1 

National SOII Respondent Follow‐Up Survey  

Elizabeth Rogers 

April 1, 2019 

Executive Summary 

Nonfatal workplace injury and illness data published by the Bureau of Labor Statistics’ (BLS) Survey of 

Occupational Injuries and Illnesses (SOII) provide a valuable measure of the safety and health of 

America’s workers. Concerns have been raised about the completeness of the SOII data, particularly that 

injury and illness cases are underreported to the survey.  

BLS contracted with Westat to conduct additional quantitative research into employer recordkeeping 

practices. The goals of this study included determining if BLS could use records or follow‐up interviews 

to capture cases that may have been left off initial SOII reporting by employers; how common record‐

keeping errors were made, especially those that may lead to SOII underreporting; and if establishments 

were willing to send in updated injury and illness logs.  

A sample of 3,703 private sector establishments was drawn from a universe of respondents who 

participated in the 2013 SOII. Establishments were sampled by state, size class, and industry sector. 

After data collection was completed, adjustments for nonresponse were made and point and variance 

estimates were produced.  

Results 

OSHA Recordkeeping and Log Maintenance 

 Around one‐half of establishments indicated that they maintained OSHA logs for the period of 

the study (2013). The percentage of establishments for which OSHA logs were not maintained 

(44 percent) was not statistically significantly different than those that maintained logs.  

 Smaller establishments were less likely to report maintained OSHA logs (41 percent) than were 

mid‐sized (71 percent) and large establishments (85 percent).  

 The majority of establishments (87 percent) indicated that the person directly responsible for 

answering the Respondent Survey had responsibility to complete or assist with completing 

OSHA recordkeeping or other injury and illness tracking. Of establishments for which OSHA logs 

were maintained, about one‐half (48 percent) said that the person with primary responsibility 

for maintaining the OSHA logs had received formal training; the percentage for those reporting 

no formal training was also about one‐half (46 percent). 

SOII Reporting 

 Fifty‐one percent of establishments indicated that the person directly responsible for reporting 

to the SOII 2013 was doing so for the first time.  

 The sources that establishments used to complete the 2013 SOII included the OSHA Log (37 

percent) and the OSHA Case Detail form (25 percent), and also company injury and illness 

records (63 percent) and workers’ compensation data (43 percent). 
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General Recordkeeping Practices 

 The majority of establishments (68 percent) recorded cases within seven days, which is 

consistent with OSHA recordkeeping guidelines.  

 There was confusion about how to determine the number of days away from work to record. 

Approximately one‐quarter of establishments correctly identified that the basis for the number 

of days away from work is calendar days; 55 percent incorrectly specified shift days. 

 According to OSHA guidelines, incidents to temporary workers should be recorded at the 

location where they are supervised. Thirty‐seven percent of establishments that used temporary 

agency workers indicated that they would include them on the SOII.  

Timing Issues 

 A majority of establishments (87 percent) could not recall if timing issues (e.g., cases happening 

late in the year or injuries becoming more serious over time) ever occurred at their company.  

Conclusions 

The results of the Respondent Survey indicate that keeping of OSHA logs is not widely prevalent, and 

that small establishments are less likely to keep records than establishments of other sizes. Also, 

relatively few SOII respondents indicated using OSHA Log (forms 300A and 301) to complete the survey. 

OSHA Recordkeeping training was not prevalent, and survey questions designed to evaluate 

understanding of recordkeeping requirements showed that there was considerable misunderstanding of 

the concepts.  

Improvements in communication or training for establishments selected to respond to the SOII about 

required recordkeeping or improvements to SOII collection procedures that can mitigate the effects that 

these have on the quality of SOII estimates should be examined. Possible changes could include 

redesigning survey materials, increasing the use of email notification to participate in the survey, and 

providing notifications throughout the reference year.   
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1. Background on Underreporting Research 

The Bureau of Labor Statistics (BLS) collects and publishes information on nonfatal workplace injuries 

and illnesses from the Survey of Occupational injuries and Illnesses (SOII). From the SOII, estimates of 

the total numbers and rates of injuries and illnesses, as well as cases that require at least one day away 

from work and cases that require job transfer or work restriction, are published for detailed industries. 

For those cases that require at least one day away from work, estimates are also published for case 

circumstances and worker demographics, which give a more comprehensive description of the kinds and 

types of occupational injuries and illnesses. The SOII is the only national source of these data, and 

millions of occupational injury and illness estimates are produced annually.  

The annual survey of approximately 230,000 establishments requires employers to report on the 

workplace injuries and illnesses of employees. The information is collected from Occupational Safety 

and Health Administration (OSHA) injury and illness logs. Recordkeeping guidelines for what constitutes 

a workplace injury or illness to be reported to the SOII is likewise determined by OSHA,1

 which has 

responsibility for maintaining these recordkeeping guidelines and issuing interpretations. Separately, 

OSHA also requires employers in certain industries to maintain records at their establishment and to 

report those records to OSHA. There is overlap between these two groups of establishments. The 

recordkeeping requirements for OSHA (and therefore SOII) are not the same as the criteria for 

determining if an injury or illness is covered by workers’ compensation. In addition, workers’ 

compensation criteria vary across states while OSHA rules are consistent across states, allowing for 

production of consistent national estimates.   

Research indicates that there is likely an underreporting of injuries and illnesses to the SOII.2

 Preliminary 

BLS and BLS‐funded research focused on matching cases reported to the SOII3

 (including the detailed 

information available for cases with at least one day away from work) to other available data sources 

such as workers’ compensation claims. This research indicates that cases to the SOII were 

underreported, but variations in data sets and methodology in the studies result in differing estimates of 

underreporting (Ruser, 2010;4

 Washington State Department of Labor, 2011;5 Nestoriak and Pierce, 

2012).6

Additional research focused on interviewing employers to determine their injury and illness 

recordkeeping practices. Some of these studies included conducting qualitative interviews with limited 

                                                            

1

 Occupational Safety and Health Administration Injury and Illness Recordkeeping and Reporting Requirements, 

https://www.osha.gov/recordkeeping/

2

 Research on the Completeness of the Injury and Illness Counts from the Survey of Occupational Injuries and 

Illnesses, https://www.bls.gov/iif/undercount.htm 3

 Bureau of Labor Statistics Survey of Occupational Injuries and Illnesses Matching Bibliography, 

https://www.bls.gov/iif/soii‐bibliography.htm#matching 4

 John W. Ruser, Allegations of Undercounting in the BLS Survey of Occupational Injuries and Illnesses, U.S. Bureau 

of Labor Statistics, Office of Survey Methods Research, October 2010 5

 Washington State Department of Labor and Industries, SOII Undercount Research: Washington SOII‐WC Record 

Linkage, 2000 – 2011 (working paper) 6

 Nicole Nestoriak and Brooks Pierce, Comparing Injury Data from Administrative and Survey Sources: 

Methodological Issues, U.S. Bureau of Labor Statistics, Office of Survey Methods Research, October 2012
4 

number of employers (Phipps and Moore, 2010;7

 Wuellner and Bonauto, 2014).8 These qualitative 

interviews pointed to potential issues with employer understanding of OSHA recordkeeping guidelines 

and SOII survey instructions.  

To produce statistically valid estimates of employers’ understanding of recordkeeping and responding to 

the SOII, BLS partnered with four states (Minnesota9

, New York10, Oregon11, and Washington12) to 

conduct four state‐based surveys. In addition to the separate state reports from this effort, a report 

combining results from all states was produced (Wuellner and Phipps, 201613). Previous SOII 

respondents were sampled, contacted by telephone, and asked about OSHA recordkeeping practices, 

injury and illness tracking, SOII reporting practices, and understanding of OSHA recordkeeping 

guidelines. The study found a large number of establishments were unfamiliar with OSHA recordkeeping 

or recording guidelines and had often not had multiple years of experience reporting to the SOII. Across 

the four states, only 19 percent of establishments reported that the person directly responsible for 

responding to the SOII had participated for multiple years.  

2. National SOII Respondent Follow‐Up Survey 

2.1 Goals and Methodology 

As data collection for the four state study was concluding, BLS contracted with Westat to conduct a 

nationally representative survey of SOII respondents. This was undertaken to provide understanding 

about recordkeeping practices and knowledge for the entire U.S., especially given variations in workers’ 

compensation by state. The study was also designed to further examine employer recordkeeping and 

reporting practices, especially those related to the potential reporting of late cases.  

A sample of 3,703 private sector establishments was drawn from a universe of respondents who had 

been sampled to participate in the 2013 SOII and who had then provided a response. All estimates 

presented in this paper were weighted, and the sample weights were developed to account for this two‐

phase survey design. State and local government establishments were excluded. Establishments in the 

railroad and mining sector that are obtained directly from the Federal Railroad Administration14 and the 

Mine Safety and Health Administration15 were excluded from the National SOII Respondent Follow‐Up 

Survey (henceforth referred to as the Respondent Survey). The sample was stratified by state, size class, 

                                                            

7

 Polly Phipps and Danna Moore, Employer Interviews: Exploring Differences in Reporting Work Injuries and 

Illnesses in the Survey of Occupational Injuries and Illnesses and State Workers’ Compensation Claims, U.S. Bureau 

of Labor Statistics, Office of Survey Methods Research, 2010 8

 Sara Wuellner and Dave Bonauto, Exploring the relationship between employer recordkeeping and 

underreporting in the BLS Survey of Occupational Injuries and Illnesses, American Journal of Industrial Medicine 57 

no. 10 (October 2014), pp. 1133‐1143

9

 William Boyer and Brian Zaidman, B, SOII Undercount Project Minnesota Interviews with SOII Respondents, 

September 2014 

10 Karen Cummings, , SOII Undercount Research: Employee Interview Project New York State, September 2014  11 Nathan Johnson,  Karen Howard, and Ronni, Rachele, R, Bureau of Labor Statistics SOII Undercount Research: 

Oregon Employer Survey Final Report, September 2014  12 Sara Wuellner, Dave Bonauto, Christine Rappin, and Wendy Lu, SOII Undercount Research: Telephone Interviews 

with SOII Respondents, Washington, September 2014 

13 Sara Wuellner and Polly Phipps, Employer‐based work injury recordkeeping: Data from four states, March 2017 14 Federal Railroad Administration https://railroads.dot.gov/ 15 Mine Safety and Health Administration https://www.msha.gov/
5 

and industry sector. Size class was defined as small, medium, and large sized establishments, which is a 

collapsed version of the 5‐category size class structure of the SOII. Industry was defined using 15 North 

American Industry Classification System (NAICS) sectors, with some sectors collapsed.  

Table 1: Percentage of Sample by Industry Sector 

NAICS  Description  Percentage 

of Sample 

11  Agriculture, Forestry, Fishing, and Hunting  1.0 

21  Mining, Quarrying, and Oil and Gas Extraction  0.5 

22  Utilities  0.7 

23  Construction  6.5 

31‐33  Manufacturing  13.9 

42  Wholesale Trade  5.3 

44‐45  Retail Trade  16.7 

48‐49  Transportation and Warehousing  4.2 

51  Information  1.9 

52‐53  Finance and Insurance, Real Estate and Rental and 

Leasing 

4.5 

54‐56  Professional, Scientific, and Technical Services; 

Management of Companies and Enterprises; 

Administrative and Support and Waste Management 

and Remediation Services 

11.8 

61  Educational Services  1.7 

62  Health Care and Social Assistance  15.2 

71‐72  Arts, Entertainment, and Recreation; 

Accommodation and Food Services 

12.6 

81  Other Services  3.6 

A questionnaire was developed to examine key concepts, including: 

 Could BLS use records or follow‐up interviews to capture cases that may have been left off initial 

SOII reporting;  

 How common are recordkeeping errors, especially those that may lead to SOII underreporting; 

 What kinds of SOII reporters are associated with late cases and measurement errors;  

 Are SOII respondents able and willing to send in updated OSHA logs? 

The survey was conducted by Computer Assisted Telephone Interviewing (CATI). Respondents were 

notified of the request to participate in the Respondent Survey by email or letter. Interviews were 

obtained from 1,852 establishments and OSHA logs were collected from 777 establishments.  

2.2  Nonresponse Bias Analysis, Adjustment and Estimation
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After data collection was completed, the sample weights were adjusted for survey nonresponse using 

the same categories of sampling criteria. Point estimates for each of the interview questions were 

produced. This paper will present these estimates as proportions of responses, in some cases cross‐

tabulated by size class or industry sector.  Variance estimates for each estimate were also produced and 

are available upon request. All statements were tested for statistical validity. 

3. Results 

3.1  OSHA Recordkeeping and Log Maintenance 

3.1.1.   Keeping OSHA Logs 

Each establishment sampled to report data to the SOII is required to keep OSHA logs for the duration of 

the reference year in which they have been sampled. At the beginning of the reference year, every 

establishment is provided a notification that they are required to complete the SOII along with a copy of 

the OSHA logs. All SOII notifications to keep records for the 2013 reference year were delivered to 

respondents by USPS. These logs are to be used by the respondent to record specific cases through the 

year which are totaled at the end of the reference year into a summary form. For the SOII, respondents 

are also asked to record detailed case‐specific information on the OSHA‐provided case form for cases 

that required at least a day away from work (or for a sample of the cases if there are more than 15 

cases). Asking respondents to maintain OSHA logs throughout the year, and not relying on other sources 

or memory, is intended to increase the accuracy of information reported to the SOII.  

Despite the requirement, about one‐half (43 percent) of establishments maintained OSHA logs, which 

was not statistically different from the percentage that reported that they did not keep logs (44 

percent). 

In addition to the requirement to keep these records when sampled by the SOII, some establishments 

are also required by OSHA to keep these records on an annual basis. OSHA exempts establishments in 

some industries from the requirement to keep injury and illness records.16 All establishments with 11 or 

more employees in the following sectors must keep OSHA records: Agriculture, Forestry, Fishing and 

Hunting; Oil and Gas Extraction, Utilities; Construction; Manufacturing; and Wholesale Trade. No 

establishments in the Educational Services sector are required to keep OSHA records. All other sectors 

include a mix of exempt and non‐exempt industries.   

The percentage of establishments indicating that OSHA logs were kept ranges from 92 percent in 

Agriculture, Forestry, Fishing, and Hunting to 17 percent in Educational Services. The percentage of 

establishments in the Agriculture, Forestry, Fishing, and Hunting (92 percent); Utilities (83 percent); 

Construction (70 percent); Manufacturing (74 percent); Retail Trade (60 Percent); and Transportation 

and Warehousing (73 percent) sectors that reported that they kept OSHA logs was higher than the 

percentage of establishments in these sectors that did not. Most establishments in these sectors are 

also required by OSHA to keep logs if they employ more than ten employees.17 In the Finance and 

Insurance, Real Estate and Rental and Leasing (73 percent); Educational Services (70 percent); and Arts, 

                                                            

16 Occupational Safety and Health Administration Non‐Mandatory Appendix A to Subpart B ‐‐ Partially Exempt 

Industries, https://www.osha.gov/laws‐regs/regulations/standardnumber/1904/1904SubpartBAppA 17 Some establishments in the Retail Trade and Transportation and Warehousing sectors are exempt regardless of 

size 
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Entertainment and Recreation, Accommodation and Food Services sectors (62 percent) more 

establishments reported that they did not maintain OSHA records than the percentage of 

establishments that did, even though some subindustries within these sectors are required by OSHA to 

do so. 

Table 2: Percentage of Establishment Indicating that OSHA Logs are Maintained 

   YES  NO 

DON’T 

KNOW  REFUSED 

Private Industry  43  44  13  0 

Agriculture, Forestry, Fishing, and Hunting  92  8  0  0 

Mining, Quarrying, and Oil and Gas Extraction  21  75  3  0 

Utilities  83  2  15  0 

Construction  70  28  2  0 

Manufacturing  74  18  8  0 

Wholesale Trade  42  57  1  0 

Retail Trade  60  30  11  0 

Transportation and Warehousing  73  26  1  0 

Information  46  53  1  0 

Finance and Insurance, Real Estate and Rental and Leasing  19  73  8  0 

Professional, Scientific, and Technical Services; Management of

Companies and Enterprises; Administrative and Support and 

Waste Management and Remediation Services  32  53  16  0 

Educational Services  17  70  12  0 

Health Care and Social Assistance  49  32  19  0 

Arts, Entertainment, and Recreation; Accommodation and Food 

Services  24  62  14  0 

Other Services  20  32  47  0 

Small establishments reported the lowest percentage of keeping OSHA logs (41 percent) when 

compared to mid‐sized (71 percent) and large establishments (85 percent). 

3.1.2.   Who Keeps Track of OSHA Recordkeeping?  

The majority of establishments (87 percent) indicated that the person directly responsible for answering 

the Respondent Survey had responsibility to complete or assist with completing OSHA recordkeeping or 

other injury and illness tracking. Of those who indicated multiple people had responsibility for this task, 

a majority (71 percent) of establishments indicated the person directly responsible for answering the 

Respondents Survey had the primary responsibility for recordkeeping and injury and illness tracking.  

3.1.3.   OSHA Recordkeeping Training 

Training in OSHA recordkeeping requirements is designed to increase recordkeepers’ knowledge of the 

kinds of injuries and illnesses that should be recorded and what information recordkeepers are required 

to include about those cases. This training intends to increase the quality of the information employers 

record on OSHA logs.      
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For respondents who indicated that OSHA logs were kept at their establishment or firm, the Respondent 

Survey asked if the person with primary responsibility for OSHA recordkeeping had ever received formal 

training in the form of classes, seminars, or online courses. Around one‐half of establishments (48 

percent) reported that the person with primary responsibility for OSHA recordkeeping had received 

formal recordkeeping training. About the same percentage of establishments (46 percent) indicated that 

formal training had not been received.    

A majority of establishments in the Utilities and Information sectors reported that the primary 

recordkeeper had received formal training. Construction was the only sector in which a majority of 

establishments indicated the primary recordkeeper (83 percent) had never received formal training.  

Table 3: Percentage of Respondents Keeping OSHA Logs Who Had Received Formal OSHA 

Recordkeeping Training 

   YES  NO 

DON’T 

KNOW  REFUSED 

Private Industry  48  46  6  0 

Agriculture, Forestry, Fishing, and Hunting  72  28  0  0 

Mining, Quarrying, and Oil and Gas Extraction  45  55  0  0 

Utilities  92  8  0  0 

Construction  17  83  0  0 

Manufacturing  63  31  6  0 

Wholesale Trade  24  73  3  0 

Retail Trade  66  17  18  0 

Transportation and Warehousing  47  51  1  0 

Information  87  7  6  0 

Finance and Insurance, Real Estate and Rental and Leasing  62  37  2  0 

Professional, Scientific, and Technical Services; Management of

Companies and Enterprises; Administrative and Support and 

Waste Management and Remediation Services  41  56  3  0 

Educational Services  42  58  0  0 

Health Care and Social Assistance  68  31  1  0 

Arts, Entertainment, and Recreation; Accommodation and Food 

Services  47  44  8  1 

Other Services  9  62  29  0 

Of the establishments who indicated that recordkeepers had received formal OSHA recordkeeping 

training, a higher percentage of them (66 percent) indicated that that training had last occurred 

between 1 and 5 years than any other time period prior to the Respondent Survey. Twelve percent 

reported that training had taken place in the past year.  

3.1.4.   SOII Reporting 

Fifty‐one percent of establishments indicated that the person directly responsible for completing the 

SOII in 2013 was a first‐time respondent to the SOII in the year 2013, while an additional 29 percent did 
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not know if that person had completed the SOII prior to 2013. Twenty percent of establishments 

indicated that that person was not a first time responder to the SOII.  While the questions asked were 

not the same, this is similar to the percentage of establishments in the four‐state study that indicated 

that the person directly responsible for completing SOII had completed the SOII multiple times (19 

percent across the four states). Previous experience to SOII reporting is likely to increase knowledge and 

thereby accuracy of the information reported to SOII.  

The Respondent Survey asked establishments to provide information on the sources that they used to 

complete the SOII at the conclusion of the 2013 reference year. They were asked to indicate all the 

sources that they used to do so. Despite being provided the OSHA logs at the time they were notified of 

their mandatory responsibility to report to the SOII, 37 percent of establishments used the OSHA 

Summary form 300A and 25 percent of establishments used the OSHA 301 detailed case form. Many 

establishments used sources that are not necessarily consistent with OSHA recordkeeping or SOII 

concepts. Sixty‐three percent used company‐specific injury and illness records, such as injury report 

forms or individual files kept on employees and 43 percent of respondents used workers’ compensation 

records such as claims or first state reports.18 This indicates that individual company definitions of 

injuries and illnesses or workers’ compensation criteria may form some of the basis of reporting 

occupational injury and illness to the SOII rather than OSHA recordkeeping guidelines.  

3.1.5. Workers’ Compensation Completion 

Most establishments (81 percent) reported that the person directly responsible for answering the 

Respondent Survey was also involved in completion of workers’ compensation claims. As the guidelines 

for workers’ compensation differ from OSHA recordkeeping rules and by state, establishments with 

employees responsible for reporting to the SOII and also completing workers’ compensation claims may 

have difficulty in correctly applying OSHA recordkeeping rules when reporting to the SOII. 

3.1.6.  General Recordkeeping Practices 

Establishments were asked a series of questions about general recordkeeping practices, separate from 

the practices at their establishment or firm for completing the 2013 SOII. If a establishment indicated 

that OSHA logs were maintained, they were asked about recordkeeping practices related to the OSHA 

log; if not, the question was altered to refer more generally to the “BLS Survey,” meaning the SOII. For 

the purposes of determining the respondents’ understanding of general recordkeeping practices, 

responses from these two groups are considered together.  

OSHA requires that injuries and illnesses be recorded on the log within seven days of occurrence. Most 

establishments (68 percent) stated that cases were recorded within one week. A majority of 

establishments in the following sectors reported recording injuries and illnesses within a week: Mining, 

Quarrying, and Oil and Gas Extraction (98 percent); Construction (86 percent); Manufacturing (76 

percent); Wholesale Trade (89 percent) and Educational Services (83 percent).  

Establishments also reported practices that were not compliant with OSHA recordkeeping guidelines 

and demonstrated confusion about how to correctly identify information to be included on the OSHA 

log and to SOII. Approximately a quarter of establishments (28 percent) accurately identified calendar 

days as the basis for the determination of the number days away from work. Fifty‐five percent 

                                                            

18 Respondents could select multiple responses to this question and percentages do not total to 100.  
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incorrectly identified shift days as the number of days away from work measure. Respondents in small 

establishments were less likely to correctly identify calendar days (25 percent) than those in mid‐sized 

and large establishments (60 and 71 percent, respectively).    

According to OSHA recordkeeping guidelines, injuries and illnesses to temporary workers should be 

recorded at the establishment where they are supervised. However, for establishments in companies 

where temporary workers are employed from staffing agencies, 37 percent include injuries or illnesses 

to these workers on the SOII.  

Of the establishments that maintained OSHA logs, 41 percent did not add or update cases on the 

previous year’s OSHA log, an additional 14 percent never needed to add or update cases on the log, and 

35 percent did add or update cases to the previous year’s log. 

3.1.7. Recordkeeping vignettes 

In a further attempt to gauge respondents’ recordkeeping knowledge about key OSHA rules, 

recordkeeping vignettes were asked of each respondent. As each vignette has a correct answer, it is 

possible to assess the sophistication of respondents’ understanding of OSHA recordkeeping. The 

establishments who indicated that they maintain logs were asked specifically about OSHA recordkeeping 

while establishments that did not keep logs were asked if they would include the injury on the SOII. The 

responses to the questions indicate that there is considerable confusion about key OSHA recordkeeping 

concepts.  

Vingette 1: 

“Let’s say an employee sprained their ankle at work on Friday. The doctor recommended they take two 

days off work. They were not scheduled to work on the weekend, and returned to work on Monday.” 

Three questions were asked related the vignette: 

 Would your company consider this recordable/include on the OSHA log/SOII? 

 (If yes) Would you record days away from work? 

 (If yes) How many? 

The correct responses to the three questions are 1) this is a recordable case that should be included on 

the OSHA log/SOII, 2) that days away from work should be recorded, and 3) the number of days away 

from work recorded should be two. Approximately one‐half of establishments (56 percent) correctly 

answered yes to the first question, 28 percent answered the question incorrectly, and an additional 16 

percent of establishments reported that they did not know the answer. Of those who correctly said yes 

to the first question, about half (54 percent) then incorrectly answered that this is not a days away from 

work case. Of those who responded correctly to the first two questions in the vignette that this is a 

recordable, days away from work case, a majority (78 percent) correctly reported that the number of 

days away from work was to be recorded as two.  

Vignette 2: 

“Let’s say a worker broke their arm at work, saw their family doctor and did not file a workers’ 

compensation claim, instead using their personal medical insurance. Would your company consider this 

recordable/include on the SOII?” 
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The correct response is that this is a recordable case that should be recorded and included on the SOII. 

About three out of five establishments (61 percent) correctly identified this as a recordable case. 

Vignette 3: 

“Let’s say a worker was injured, and the doctor recommended two days away from work and 10 days of 

modified or restricted job duties. Would your company classify this as a “days away from work case” or 

a “days of job transfer and restriction” case for the OSHA log/SOII?” 

The correct answer is that this should be identified as a days away from work case. Twenty‐nine percent 

of establishments correctly identified it as a days away from work case, 31 percent identified it as a days 

of job transfer or restriction case, while 17 percent considered it an “other” kind of case and 22 percent 

said that they did not know.  

3.1.8. Timing Issues That May Prevent Inclusion of and Injury or Illness Case in the 

SOII  

Another goal of the Respondent Survey was to determine if there are cases that occur that do not get 

recorded on the OSHA log or reported to the SOII due to timing issues (such as the case being reported 

in November or December, the case worsening after being reported, or reported/worsening after the 

submission of the SOII), pending workers’ compensation status, or employment considerations (such as 

an employee no longer working at the company). Establishments were asked if they could recall any of 

these instances happening at their company. Most establishments (87 percent) reported that they did 

not recall any of these types of timing situations occurring at any time at their company.  

When asked individually about each of the specific situations, a majority of establishments indicated 

that none of these scenarios had ever happened and none had happened in 2013.  

Despite a majority of establishments not recalling situations likely to cause missing cases or reporting 

that their company does not update or need to update the OSHA log, most establishments indicated (72 

percent) that they could produce an OSHA log with updates if asked.  

4.  Conclusions 

The goals of the Respondent Survey included determining if there were recordkeeping issues found 

among establishments (especially those that would lead to SOII underreporting), if the SOII could 

capture late cases by following up with establishments, and if establishments could supply BLS with 

OSHA logs after the submission of SOII.  

Results show that there were notable recordkeeping issues found, especially related to the percentage 

of establishments who keep OSHA logs, the relatively low occurrence of recordkeeper training, the use 

of sources other than the OSHA forms in responding to the SOII, and in confusion related to 

recordkeeping knowledge in general.  

The results of the Respondent Survey indicate that establishments keeping OSHA logs is not a common 

practice, with the about same percentage of establishments reporting that they maintain logs and do 

not maintain logs. Smaller establishments are less likely to keep OSHA logs than mid‐sized or large 

establishments. Six sectors of fifteen reported more establishments maintaining OSHA logs than did not. 

The other sectors either reported a higher percentage of establishments that did not maintain logs or 
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that there was no difference in the percentage of establishments keeping or not keeping OSHA records. 

Even in sectors where some establishments are required to keep OSHA logs on a regular annual basis, 

results show that not all establishments replied that OSHA logs were kept. Also, only around a third of 

establishments indicated using the OSHA summary form 300A and one quarter of establishments 

indicated using the OSHA Case Form 301 to complete the survey. 

About half of establishments reported that the person responsible for keeping the OSHA log (if 

maintained) had some form of formal recordkeeping training, most of whom reporting training within in 

the last five years. Survey questions designed to indicate understanding of recordkeeping requirements 

showed that there was considerable misunderstanding of these concepts. Reported answers to 

occupational injury and illness scenarios indicate confusion over the use of calendar days to determine 

the duration of an injury or illness, which is likely to contribute to the underreporting of both the total 

number of cases with days away from work as well as the total number of days away from work 

required for cases that are correctly identified. Also, similar levels of confusion over the requirement to 

record the injuries and illnesses of temporary workers should be examined further to determine if this 

increases the underreporting of injuries and illnesses to these workers 

Most establishments indicated that late cases had never happened at their company but that if asked, 

they could supply an updated OSHA log.  

Further research is required to determine if there are improvements to make in communication or 

training to SOII respondents about required recordkeeping. Also, improvements to SOII collection 

procedures should be examined, focusing on mitigating any effects that these procedures have on the 

quality of SOII estimates. Possible changes to SOII collection could include redesigning survey materials, 

increasing the use of email notifications to include first‐time respondents to the survey, and providing 

notifications throughout the reference year.  

To improve the recordkeeping knowledge of SOII respondents, BLS could provide access to currently 

available online OSHA Recordkeeping training modules and other training resources with SOII survey 

materials. BLS could also work with OSHA to help develop new training options to be made available to 

all establishments required to keep OSHA logs, whether as a respondent to SOII or required to keep 

records for OSHA. BLS’s knowledge of topics where employers may be confused by or unaware of 

recordkeeping guidelines, gained by routine SOII data collection and the research designed to better 

understand the SOII undercount, can be shared with OSHA to help guide the trainings to topics most in 

need of improvement.