the 

survey are only those required by OSHA to be recorded. As such, the data 

differ from those collected by other systems, such as data collected using 

workers’ compensation claims. While BLS and OSHA collect the same 

basic information, they largely collect data from different employers. 

However, BLS estimates a potential overlap of less than 10 percent of 

employers who must complete both the BLS SOII and OSHA ODI surveys 

in a given year. In these cases, employers send the data to both BLS and 

OSHA because the agencies do not share data. Figure 1 shows the surveys 

and how they are used. 

 

5

In addition to targeting worksites for inspection through its Site-Specific Targeting 

program, OSHA also targets worksites through its national, regional, and local emphasis 

programs. 

6

The SOII excludes the self-employed; farms with fewer than 11 employees; private 

households; federal government agencies; and, for national estimates, employees in state 

and local government agencies. 

Page 5 GAO-10-10 Workplace Safety and Health
 

Figure 1: DOL’s Annual Occupational Injury and Illness Surveys 

Bureau of Labor Statistics Occupational Safety and

Health Administration SOII survey ODI survey

Sources: GAO analysis of DOL’s Annual Occupational Injury and Illness Surveys.

Trend data

Produces industry-based 

injury and illness statistics

used to identify national 

trends

Worksite-level data

Produce injury and 

illness rates used

to direct OSHA’s

enforcement efforts

0

100

200

300

400

2006

2007

2008

200

2004

2005

3

9/2008

5/2007

Number of claims (in thousands)

End of fiscal year

Employerreported data from

80,000 

worksites

Employerreported data from

241,000 

worksites

BLS’s data show a generally steady decline in the number and rate of 

injuries and illnesses reported by employers from 1992 to 2007 (see fig. 2). 

DOL officials often cite this decline as evidence of the success of OSHA’s 

workplace safety programs and its enforcement efforts. However, because 

of the SOII’s sole reliance on employer-reported injury and illness data, 

some academic studies have reported that the survey may undercount the 

total number of workplace injuries and illnesses.7

 OSHA officials stated 

that the decline has been driven by employer improvements to workplace 

safety and health, and by the decrease in the number of manufacturing 

jobs in the United States. According to BLS, manufacturing jobs in the 

 

7

See, for example, Leslie I. Boden and Al Ozonoff, “Capture-Recapture Estimates of 

Nonfatal Workplace Injuries and Illnesses,” Annals of Epidemiology, vol. 18, no. 6 (2008); 

Kenneth D. Rosenman, et al., “How Much Work-Related Injury and Illness is Missed By the 

Current National Surveillance System?,” Journal of Occupational and Environmental 

Medicine, vol. 48, no. 4 (2006); and J. Paul Leigh, James P. Marcin, and Ted R. Miller, “An 

Estimate of the U.S. Government’s Undercount of Nonfatal Occupational Injuries,” Journal 

of Occupational and Environmental Medicine, vol. 46, no. 1 (2004). 

Page 6 GAO-10-10 Workplace Safety and Health
 

United States have declined by almost 24 percent since 1998. The OSHA 

officials also said that the decline in the rate of U.S. occupational injuries 

and illnesses is consistent with declines in other countries. Data

International Labour Organization show that several countries 

experie

 from the 

nced declines in their rates of injuries and illnesses from 1992 to 

2006.8

Figure 2: Number and Rate of Injuries and Illnesses in the United States, 1990-2007 

0

1

2

3

4

5

6

7

8

9

0

1

2

3

4

5

6

7

8

9

200

2004

2005

2006

2007

3

199

1999

2000

2001

2002

8

199

1994

1995

1996

1997

3

1990

1991

1992

Year

Number of injured and ill workers (in millions) Rate of injuries per 100 full-time workers

Rate of injuries per 100

full-time workers

Number of injured

and ill workers

Source: BLS.

Note: Rule changes in 2002 may affect the comparability of the data in this time series. 

From the time the ODI was established in 1995, OSHA has annually 

surveyed about 80,000 of the approximately 130,000 worksites with 40 or 

 

yment. 

8

The International Labour Organization is the United Nations agency that brings together 

representatives of governments, employers, and workers of its member states to jointly 

shape polices and programs that promote decent and productive emplo

Page 7 GAO-10-10 Workplace Safety and Health
 

more workers it defines as being in high hazard industries.9 According to 

OSHA officials, the survey size is based on the budgetary resources OSHA 

had when the ODI was established. The agency uses data from the ODI to 

target employers for inspections, outreach, and technical assistance, and 

to measure its performance in reducing workplace injuries and illnesses

For example, OSHA provides employers with onsite assistance to help 

them identify and correct hazards and set up safety and health programs. 

OSHA also provides employers with training and education to help them

reduce worker accidents and injuries. The 130,000 worksites in the ODI 

universe are selected from manufacturing and 22 other industries O

defined as high hazard on the basis of their injury and illness rates 

reported by BLS in 2002: worksites with a lost workday injury and illne

(LWDII) rate of 5.0 or higher.

. 

SHA 

ss 

in the ODI, instead of using the current threshold of 40 or more employees. 

g 

or 

injury 

ffering 

n the average number of workers at each worksite 

(see fig. 3). 

 

10 To expand its coverage of high hazard 

worksites, OSHA included 20,000 construction worksites in its 2008 ODI. 

OSHA has also proposed including worksites with 30 or more employees 

OSHA and some state-plan states annually conduct onsite audits of 

employer injury and illness logs to verify the accuracy of the ODI data. 

While OSHA inspectors check employers’ injury and illness records durin

safety and health inspections, a records audit is the primary mechanism 

OSHA uses to verify the accuracy of the data submitted by employers f

the ODI. OSHA annually conducts records audits for a representative 

sample of approximately 250 of the 130,000 worksites included in its ODI 

survey. The primary purpose of a records audit is to verify that the 

and illness data submitted to OSHA are identical to the data in the 

employer’s injury and illness log and that they are accurate. The records 

audits OSHA conducted from 2005 to 2007 of employers’ 2003, 2004, and 

2005 injury and illness data occurred at a range of worksites of di

sizes based o

9

OSHA generally excludes from the ODI worksites with fewer than 40 employees; those in 

states that do not participate in the ODI; and all construction sites, hospitals, and general 

merchandise stores. The ODI also excludes worksites in the mining and railroad industries 

because their injuries and illnesses are tracked separately by the Mine Safety and Health 

Administration and the Federal Railroad Administration, respectively. 

10Until 2002, DOL used the LWDII rate to compare the rates of injuries and illnesses among 

worksites of varying sizes. The rate was calculated based on the total number of injuries or 

illnesses resulting in lost work days. In 2002, after revising its recordkeeping requirements, 

DOL began using the days away from work, restricted activity, or job transfer (DART) rate 

to compare injuries and illnesses among worksites instead of the LWDII rate. 

Page 8 GAO-10-10 Workplace Safety and Health
 

Figure 3: Number of Worksites Audited by Size, 2003-2005 

Number worksites audited

Target year

Source: OSHA.

Small worksites (40 to 99 workers)

Medium worksites (100 to 249 workers)

Large worksites (250 or more workers)

0

20

40

60

80

100

120

140

160

180

2003 2004 2005

The audits cover worksites in a variety of industries, including health 

services, trucking and warehousing, fabricated metal products, and 

printing and publishing (see table 2). 

Table 2: Number of Records Audits by Type of Industry, 2003-2005 

Number of audited worksitesa

Industry 2003 2004 2005 Total 

Agricultural production—crops 2 0 2 4

Agricultural production—livestock 1 0 0 1

Agricultural services 1 0 1 2

Food and kindred products 22 14 13 49

Tobacco manufacturers 0 0 0 0

Textile mill products 4 2 3 9

Apparel and other textile products 3 7 5 15

Lumber and wood products 7 4 11 22

Page 9 GAO-10-10 Workplace Safety and Health
 

Number of audited worksitesa

Industry 2003 2004 2005 Total 

Furniture and fixtures 7 5 4 16

Paper and allied products 4 7 6 17

Printing and publishing 12 14 7 33

Chemicals and allied products 9 12 9 30

Petroleum and coal products 1 1 0 2

Rubber and miscellaneous plastic 

products 14 16 9 39

Leather and leather products 1 0 0 1

Stone, clay, and glass products 5 8 8 21

Primary metal industries 8 7 9 24

Fabricated metal products 20 24 21 65

Machinery, except electrical 23 15 20 58

Electric and electronic equipment 11 16 12 39

Transportation equipment 8 3 10 21

Instruments and related products 8 6 5 19

Miscellaneous manufacturing 

industries 4 3 3 10

Trucking and warehousing 15 22 21 58

U.S. Postal Service 0 0 0 0

Water transportation 0 0 0 0

Transportation by air 6 2 2 10

Transportation services 0 0 1 1

Electric, gas, and sanitary services 3 2 2 7

Wholesale trade—durable goods 5 16 8 29

Wholesale trade—nondurable goods 8 7 8 23

Building materials and garden 

supplies 9 10 13 32

Health services 30 33 32 95

Total 251 256 245 752

Source: OSHA. 

a

OSHA surveys a portion of its ODI universe annually and as a result, an industry may be included 

one year and excluded the next. Therefore, industries in this table may not have any records audits 

for a given year because the industry was not included in that year’s ODI. 

Page 10 GAO-10-10 Workplace Safety and Health
 

Based on its analysis of OSHA’s records audits of employers’ 2003, 2004, 

and 2005 injury and illness data, Eastern Research Group, Inc.11 found an 

accuracy rate of over 90 percent for the total number of cases that were 

required to be recorded and those involving days away from work, 

restricted activity, or job transfer (DART).12 OSHA uses these findings to 

support the agency’s continued use of the ODI data to target worksites for 

enforcement and compliance assistance, and to measure the agency’s 

performance in reducing workplace injuries and illnesses. 

Although DOL is not required to, it verifies some of the workplace injury 

and illness data it collects from employers on the ODI survey via OSHA’s 

records audits. However, OSHA’s efforts to verify the accuracy of the data 

are not adequate because OSHA overlooks some information it could 

obtain from workers about injuries and illnesses during these audits that 

could help verify the accuracy of the data. In addition, OSHA excludes 

certain high hazard industries from its data collection efforts, which 

precludes them from being selected for records audits and makes them 

unlikely to be targeted by OSHA for inspections, outreach, and technical 

assistance. BLS does not verify the injury and illness data it collects from 

employers in the SOII that are used to report national injury and illness 

statistics and trends, but it has taken or is planning to take several actions 

to respond to concerns about the quality and completeness of the data. 

DOL Verifies the 

Injury and Illness 

Data in the ODI, but 

OSHA Does Not 

Always Collect 

Information from 

Workers, and 

Excludes Certain 

Industries 

OSHA Does Not Require 

Inspectors to Interview 

Workers during Records 

Audits 

OSHA does not require inspectors to interview workers during records 

audits about injuries and illnesses that they or their co-workers may have 

experienced. Although OSHA’s procedures manual states that inspectors 

must conduct interviews if they believe the records do not provide full and 

accurate information, it does not provide criteria for what constitutes “full 

and accurate” information. OSHA officials confirmed that it is optional for 

inspectors to interview workers during records audits. As a result, 

inspectors may miss opportunities to obtain information from workers 

about injuries and illnesses that may not have been properly recorded by 

 

11Eastern Research Group, Inc. is a private consulting firm that annually analyzes the 

records audit data collected by inspectors. 

12The DART rate is calculated by totaling the number of work-related injuries and illnesses 

that resulted in days away from work, job duty restrictions, or job transfer at a worksite; 

dividing by the total number of hours worked by all workers during the calendar year; and 

multiplying this number by 200,000, which represents a base for 100 full-time workers 

working 50 weeks per year. 

Page 11 GAO-10-10 Workplace Safety and Health
 

employers on their injury and illness logs. As noted in our previous work, 

there are potential risks in relying solely on employer-reported data.13

When OSHA inspectors conduct records audits, the audit procedures 

direct them to inspect the records of a random sample of workers at the 

worksites, among other things. These records, which are provided to the 

inspectors by the employer, can include workers’ compensation records, 

medical records, accident reports, and records of absences. 

In addition to reviewing these records, OSHA’s procedures provide 

inspectors with the option to interview workers. Worker interviews are the 

only source of information used during the audit not provided by the 

employer. If inspectors choose to interview workers, OSHA’s audit 

software generates a sample of workers to be interviewed from the initial 

random sample of workers. For the 753 records audits OSHA conducted of 

employers’ 2003, 2004, and 2005 injury and illness records, we found that 

inspectors chose to interview workers in about half of the audits. During 

our interviews, inspectors told us one challenge they face in interviewing 

workers is that many workers are no longer employed at the worksite or 

are unavailable to be interviewed at the time of the audit. Of these 

inspectors who conducted interviews, 9 of 14 reported they are rarely or 

never able to interview the full sample of workers. We examined the data 

for audits conducted from 2005 to 2007, and found that when inspectors 

interviewed workers, 72 percent of the time they did not interview the full 

number of workers recommended by the audit procedures. OSHA 

headquarters officials told us that, although the records audit procedures 

do not direct inspectors to substitute other workers to interview when the 

workers originally selected are unavailable, they always instruct 

inspectors to do so during records audit training. However, OSHA does not 

conduct all of the records audit training inspectors receive, and several of 

the inspectors we interviewed said they had not received this training. 

Lack of Timeliness in 

Conducting Interviews 

with Workers Can Affect 

Their Usefulness 

Interviewing workers might provide information to help inspectors 

evaluate the accuracy and completeness of employer-provided data; 

however, the lack of timeliness in conducting the interviews can affect 

their usefulness. Some inspectors told us that because OSHA does not 

conduct records audits until about 2 calendar years after the injuries and 

illnesses are recorded, inspectors rarely learn about underrecorded 

 

13GAO, Occupational Safety and Health: Changes Needed in the Combined Federal-State 

Approach, GAO/HEHS-94-10 (Washington, D.C.: Feb. 28, 1994). 

Page 12 GAO-10-10 Workplace Safety and Health
 

injuries or illnesses from the interviews. Because of this lag, inspectors 

told us many workers are no longer employed at the worksite and those 

who remain may be unable to remember the injury or illness. OSHA 

officials said the lag exists because, after the end of the calendar year in 

which the injury or illness is recorded, it takes OSHA a full year to collect 

the data and up to 9 additional months to conduct the records audits. For 

example, in early 2008, OSHA selected the ODI worksites for the calendar 

year 2007 injury and illness data. OSHA then spent a year collecting the 

data from employers. After collecting the data, OSHA selected worksites 

for records audits in early 2009, and generally gave inspectors until the end 

of September to complete the audits. As a result, if a worker was injured in 

January 2007, OSHA might not examine the employer’s records or 

interview the worker about the injury until the summer or fall of 2009—21⁄2 

years after the injury occurred. Figure 4 depicts the timeline for the 

process and the activities performed. In comparison, it takes BLS 

approximately 10 months to both collect and report the SOII data; 

however, BLS does not conduct follow-up verifications like OSHA’s 

records audits. 

Figure 4: Timeline for Collecting and Auditing Employers’ Injury and Illness Records 

Source: GAO analysis of information provided by OSHA.

Year 1 Year 2 Year 3

Employers at worksites record worker

injuries and illnesses on OSHA’s Form 300

Log of Work-Related Injuries and Illnesses

OSHA selects

worksites from which 

to collect the summary 

of the previous year’s

Form 300

OSHA selects

worksites for 

records audits

Inspectors conduct records audits

OSHA collects summary

of the Form 300 from employers

OSHA’s ODI Universe 

Excludes Eight High 

Hazard Industries 

Worksites under eight high hazard industries cannot be selected for 

records audits or targeted for OSHA’s enforcement and compliance 

activities, because OSHA has not updated its list of high hazard industries 

included in the ODI universe since 2002. (See app. V for a list of high 

hazard industries included in the ODI universe.) OSHA has neither a 

formal written policy on how or when to update the list of industries 

included in the ODI, nor clear documentation that explains the original 

construction of the ODI or its subsequent updates. We first reported on 

OSHA’s lack of documentation for its ODI industry selection process in 

Page 13 GAO-10-10 Workplace Safety and Health
 

1998.14 By not updating its high hazard industry list using the most recent 

BLS SOII data, we found that OSHA is excluding eight high hazard 

industries that had an average DART rate of 4.2, which is higher than twice 

the national average or greater, for the three most recent years, from 2005 

to 2007. Industries excluded include amusement parks, industrial 

launderers, and general rental centers (see table 3). As a result, worksites 

in these industries are precluded from being selected for OSHA’s records 

audits and they are unlikely to be targeted by OSHA for inspections, 

outreach, and technical assistance. Table 3 shows the industries excluded 

from the ODI universe. 

Table 3: Industries That Would be High Hazard if OSHA Updated Its ODI Universe 

NAICS codea

Industry 

22133 Steam and air-conditioning supply 

483113 Coastal and Great Lakes freight transportation 

53212 Truck, utility trailer, and RV (recreational vehicle) rental and leasing 

5323 General rental centers 

7131 Amusement parks and arcades 

71392 Skiing facilities 

812331 Linen supply 

812332 Industrial launderers 

Source: GAO analysis of DOL data. 

a

NAICS = North American Industry Classification System. 

OSHA officials told us they have not updated the high hazard list because 

an agency regulation requires them to use the Standard Industrial 

Classification (SIC) system to classify industries, rather than the North 

American Industry Classification System (NAICS) industry codes currently 

used by BLS to report injury and illness rates. Prior to 2003, both OSHA 

and BLS used the SIC codes to classify industries. OSHA officials said they 

would like to switch to the NAICS codes, but they stated it is not currently 

an agency priority to pursue the regulatory change required to do so. In 

addition to a regulatory change, switching to NAICS would require OSHA 

to re-evaluate the criteria it uses to define industries as high hazard 

because in 2002, OSHA switched from using the LWDII rate to the DART 

 

14GAO, Occupational Safety and Health: Efforts to Obtain Establishment-Specific Data 

on Injuries and Illnesses, GAO-98-122 (Washington, D.C.: May 22, 1998). 

Page 14 GAO-10-10 Workplace Safety and Health
 

rate for measuring workers’ injuries and illnesses.15 Because the LWDII 

and DART are not exactly comparable, OSHA would have to identify a 

DART rate that is comparable to its LWDII rate of 5.0, which was the 

criterion OSHA used in 2002 to define a high hazard industry. According to 

our analysis, the results of which we confirmed through discussions with 

OSHA officials, a 4.2 DART rate is comparable to a 5.0 LWDII rate. 

BLS Does Not Verify 

Employer-reported Data in 

the SOII, but Has 

Undertaken Actions to 

Improve the Quality and 

Completeness of the Data 

BLS is not required to verify the accuracy of the data employers record on 

their OSHA forms; however, BLS has acknowledged limitations to the 

survey and has taken steps to improve it. BLS uses the SOII to report 

national, industry-wide injury and illness data, and policymakers and 

employers rely on the data to understand national trends in worker safety 

and health. The SOII only includes injury and illness data provided by 

employers. In contrast, BLS reports monthly employment statistics with 

data from employers on the number of jobs and from households on the 

number of people employed. A number of studies have compared the BLS 

data on injuries and illnesses to data collected from other sources, such as 

workers’ compensation, hospital discharge data, and medical records.16

These studies found discrepancies between the number of injuries and 

illnesses reported in the SOII and the information in the other data sets. 

Some researchers have also criticized the scope of the SOII, noting, for 

example, that the 14.7 percent of all workers in 1999 who were 

government workers and the 7.3 percent of all workers who were selfemployed were not included in the SOII.17

In response to questions about the accuracy of the employer-reported SOII 

data, BLS has taken several actions designed to improve the quality and 

 

15The DART rate is calculated using the same formula as the LWDII rate; however, the rates 

do not count the exact same injuries and illnesses. 

16SM Marsh, SJ Derk, and LL Jackson, “Nonfatal Occupational Injuries and Illnesses Among 

Workers Treated in Hospital Emergency Departments—United States, 2003,” Morbidity 

and Mortality Weekly Report, vol. 55, no. 16 (2006); Rosenman, et al., “How Much WorkRelated Injury and Illness is Missed By the Current National Surveillance System?,” Journal 

of Occupational and Environmental Medicine, vol. 48, no. 4 (2006); J. Paul Leigh, James 

P. Marcin, and Ted R. Miller, “An Estimate of the U.S. Government’s Undercount of 

Nonfatal Occupational Injuries,” Journal of Occupational and Environmental Medicine, 

vol. 46, no. 1 (2004). 

17Leigh, Marcin, and Miller, “An Estimate of the U.S. Government’s Undercount of Nonfatal 

Occupational Injuries,” Journal of Occupational and Environmental Medicine, vol. 46, no. 

1 (2004). 

Page 15 GAO-10-10 Workplace Safety and Health
 

completeness of the data. For example, to address concerns about the 

survey’s limited scope, BLS expanded the SOII for its 2008 survey to 

include data on state and local government workers in all states and 

conducted a quality assurance study to verify that employers correctly 

transcribed information from their 2006 OSHA logs onto BLS’s SOII survey 

forms. BLS also interviewed employers to determine how they record 

injury and illness data on the OSHA and workers’ compensation forms. 

The aim of this effort was to identify cases where employers reported an 

injury or illness to the state’s Workers’ Compensation program, but did not 

record the cases on the OSHA log, despite the fact that the injury or illness 

was an OSHA-recordable case. In addition, in a 2009 research study, BLS 

examined discrepancies between the number of workplace injuries and 

illnesses reported in states’ workers’ compensation databases and in the 

SOII to address concerns about data accuracy. From the research, BLS 

identified some factors associated with discrepancies between the SOII 

and workers’ compensation data, and is continuing to conduct research to 

identify additional potential factors. BLS stated that some of the 

discrepancies arose from cases that were compensable, but in which 

workers had no days away from work, and cases that entered workers’ 

compensation after the end of the year, but did appear in the BLS data. 

In addition to the actions it has already taken, BLS is planning to explore 

the use of other data sets to improve the quality of the SOII data. For 

example, BLS officials told us they plan to support the work of the 

National Institute for Occupational Safety and Health to explore the use of 

occupational injury and illness data collected by emergency departments 

to help identify gaps in the SOII data.18 The emergency department data 

could be particularly important because they would capture injuries and 

illnesses for self-employed workers, who are currently excluded from the 

SOII. In addition, since these data are reported by hospitals and not 

employers, they could help BLS identify underrecorded injuries and 

illnesses. Finally, BLS is planning to work with the Council of State and 

Territorial Epidemiologists to evaluate the quality of the SOII data for 

 

18The National Institute for Occupational Safety and Health (NIOSH), part of the Centers 

for Disease Control and Prevention within the Department of Health and Human Services, 

is the federal agency responsible for conducting research and making recommendations to 

prevent workplace injuries and illnesses. One of the research projects that NIOSH is 

conducting is the national surveillance of nonfatal occupational injuries using the National 

Electronic Injury Surveillance System (NEISS). This project collects nationally 

representative, timely, nonfatal occupational injury surveillance data by using a sample of 

U.S. hospital emergency departments through NEISS. 

Page 16 GAO-10-10 Workplace Safety and Health
 

certain injuries such as amputations and carpal tunnel syndrome.19 BLS 

has issued grants to three states to evaluate the possibility of using 

multiple sources of data to enumerate the quality of the SOII for certain 

injuries such as amputations and carpal tunnel syndrome. 

Disincentives that influence workers’ decisions to report and employers’ 

decisions to record work-related injuries and illnesses are primary factors 

that may affect the accuracy of the data, according to occupational safety 

and health practitioners and stakeholders. They also reported that a lack 

of understanding of OSHA’s recordkeeping requirements by those 

responsible for recording injuries and illnesses may affect the accuracy of 

the data. 

Occupational Safety 

and Health 

Practitioners and 

Stakeholders Cited 

Worker and Employer 

Disincentives as 

Primary Factors That 

May Affect the 

Accuracy of Injury 

and Illness Data 

Various Disincentives May 

Discourage Workers from 

Reporting and Employers 

from Recording Injuries 

and Illnesses 

Occupational safety and health stakeholders we interviewed and 

occupational health practitioners we surveyed told us that primary factors 

affecting the accuracy of injury and illness data include disincentives that 

affect workers’ decisions to report work-related injuries and illnesses and 

employers’ decisions to record them. Stakeholders most often cited 

workers’ fear of job loss and other disciplinary actions as disincentives 

that can affect workers’ decisions to report injuries and illnesses. 

Occupational health practitioners concurred: 67 percent reported 

observing worker fear of disciplinary action for reporting an injury or 

illness, and 46 percent said that this fear of disciplinary action has at least 

a minor impact on the accuracy of employers’ injury and illness records. 

Workers’ fear of disciplinary actions may be compounded by policies at 

some worksites that require workers to undergo mandatory drug testing 

following incidents resulting in reported injuries or illnesses, regardless of 

 

19The Council of State and Territorial Epidemiologists is a professional organization of 

public health epidemiologists working in state, territorial, or local health departments, and 

individuals from federal health agencies or academia. It works to establish more effective 

relationships among states and other health agencies and provides technical advice and 

assistance to partner organizations. 

Page 17 GAO-10-10 Workplace Safety and Health
 

any evidence of drug use. Several labor representatives described 

mandatory drug testing policies as a disincentive that affects workers’ 

decisions to report injuries and illnesses, and 67 percent of health 

practitioners reported they were aware of this practice at the worksites 

where they treated workers in 2008. 

Stakeholders also said employers’ safety incentive programs can serve as 

disincentives for workers reporting injuries and illnesses. These programs 

reward workers when their worksites have few recordable injuries or 

illnesses. One-half of the health practitioners who responded to our survey 

reported they were aware of incentive programs at the worksites where 

they treated workers in 2008. Safety incentive programs are designed to 

promote safe behavior by workers, and 72 percent of health practitioners 

reported that these programs motivate workers to work in a safe manner. 

However, some stakeholders said these programs can discourage workers 

from reporting injuries and illnesses; more than three-quarters of health 

practitioners said they believed workers sometimes avoid reporting workrelated injuries and illnesses as a result. Stakeholders also said that in 

addition to missing the chance to win prizes for themselves, workers who 

report injuries and illnesses may risk ruining their coworkers’ chances of 

winning such prizes. 

Various disincentives may also discourage employers from recording 

workers’ injuries and illnesses. Stakeholders told us employers are 

concerned about the impact of higher injury and illness rates on their 

workers’ compensation costs. Several researchers and labor 

representatives said that because employers’ workers’ compensation 

premiums increase with higher injury and illness rates, employers may be 

reluctant to record injuries and illnesses. They also said businesses 

sometimes hire independent contractors to avoid the requirement to 

record workers’ injuries and illnesses because they are not required to 

record them for self-employed individuals.20 Stakeholders also told us 

employers may not record injuries and illnesses because having high 

injury and illness rates can affect their ability to compete for contracts for 

new work. The injury and illness rate for worksites in certain industries, 

such as construction, affects some employers’ competitiveness in bidding 

on the same work. 

 

20However, under DOL regulations, if an employer supervises a contractor’s employee on a 

day-to-day basis, the employer must record the employee’s injury or illness. 29 C.F.R. § 

1904.31(b)(3). 

Page 18 GAO-10-10 Workplace Safety and Health
 

Disincentives that discourage workers from reporting and employers from 

recording injuries and illnesses may also result in pressure on 

occupational health practitioners to treat workers in a manner that avoids 

the OSHA requirement to record injuries and illnesses. From our survey, 

we found that more than one-third of health practitioners were asked by 

company officials or workers to provide treatment that resulted in an 

injury or illness not being recorded, but also was not sufficient to properly 

treat the injury or illness. For example, in some cases, practitioners stated 

that employers may seek out alternative diagnoses if the initial diagnosis 

would result in a recordable injury or illness. One practitioner said that an 

injured worker’s manager took the worker to multiple providers until the 

manager found one who would certify that treatment of the injury required 

only first aid, which is not a recordable injury. Fifty-three percent of the 

health practitioners reported that they experienced pressure from 

company officials to downplay injuries or illnesses, and 47 percent 

reported that they experienced this pressure from workers. Further, 44 

percent of health practitioners stated that this pressure had at least a 

minor impact on whether injuries and illnesses were accurately recorded, 

and 15 percent reported it had a major impact. In some cases, this 

pressure may be related to the employers’ use of incentive programs. Of 

those experiencing pressure from workers, 61 percent reported they were 

aware of incentive programs at the worksites where they treated workers 

(see fig. 5). In comparison, of the practitioners who reported not 

experiencing pressure from workers in 2008, 41 percent reported being 

aware of incentive programs at the worksites where they treated workers. 

Page 19 GAO-10-10 Workplace Safety and Health
 

Figure 5: Pressure From Workers to Downplay Injuries and Illnesses and 

Awareness of Incentive Programs 

6%

47%

48% 24%

16%

61%

Not sure

Not sure

Yes

No Yes No

Did you experience pressure 

from workers to downplay 

injuries or illnesses in 2008?

Did any of the worksites where you 

treated workers in 2008 have 

incentive programs?

Source: GAO analysis of occupational health practitioner survey data.

An OSHA official told us that OSHA does not have an official policy on 

incentive programs or practices that may affect workers’ decisions to 

report injuries and illnesses, but it has authority under the OSH Act to 

discourage inaccurate reporting by employers. The official stated that, 

under a planned National Emphasis Program, OSHA will explore the 

possible impact that incentive programs have on workers’ decisions to 

report injuries and illnesses. To address disincentives that may affect 

employers’ decisions to accurately record injuries and illnesses, the 

official stated OSHA can issue citations or fine employers when 

recordkeeping violations are found. 

Lack of Understanding of 

OSHA’s Recordkeeping 

Requirements and Other 

Factors May Also Affect 

the Accuracy of the Injury 

and Illness Data 

Several stakeholders and nearly all of the OSHA inspectors we interviewed 

said that the lack of understanding of OSHA’s recordkeeping requirements 

by the individuals charged with recording injuries and illnesses affects the 

accuracy of the injury and illness data. Forty-one percent of occupational 

health practitioners reported that misinterpretation of OSHA’s 

recordkeeping requirements by company officials has an impact on 

whether injuries and illnesses are accurately recorded (see fig. 6). Several 

Page 20 GAO-10-10 Workplace Safety and Health
 

researchers and a representative from a labor organization with whom we 

spoke said that inaccuracies in recording injuries and illnesses can result 

from a lack of understanding of the differences between OSHA’s 

recordkeeping requirements and the eligibility criteria for workers’ 

compensation claims. They stated that some individuals charged with 

maintaining employers’ OSHA logs erroneously think that the criteria for 

recording injuries and illnesses are the same as the eligibility criteria for 

filing workers’ compensation claims. Therefore, they may be less likely to 

record injuries and illnesses that are not compensable through the 

workers’ compensation system. In addition, some stakeholders said they 

thought the lack of understanding among those recording injuries and 

illnesses was likely worse in smaller companies with fewer resources than 

larger companies, which have a greater capacity for providing 

recordkeeping training. 

Figure 6: Reported Impact of Misinterpretation of Recordkeeping Requirements on 

Records Accuracy 

Source: GAO analysis of occupational health practitioner survey data.

What impact does misinterpretation of 

recordkeeping requirements by 

company officials have on records

accuracy?

11%

21%

30%

38%

Not sure

Major

impact

No impact

Minor

impact

OSHA provides a number of tools to assist employers in understanding its 

recordkeeping requirements. For example, the form employers use to 

record injuries and illnesses—the OSHA injury and illness log—provides 

examples of which injuries and illness must be recorded and how to 

record them. OSHA also posts guidance and frequently asked questions 

about its recordkeeping requirements on its Web site. In addition, OSHA 

officials told us employers with recordkeeping questions can phone 

Page 21 GAO-10-10 Workplace Safety and Health
 

officials in OSHA headquarters and area offices, or e-mail questions to 

OSHA via its Web site. They also said they have considered creating an 

online tool to help employers quickly and easily determine whether to 

record specific injuries and illnesses on their logs. 

Stakeholders also discussed additional factors that may affect the 

accuracy of employers’ data, including weaknesses in OSHA’s 

enforcement efforts and the difficulty of determining whether some 

illnesses are work related. Several stakeholders pointed to weaknesses in 

OSHA’s enforcement efforts as a reason for inaccuracies in employers’ 

injury and illness data. For example, some stakeholders noted that OSHA’s 

enforcement of recordkeeping practices has diminished in recent years. 

Two stakeholders said OSHA’s enforcement capabilities could be 

strengthened with additional resources. Another factor a few researchers 

cited that could affect the accuracy of injury and illnesses data is that 

illnesses, particularly those with long latency periods, are less likely to be 

reported by workers and recorded by employers than injuries. They 

explained that, for many of these illnesses, it is difficult to prove they were 

caused by work-related activities. 

Workers are entitled to safe and healthful workplaces, and it is DOL’s 

responsibility to track the safety and health of the nation’s workplaces and 

ensure that employers take steps to minimize workers’ risks of injuries 

and illnesses. Accurate injury and illness records are important because 

they assist Congress, researchers, OSHA, BLS, and other agencies in 

describing the nature and extent of occupational safety and health 

problems. These records are also vital to helping employers and workers 

identify and correct safety and health problems in the workplace. In 

addition, these records help OSHA evaluate programs, allocate resources, 

and set and enforce safety and health standards. Without accurate records, 

employers engaged in hazardous activities can avoid inspections because 

OSHA bases many of its safety inspections on work-related injury and 

illness rates. 

Conclusions 

Because injury and illness data are so vital, it important that OSHA and 

BLS take steps to ensure that the data are as accurate as possible. First, 

OSHA inspectors must take advantage of opportunities to verify the 

accuracy and completeness of employer-provided records by interviewing 

workers who may be aware of injuries and illness that may not have been 

recorded by employers. It is also important that OSHA conduct its records 

audits as soon as possible after it collects employers’ injury and illness 

data to maximize the usefulness of information collected from worker 

Page 22 GAO-10-10 Workplace Safety and Health
 

interviews. In addition, it is imperative that employers understand which 

injuries and illnesses should be recorded under OSHA’s recordkeeping 

standards. Finally, although BLS has taken steps to improve the quality of 

the injury and illness data it collects, these actions will not address all of 

the concerns regarding the accuracy of the injury and illness data that BLS 

collects and reports. As these data are the only comprehensive source of 

national data on workers’ injuries and illnesses, it will be important for 

BLS to follow through on its efforts. 

To improve OSHA’s efforts to verify the accuracy of employer-provided 

injury and illness data, the Secretary of Labor should direct the Assistant 

Secretary for OSHA to take the following three actions: 

• require inspectors to interview workers during the records audits to obtain 

information on injuries or illnesses and substitute other workers when 

those initially selected for interviews are not available; 

• minimize the amount of time between the date injuries and illnesses are 

recorded by employers and the date they are audited by OSHA; and 

• update the list of high hazard industries used to select worksites for 

records audits and target inspections, outreach, and technical assistance. 

To improve the accuracy of the data recorded by employers on workers’ 

injuries and illnesses, the Secretary of Labor should direct the Assistant 

Secretary for OSHA to 

• increase education and training provided to employers to help them 

determine which injuries and illnesses should be recorded under the 

recordkeeping standards, such as providing assistance to employers via 

the online tool that OSHA is considering. 

We provided a draft of this report to the Secretary of Labor for comment. 

We received written comments from the Acting Assistant Secretary for 

OSHA, which are reproduced in their entirety in appendix VI. OSHA and 

BLS also provided technical comments, which we incorporated in the 

report as appropriate. 

Recommendations for 

Executive Action 

Agency Comments 

and Our Evaluation 

Page 23 GAO-10-10 Workplace Safety and Health
 

OSHA agreed with all of our recommendations and stated that it would 

move forward to implement them. To address the first two 

recommendations, OSHA stated that it would require inspectors to 

interview employees during records audits and develop policies to 

conduct record audits inspections in a timely fashion. For the third 

recommendation, OSHA stated that it would pursue rulemaking at the 

earliest possible date to update the industry coverage of the recordkeeping 

rule from the SIC system to NAICS, which would ensure that records 

audits include emerging high-risk industries. To address our fourth 

recommendation, OSHA stated that it would supplement its current 

educational outreach and develop a Web-based tool to assist employers in 

meeting the requirements of OSHA’s recordkeeping regulations. OSHA 

also informed us that it implemented a National Emphasis Program (NEP) 

on Recordkeeping on October 1, 2009. The purpose of the NEP is to 

identify and correct recordkeeping inaccuracies and complement BLS’s 

efforts to investigate factors accounting for differences in the number of 

workplace injuries and injuries estimated by BLS and other data sources. 

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to the Secretary 

of Labor, relevant congressional committees, and other interested parties. 

In addition, the report will also be available at no charge on GAO’s Web 

site at http://www.gao.gov. 

A list of related GAO products is included at the end of this report. If you 

or your staff have questions about this report, please contact me at 

(202) 512-7215 or moranr@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. Key contributors to this report are listed in appendix VII. 

evae E. Moran 

Acting Director, Education, Workforce 

curity Issues 

R

 and Income Se

Page 24 GAO-10-10 Workplace Safety and Health
 

List of Requesters 

The Honorable Tom Harkin 

Chairman 

Committee on Health, Education, 

 Labor, and Pensions 

United States Senate 

The Honorable Patty Murray 

Chair 

Subcommittee on Employment and 

 Workplace Safety 

Committee on Health, Education, 

 Labor, and Pensions 

United States Senate 

The Honorable George Miller 

Chairman 

Committee on Education and Labor 

House of Representatives 

The Honorable Lynn Woolsey 

Chairwoman 

Subcommittee on Workforce Protections 

Committee on Education and Labor 

House of Representatives 

Page 25 GAO-10-10 Workplace Safety and Health
Appendix I: Scope and Methodology 

Page 26 GAO-10-10 

Appendix I: Scope and Methodology 

To examine whether the Department of Labor (DOL) verifies that 

employers are accurately recording workers’ injuries and illnesses, and, if 

so, the adequacy of such efforts, we focused on the efforts of DOL’s 

Occupational Safety and Health Administration (OSHA) to verify the data 

it collects from employers on workers’ injuries and illnesses through its 

annual OSHA Data Initiative (ODI) survey. We analyzed OSHA’s policies 

and procedures and interviewed OSHA officials regarding the agency’s 

employer recordkeeping requirements. In addition, we reviewed the 

Bureau of Labor Statistics’ (BLS) efforts to verify the data it collects for 

the Survey of Occupational Injuries and Illnesses (SOII). 

Review of the 

Department of Labor’s 

Efforts to Verify the 

Accuracy of 

Employer-Reported 

Injury and Illness 

Data 

Analysis of OSHA’s Audits 

of Employer Injury and 

Illness Records 

We analyzed the results of the onsite audits of employers’ injury and 

illness records (records audits) OSHA conducted in 2005, 2006, and 2007 

of employers’ injury and illness logs for 2003, 2004, and 2005—the most 

recent period for which data were available. Prior to our analysis, we 

assessed the reliability of the database OSHA uses to track its records 

audits—the OSHA Recordkeeping Audit Assistant—by reviewing 

information obtained from OSHA about the database, interviewing 

knowledgeable agency officials, and performing electronic testing of the 

software, among other steps. On the basis of our assessment, we 

concluded that the data maintained by OSHA in its database were 

sufficiently reliable for our reporting purposes. 

Interviews of OSHA 

Inspectors Who Audit 

Employers’ Injury and 

Illness Records 

We interviewed selected OSHA inspectors who conducted the records 

audits in 2005, 2006, and 2007 to learn about (1) the training they received, 

(2) the extent to which they followed OSHA’s procedures for the records 

audits, and (3) their views on the accuracy of the employers’ injury and 

illness records they reviewed. Although we did not seek to generalize the 

responses of individual inspectors to the broader group of all inspectors 

who conducted these audits, we took steps to ensure that we had a mix of 

inspectors. We interviewed inspectors in states where federal OSHA 

directly enforces safety and health regulations and standards and those in 

states that have been approved by OSHA to conduct such activities (stateplan states).1

 These inspectors had a range of experience as determined by 

the number of audits they conducted in 2005, 2006, and 2007. We selected 

two inspectors for these interviews in each of OSHA’s 10 regions—1 

 

1

In some state-plan states, federal OSHA inspectors conduct these audits and, in others, 

state inspectors conduct the records audits. 

 Workplace Safety and Health 
Appendix I: Scope and Methodology 

inspector who conducted the greatest number of records audits and 1 who 

conducted the fewest number. Although we attempted to select 2 

inspectors in each region, we were only able to interview 1 inspector in 1 

of the regions because only 1 inspector in that region conducted records 

audits during the 3-year period we reviewed. As a result, we interviewed a 

total of 19 inspectors, including 12 federal and 7 state inspectors. In each 

of the 10 regions, we also interviewed other regional staff to obtain their 

views about the records audits. We interviewed the regional administrator, 

the deputy regional administrator, or someone designated as representing 

their views in each region. In addition, we interviewed 8 officials from 6 

regions who were area directors, records audit coordinators, or 

supervisors. 

Analysis of the Methods 

OSHA Uses to Select 

Worksites for Records 

Audits Using the ODI 

Universe 

To understand OSHA’s process for selecting worksites for records audits, 

we interviewed federal OSHA officials about the methods they use to 

select worksites from the ODI universe. We also analyzed the methods 

they use to compile and update the ODI universe, which is used to select 

worksites for records audits, and target worksites for safety and health 

inspections, outreach, and technical assistance. 

As part of this work, we examined the methods OSHA uses to define 

industries as “high hazard,” which makes the worksites in these industries 

eligible to be selected by OSHA for records audits and targeted for safety 

and health inspections.2

 In defining the industries to be included in the 

ODI, OSHA uses industry-level data published by BLS prior to 2002 based 

on the employer data collected in the Survey of Occupational Injuries and 

Illnesses (SOII) on the incidence rates of occupational injuries and 

illnesses resulting in lost work days (referred to as Lost Work Day Injuries 

and Illnesses [LWDII]) using Standard Industrial Classification (SIC) 

codes. In 2003, BLS began publishing SOII data using North American 

Industry Classification System (NAICS) codes to categorize industries 

instead of SIC codes. 

When OSHA last updated its ODI universe, it included manufacturing and 

industries with an LWDII rate of 5.0 or greater; at that time, 5.0 was twice 

 

2

OSHA only verifies the accuracy of employers’ injury and illness records for worksites in 

industries defined by OSHA as being high hazard industries—industries with an average 

occupational injury and illness rate of 5.0 or higher based on injuries or illnesses that result 

in lost work days due to injuries and illnesses—based on rates published by BLS prior to 

2002. 

Page 27 GAO-10-10 Workplace Safety and Health
Appendix I: Scope and Methodology 

the national injury and illness rate. Since OSHA has not updated the ODI 

universe since 2002, it has not yet established a new threshold for 

inclusion based on the days away, restricted or transferred (DART) rate 

measurement it now utilizes. Based on our analysis of current BLS data, 

we determined that a current DART rate of 4.0 was comparable to OSHA’s 

LWDII rate of 5.0 in 2002. In order to determine which industries are high 

hazard using current data, we first converted the high hazard industries in 

OSHA’s ODI universe from the SIC codes OSHA provided to GAO into the 

comparable NAICS codes. We then examined the incidence of injuries and 

illnesses in industries that were not in the ODI universe, and designated as 

potentially high hazard those that had a DART rate of 4.0 or higher in any 

year in the 5-year period from 2003 to 2007, which resulted in a list of 33 

potentially high hazard industries. We asked OSHA officials to review the 

list of 33 industries and identify any that were not under their jurisdiction 

or were otherwise inappropriate for inclusion in the ODI. The officials 

stated that a DART rate of 4.2—twice the national average—is the 

threshold they would use to determine which industries are high hazard. 

After we removed the 8 industries with DART rates below 4.2, we found 26 

industries that might be eligible for inclusion in the ODI universe. OSHA 

officials also told us that they used a 3-year average injury and illness rate 

to determine eligibility for inclusion in the ODI universe. Of the 26 

industries, we found that 12 had average DART rates for 2005 to 2007 that 

were lower than the 4.2 threshold and were therefore not eligible for 

inclusion. Five others were not appropriate for inclusion in the ODI 

because they did not fall under the agency’s jurisdiction or were 

comprised mostly of small employers. One remaining industry of the 26 

was already included in the ODI under a different, but related, NAICS 

code. After obtaining OSHA’s input, we identified 8 industries that could 

be included in the ODI universe if OSHA updated the universe using 

NAICS codes and current BLS data. 

Page 28 GAO-10-10 Workplace Safety and Health
Appendix I: Scope and Methodology 

To examine the factors that may affect the accuracy of employers’ injury 

and illness records, we selected various experts and researchers to 

interview based on (1) the individual’s title, affiliation, and type and depth 

of experience; (2) the extent to which the individual’s published work has 

been cited by other studies, and by OSHA, BLS, and other relevant 

organizations; (3) recommendations from other stakeholders; (4) the 

relevance of the individual’s work; and (5) the source of funding of the 

individual’s published work. By reviewing the literature on occupational 

injury and illness data, and other efforts, we identified 12 experts and 

researchers for our interviews.3

 We vetted this group with (1) the director 

of safety and health at a major organization representing labor issues and 

concerns; (2) a BLS official from the Office of Compensation and Working 

Conditions who published a 2008 article addressing the accuracy of injury 

and illness data; and (3) a researcher at the National Institute for 

Occupational Safety and Health (NIOSH) who heads an effort to collect 

national occupational injury and illness data from a representative sample 

of emergency departments in the United States. 

Discussions with 

Stakeholders of 

Factors That Affect 

the Accuracy of 

Employers’ Injury and 

Illness Records 

We surveyed three categories of occupational health practitioners about 

how they treat injured or ill workers; the extent of their involvement with 

OSHA recordkeeping responsibilities; their views on worksite safety 

incentive programs; and their perspectives on factors that affect the 

completeness and accuracy of employer records of workplace injuries and 

illnesses. We surveyed (1) occupational physicians identified on lists 

compiled by the American Medical Association of all practicing physicians 

in the United States with a primary specialty of occupational medicine, (2) 

occupational physician assistants identified on lists compiled by the 

American Academy of Physician Assistants of all certified physician 

assistants in the United States who specialize in occupational medicine, 

and (3) nurse practitioners specializing in occupational health identified 

on lists compiled by a medical information broker of all nurse 

practitioners in the United States. 

GAO Survey of 

Occupational Health 

Practitioners 

Study Population, Sample 

Frame, and Sample Design 

We designed and implemented a dual mode survey (mail and Web-based) 

to obtain information from occupational health practitioners. We obtained 

 

3

Although we interviewed all 12 of the experts and researchers, we did not include the 

results from 1 researcher because that individual’s responses were not pertinent to our 

questions. 

Page 29 GAO-10-10 Workplace Safety and Health
Appendix I: Scope and Methodology 

lists of the occupational health practitioners from Medical Marketing 

Service, a data management firm providing medical lists to marketers, 

researchers, and government agencies. We constructed our universe of 

physicians from the American Medical Association’s Physician Masterfile 

of all practicing physicians in the United States with a primary specialty of 

occupational medicine; our universe of physician assistants from the 

American Academy of Physician Assistants’ list of physician assistants 

specializing in occupational medicine; and our universe of nurse 

practitioners from a comprehensive list of nurse practitioners specializing 

in occupational health. We independently selected a random sample from 

each of the three groups, resulting in a sample of 409 of the 1,941 

physicians; 396 of the 1,246 physician assistants; and 382 of the 861 nurse 

practitioners, for a sample of 1,187 of the total 4,048 occupational health 

practitioners. Due to the results of our nonresponse analysis (described 

below) we restricted our sample of physician assistants to those who were 

certified, which resulted in a sample size of 340 certified physician 

assistants. Therefore, our resulting total sample was 1,131 (see table 4). 

Out of the sample of 1,131 health practitioners, 504 completed the 

questionnaires, for a total response rate of 45 percent. This response rate 

allowed us to generalize our results to the total population of the three 

groups. All estimates we report from the survey results (including those in 

this appendix) have a margin of error of plus or minus 7 percentage points 

or less at the 95 percent confidence level. See table 4 for the disposition of 

the three separate groups of health practitioners. 

Table 4: Disposition of Health Practitioner Sample 

Practitioner group Sample size Completed responses Response rate

Physicians 409 191 47%

Physician Assistants 340 163 48%

Nurse Practitioners 382 150 39%

Total 1,131 504 45%

Source: GAO analysis of occupational health practitioner survey data. 

The sample size for each practitioner group was determined to be able to 

detect a 10 percent difference between the sample estimate and the true 

population with a significance level of 0.05. We also oversampled from 

each of the populations to account for practitioners who would not 

respond to our survey and those we determined to be out of scope, such as 

practitioners who did not treat workers for occupational injuries or 

illnesses during 2008. 

Page 30 GAO-10-10 Workplace Safety and Health
Appendix I: Scope and Methodology 

The respondents treated workers in various industries, and varied in the 

number of years they had treated workers, but the majority had been 

treating workers for 10 years or more (see figs. 7 and 8). The majority also 

treated more than 100 workers in 2008 (see fig. 9). 

Figure 7: Industries in Which the Majority of Workers Treated by Practitioner 

Respondents Were Employed in 2008 

9%

24%

12%

25%

Source: GAO analysis of occupational health practitioner survey data.

Health care (e.g., nursing homes, hospitals)

Manufacturing

1%

2%

3%

Agriculture

Oil and gas

Chemicals and chemical products

Services 4%

(e.g., hotels, laundry, cleaning)

6% Not sure

Construction

Other

Note: Less than 1 percent of respondents reported treating workers in both the meatpacking or 

poultry and mining industries. 

Responses do not add to 100 percent because 14 percent of respondents indicated that the majority 

of the workers they treated in 2008 were equally divided between two or more industries. 

Page 31 GAO-10-10 Workplace Safety and Health
Appendix I: Scope and Methodology 

Figure 8: Number of Years Respondents Had Treated Workers 

0

50

100

150

200

250

300

350

Number of respondents

Source: GAO analysis of occupational health practitioner survey data.

Year

10 or more

5 to fewer

than 10

1 to fewer 

Fewer 

than 1

than 5

Figure 9: Number of Workers Treated by Respondents in 2008 

0

50

100

150

200

250

Number of respondents

Source: GAO analysis of occupational health practitioner survey data.

Not sure

More

than 500

100-500

Fewer

than 100

Page 32 GAO-10-10 Workplace Safety and Health
Appendix I: Scope and Methodology 

To develop survey questions, we drew on information we previously 

gathered from interviews with occupational safety and health 

stakeholders, as well as from scholarly studies from the field of 

occupational safety and health research. Appendix II provides our survey 

instrument. Two GAO survey specialists designed the questionnaire in 

collaboration with the analysts staffed to the engagement. We pretested 

the questionnaire with nine health practitioners who represented the three 

study populations and made appropriate modifications based on their 

feedback. Appendix III provides additional selected survey results. 

Developing the 

Questionnaire, Content, 

and Question Wording 

Data Collection and 

Nonresponse Follow-up 

We conducted the survey using a self-administered questionnaire, and 

offered prospective respondents the option of completing and mailing a 

hard copy questionnaire or completing the questionnaire online. We 

offered both options because during our pretests, health practitioners 

advised us to offer a Web-based option; however, a study of occupational 

health practitioners showed that, given the choice, 90 percent of 

respondents chose to respond by mail.4

 None of our three data sources 

included e-mail addresses, so we mailed a hard copy of the questionnaire 

with instructions to either mail the completed paper version in a prepaid 

envelope or to go to a Web site designated for the survey and use a 

preassigned login identification and password. To encourage further 

participation, we mailed a second questionnaire to all those who had not 

yet responded. We also contracted with a survey research firm to make 

follow-up phone calls for those who had not responded. 

Population Estimates and 

Sampling Errors for 

Probability Samples 

Since we drew an independent sample from each occupational 

practitioner group, each response represented a different number in the 

population of the group. To enable data from the survey response to 

represent the combined population of three occupational health 

practitioner groups, we calculated weights of the responses for the three 

groups. We calculated the weights as 

Weighting Survey Response 

 

4

B. Baker, et al., “Occupational Medicine Physicians in the United States: Demographics 

and Core Competencies,” Journal of Occupational and Environmental Medicine, vol. 49, 

no. 4 (2007). 

Page 33 GAO-10-10 Workplace Safety and Health
Appendix I: Scope and Methodology 

wh= Nh

 nh

where 

• wh denotes the weight for the hth occupational practitioner group, 

• Nh denotes the population for the hth occupational practitioner group, 

• nh denotes the total number of survey responses for the hth practitioner 

group, and 

• h denotes practitioner group: 1 = physicians, 2 = physician assistants, and 

3 = nurse practitioners. 

We also estimated population statistics for the combined three health 

practitioner groups by calculating the difference in weights among the 

groups. We calculated the ratio estimate of the overall population by using 

the following equation: 

Population Estimates and 

Confidence Intervals 

R = (Σhwh Σi

 yhi) / (Σhwh Σi xhi) 

where 

• wh denotes the sample weight for the hth stratum, 

• yhi represents the ith response of the variable y response in the hth stratum 

(for example, yhi =1 if the ith response was ‘Construction’ in Q5, yhi =0 

otherwise), 

• xhi represents the ith response of the variable x in the hth stratum (for 

example, xhi = 1 if the ith response was ‘LESS THAN 100 WORKERS’ in Q3, 

xhi =0 otherwise), and 

• R denotes a population estimate of the ratio (in this example, the ratio of 

respondents who treated workers from the construction industry among 

those who treated less than 100 workers in calendar year 2008). 

Page 34 GAO-10-10 Workplace Safety and Health
Appendix I: Scope and Methodology 

To assess the precision of our estimates, we calculated confidence 

intervals for each measure. A confidence interval gives an estimated range 

of values, calculated from sample data, which is likely to include the true 

measure of the population. As is commonly done, we calculated 95 percent 

confidence intervals. 5

 We obtained the 95 percent confidence intervals of 

our population estimates by using methods detailed in Cochran6

 and 

Hansen, Hurwitz, and Madow,7

 since our estimates were calculated from 

our survey—that is, from a stratified sample. We estimated the population 

percentage and the confidence intervals of those percentages using 

specialized software for survey data analysis—SUDAAN®

.

8

Nonsampling Errors We took steps in developing the questionnaire, collecting the data, and 

analyzing the data to minimize the variability in the survey results due to 

nonsampling errors—such as those resulting from the differences in the 

way a particular question is interpreted or the sources of information 

available to respondents. The data collected were analyzed by a data 

analyst working directly with staff who have subject matter expertise. 

After the data were analyzed, a second independent data analyst checked 

all computer programs for accuracy. We contracted with an outside 

company to enter the data from the paper questionnaires into a database, 

and we checked a 10 percent sample of the database as a quality control 

measure. Respondents who completed questionnaires online entered their 

answers directly. 

Nonresponse Bias Analysis Because only about 45 percent of the health practitioners (47 percent of 

physicians, 48 percent of physician assistants, and 39 percent of nurse 

practitioners) provided usable responses to our survey, bias from 

 

5

If independent samples are taken repeatedly from the same population, and a confidence 

interval calculated for each sample, then a certain percentage of the intervals will include 

the unknown population measure. The confidence interval is often calculated so that the 

percentage is 95 percent. 

6

W.G. Cochran, Sampling Techniques, 3rd ed., Wiley Series in Probability and 

Mathematical Statistics, section 11.7 (New York, N.Y.: John Wiley & Sons, 1977), 303. 

7

M.H. Hansen, W.N. Hurwitz, and W.G. Madow, Sample Survey Methods and Theory, vol. I, 

Methods and Applications, Wiley Publications in Statistics, sections 6.6 and 6.7 (New York, 

N.Y.: John Wiley & Sons, Inc., 1953), 252-259. 

8

B.V. Shah, B.B. Barnwell, and G.S. Bieler, SUDAAN: User’s Manual, Release 7.5, vols. 1 

and 2 (Research Triangle Park, N.C.: Research Triangle Institute, 1997). SUDAAN®

 is a 

registered trademark of the Research Triangle Institute. 

Page 35 GAO-10-10 Workplace Safety and Health
Appendix I: Scope and Methodology 

nonresponse may result. If the views of those who did not respond 

differed from the views of those who did respond to some survey 

questions, the estimates made solely from those who did respond would 

be biased from excluding parts of the population with different 

characteristics or views. To limit this kind of error, we made several 

attempts to gain the participation of as many occupational health 

practitioners as possible, including additional mailings and contracting 

with a survey firm to call nonrespondents to encourage their participation. 

To assess the likelihood of significant bias, we collected additional data 

through the calls made by our contractor concerning reasons why the 

practitioners did not respond, and by trying to persuade them to answer 

three key questions from our survey on the phone. We also conducted 

several analyses of these follow-up data, our survey data, and data we had 

about the population from which we sampled, to attempt to detect any 

nonresponse bias. 

We analyzed practitioner characteristics that may have been related to 

what their answers to our survey questions would have been if they had 

responded. The variables available to us for this analysis differed by 

practitioner type. For physicians, we used age, gender, number of offices, 

type of physician (medical doctor or doctor of osteopathic medicine), and 

geographic region. For physician assistants we used age, gender, years 

since graduation, and certification status. For nurse practitioners, we used 

age, gender, and practice setting. Using logistic regression, we compared 

the characteristics of nonrespondents to respondents to determine if any 

of these characteristics were more likely to be associated with being a 

responder. With the exception of one characteristic for one group, we did 

not detect a significant difference between those who chose to respond 

and those who did not. We did detect a difference in our sample of 

physician assistants: those who were certified were more likely to respond 

to our survey than those who were not. Because we could not be sure if 

this represented a bias and because we later determined that noncertified 

physician assistants were likely out of scope, we removed all noncertified 

physician assistants from our estimates, which resulted in eliminating 13 

respondents and 43 nonrespondents from our final data. 

Our follow-up calls had several purposes related to our nonresponse 

analysis. The primary purpose was to attempt to convert nonresponders to 

responders by persuading them to complete the survey. If after several 

attempts the respondent indicated that he or she would not complete the 

survey, our contractor asked the person to answer three key questions 

from our survey: (1) whether or not any of their worksites had incentive 

programs, (2) whether they had ever observed or experienced pressure 

Page 36 GAO-10-10 Workplace Safety and Health
Appendix I: Scope and Methodology 

from workers to downplay injuries or illnesses, and (3) whether they had 

observed or experienced such pressure from company officials. Because 

only 14 nonrespondents answered at least one of these questions, we were 

unable to conduct any statistical analyses to detect whether their 

responses to these three questions were different, in aggregate, from those 

of the respondents. Regardless of whether or not the respondents 

answered these three questions, the respondents were asked why they 

would not complete the full survey. Sixty-four nonrespondents answered 

this question. Of these, 53 (83 percent) offered reasons that suggested they 

were likely out of scope because they had changed careers, were retired, 

or the survey did not relate to their job. This suggests that nonresponse 

bias may not be substantial as it is possible that many nonresponders were 

actually out of scope and would not have been able to complete the 

survey. 

Finally, we analyzed the differences in response patterns between those 

who answered in the earlier period of the survey timeframe (early 

responders) and those who responded only after follow-up attempts (late 

responders). It is possible that the late responders more closely resemble 

the nonresponders than the early responders. Based on chi-square tests, 

we detected no significant difference in survey responses to our three key 

questions between the early and the late groups, which may suggest that 

actual nonrespondents would not have answered in a substantially 

different way from those who responded. While the possibility exists that 

the true results for the entire population might be different from those we 

estimated in our report, based on these various nonresponse analyses, we 

believe that nonresponse bias is unlikely. 

We conducted this performance audit from August 2008 through October 

2009 in accordance with generally accepted government auditing 

standards. These standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. 

Statement of 

Compliance with 

Generally Accepted 

Government Auditing 

Standards 

Page 37 GAO-10-10 Workplace Safety and Health
Appendix II: Survey Instrument for Appendix II: Survey Instrument for Occupational Health Practitioners 

Occupational Health Practitioners 

Page 38 GAO-10-10 Workplace Safety and Health 
Appendix II: Survey Instrument for 

Occupational Health Practitioners 

Page 39 GAO-10-10 Workplace Safety and Health
Appendix II: Survey Instrument for 

Occupational Health Practitioners 

Page 40 GAO-10-10 Workplace Safety and Health
Appendix II: Survey Instrument for 

Occupational Health Practitioners 

Page 41 GAO-10-10 Workplace Safety and Health
Appendix II: Survey Instrument for 

Occupational Health Practitioners 

Page 42 GAO-10-10 Workplace Safety and Health
Appendix II: Survey Instrument for 

Occupational Health Practitioners 

Page 43 GAO-10-10 Workplace Safety and Health
Appendix II: Survey Instrument for 

Occupational Health Practitioners 

Page 44 GAO-10-10 Workplace Safety and Health
Appendix II: Survey Instrument for 

Occupational Health Practitioners 

Page 45 GAO-10-10 Workplace Safety and Health
Appendix II: Survey Instrument for 

Occupational Health Practitioners 

Page 46 GAO-10-10 Workplace Safety and Health
Appendix II: Survey Instrument for 

Occupational Health Practitioners 

Page 47 GAO-10-10 Workplace Safety and Health
Appendix II: Survey Instrument for 

Occupational Health Practitioners 

Page 48 GAO-10-10 Workplace Safety and Health
Appendix III: Selected Questionnaire Results 

Page 49 GAO-10-10 

Appendix III: Selected Questionnaire Results 

All estimates we report from the survey results have a margin of error of 

plus or minus 7 percentage points or less at the 95 percent confidence 

level. 

Health practitioners provided their opinions on the efficacy of safety 

incentive programs (see fig. 10). 

Figure 10: Practitioners’ Opinions on the Efficacy of Safety Incentive Programs 

Source: GAO analysis of occupational health practitioner survey data.

Disagree

Agree

Strongly agree

7% 5%

22%

55%

11%

Not sure

Strongly disagree

Done correctly, worksite safety incentive programs

provide an effective way to improve worksite safety.

In addition to experiencing pressure to downplay injuries and illnesses, 

respondents also observed behavior by workers and company officials 

that would result in underrecording (see fig. 11). 

 Workplace Safety and Health 
Appendix III: Selected Questionnaire Results 

Figure 11: Worker and Company Official Behavior Related to Reporting Injuries or 

Illnesses in 2008 

Types of behavior from workers or company officials

Number of respondents

One or more times in 2008

Never in 2008

Not sure

Source: GAO analysis of occupational health practitioner survey data.

0 50 100 150 200 250 300 350 400 450 500

Company officials

underrecording illnesses

Company officials

overrecording illnesses

Company officials

underrecording injuries

Company officials

overrecording injuries

Worker discomfort in reporting

worksite injuries or illnesses

Worker requested incident

not be recorded in employer log

Finally, health practitioners reported the impact they thought various 

factors had on whether injuries and illnesses are recorded accurately in 

the employers’ log (see fig. 12). They also reported how often they 

experienced various requests from workers or company officials (see fig. 

13). 

Page 50 GAO-10-10 Workplace Safety and Health
Appendix III: Selected Questionnaire Results 

Figure 12: Impact of Various Factors on Accuracy of Employers’ Injury and Illness 

Logs 

Worksite Safety Incentive Programs

Worker Fear of Disciplinary Actions

for Reporting Injuries or Illnesses

Misinterpretation of Recordkeeping

Requirements by Company Officials

Pressure on Practioners to 

Downplay Injuries or Illnesses

Major impact

Minor impact

No impact

Not sure

Source: GAO analysis of occupational practitioner survey data.

18%

23%

34%

25%

16%

30%

28%

26%

11%

30%

38%

21% 15%

29%

21%

35%

Page 51 GAO-10-10 Workplace Safety and Health
Appendix III: Selected Questionnaire Results 

Figure 13: Frequency of Experiencing Various Requests From Workers or Company 

Officials in 2008 

Requests from workers or company officials

Number of respondents

One or more times in 2008

Never in 2008

Source: GAO analysis of occupational health practitioner survey data.

0 50 100 150 200 250 300 350 400 450 500

Provide a treatment that is not

recordable in the OSHA log,

but is equivalent 

Provide a less expensive

treatment than I would order

Turn treatment of workers over

to staff without medical training

Send workers home to

recover from work injuries

Send workers back to work to

avoid recording lost work days

Page 52 GAO-10-10 Workplace Safety and Health
Appendix IV: OSHA’s Forms for Recording Appendix IV: OSHA’s Forms for Recording Work-Related Injuries and Illnesses 

Work-Related Injuries and Illnesses 

Page 53 GAO-10-10 Workplace Safety and Health 
Appendix IV: OSHA’s Forms for Recording 

Work-Related Injuries and Illnesses 

Page 54 GAO-10-10 Workplace Safety and Health
Appendix IV: OSHA’s Forms for Recording 

Work-Related Injuries and Illnesses 

Page 55 GAO-10-10 Workplace Safety and Health
Appendix IV: OSHA’s Forms for Recording 

Work-Related Injuries and Illnesses 

Page 56 GAO-10-10 Workplace Safety and Health
Appendix IV: OSHA’s Forms for Recording 

Work-Related Injuries and Illnesses 

Page 57 GAO-10-10 Workplace Safety and Health
Appendix IV: OSHA’s Forms for Recording 

Work-Related Injuries and Illnesses 

Page 58 GAO-10-10 Workplace Safety and Health
Appendix IV: OSHA’s Forms for Recording 

Work-Related Injuries and Illnesses 

Page 59 GAO-10-10 Workplace Safety and Health
Appendix IV: OSHA’s Forms for Recording 

Work-Related Injuries and Illnesses 

Page 60 GAO-10-10 Workplace Safety and Health
Appendix IV: OSHA’s Forms for Recording 

Work-Related Injuries and Illnesses 

Page 61 GAO-10-10 Workplace Safety and Health
Appendix IV: OSHA’s Forms for Recording 

Work-Related Injuries and Illnesses 

Page 62 GAO-10-10 Workplace Safety and Health
Appendix IV: OSHA’s Forms for Recording 

Work-Related Injuries and Illnesses 

Page 63 GAO-10-10 Workplace Safety and Health
Appendix IV: OSHA’s Forms for Recording 

Work-Related Injuries and Illnesses 

Page 64 GAO-10-10 Workplace Safety and Health
Appendix V: High Hazard Industries Included Appendix V: High Hazard Industries Included in ODI Universe as of August 2009 

in ODI Universe as of August 2009 

SIC Industry SIC Industry 

0181 Ornamental Floriculture and Nursery Products 4513 Air Courier Services 

0182 Food Crops Grown Under Cover 4581 Airports, Flying Fields, and Airport Terminal Services 

0211 Beef Cattle Feedlots 4783 Packing and Crating 

0212 Beef Cattle, Except Feedlots 4953 Refuse Systems 

0213 Hogs 5012 Automobiles and Other Motor Vehicles 

0214 Sheep and Goats 5013 Motor Vehicle Supplies and New Parts 

0219 General Livestock, Except Dairy and Poultry 5014 Tires and Tubes 

0241 Dairy Farms 5015 Motor Vehicle Parts, Used 

0251 Broiler, Fryer, and Roaster Chickens 5031 Lumber, Plywood, Millwork, and Wood Panels 

0252 Chicken Eggs 5032 Brick, Stone, and Related Construction Materials 

0253 Turkeys and Turkey Eggs 5033 Roofing, Siding, and Insulation Materials 

0254 Poultry Hatcheries 5039 Construction Materials, Not Elsewhere Classified 

0259 Poultry and Eggs, Not Elsewhere Classified 5051 Metals Service Centers and Offices 

0291 General Farms, Primarily Livestock and Animal 

Specialties 

5052 Coal and Other Minerals and Ores 

0783 Ornamental Shrub and Tree Services 5093 Scrap and Waste Materials 

4212 Local Trucking Without Storage 5141 Groceries, General Line 

4213 Trucking, Except Local 5142 Packaged Frozen Foods 

4214 Local Trucking With Storage 5143 Dairy Products, Except Dried or Canned 

4215 Courier Services, Except by Air 5144 Poultry and Poultry Products 

4221 Farm Product Warehousing and Storage 5145 Confectionery 

4222 Refrigerated Warehousing and Storage 5146 Fish and Seafoods 

4225 General Warehousing and Storage 5147 Meats and Meat Products 

4226 Special Warehousing and Storage, Not 

Elsewhere Classified 

5148 Fresh Fruits and Vegetables 

4231 Trucking and Joint Terminal Maintenance 

Facilities for Motor Freight Transportation 

5149 Groceries and Related Products, Not Elsewhere 

Classified 

4491 Marine Cargo Handling 5181 Beer and Ale 

4492 Towing and Tugboat Service 5182 Wine and Distilled Alcoholic Beverages 

4493 Marinas 5211 Lumber and Other Building Materials Dealers 

4499 Water Transportation Services, Not Elsewhere 

Classified 

8051 Skilled Nursing Care Facilities 

4512 Air Transportation, Scheduled 8052 Intermediate Care Facilities 

8059 Nursing and Personal Care Facilities, Not Elsewhere 

Classified 

Source: OSHA. 

Page 65 GAO-10-10 Workplace Safety and Health 
Appendix VI: Comments from the Department Appendix VI: Comments from the of Labor 

Department of Labor 

Page 66 GAO-10-10 Workplace Safety and Health
Appendix VI: Comments from the Department 

of Labor 

Page 67 GAO-10-10 Workplace Safety and Health
Appendix VII: 

A

GAO Contact and Staff 

cknowledgments 

Page 68 GAO-10-10 

Appendix VII: GAO Contact and Staff 

Acknowledgments 

Revae Moran, Acting Director, (202) 512-3863 or moranr@gao.gov

In addition to the contact named above, Gretta L. Goodwin, Assistant 

Director, and Mary A. Crenshaw, Analyst in Charge, managed all aspects of 

this assignment and Sara Pelton, Analyst, and Tanya Doriss, Analyst, made 

significant contributions to all phases of the work. Shana B. Wallace, 

Pamela R. Davidson, Dae B. Park, Catherine M. Hurley, Amanda K. Miller, 

and Carl M. Ramirez provided assistance in developing and applying the 

methodologies and analyzing the data. James M. Rebbe provided legal 

assistance, Susan L. Aschoff assisted with message and report 

development, and Mimi Nguyen and James E. Bennett drafted the report’s 

graphics. 

GAO Contact 

Staff 

Acknowledgments 

 Workplace Safety and Health 
Related GAO Products Related GAO Products 

OSHA’s Voluntary Protection Programs: Improved Oversight and 

Controls Would Better Ensure Program Quality. GAO-09-395. 

Washington, D.C.: May 20, 2009. 

Workplace Safety and Health: Safety in the Meat and Poultry, While 

Improving, Could Be Further Strengthened. GAO-05-96. Washington, D.C.: 

January 12, 2005. 

Occupational Safety and Health: Efforts to Obtain EstablishmentSpecific Data on Injuries and Illnesses. GAO-98-122. Washington, D.C.: 

May 22, 1998. 

Occupational Safety and Health: Changes Needed in the Combined 

Federal and State Approach. GAO/HEHS-94-10. Washington, D.C.: 

February 28, 1994. 

(130850) Page 69 GAO-10-10 Workplace Safety and Health
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