Workplace Safety and Health: Enhancing OSHA's Records Audit Process Could Improve the Accuracy of Worker Injury and Illness Data
Published: 2009-10-15T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: 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.
section_title: What GAO Found
paragraphs: 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.

section_title: Letter
paragraphs: 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 work- related 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  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). 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.
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.
subsections: section_title: Background
paragraphs: 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).
The OSH Act requires nonexempt employers to prepare and maintain  records of injuries and illnesses sustained by their workers and make them  available to OSHA. 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.
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  target high hazard worksites for inspection. Table 1 shows the number of  programmed and unprogrammed inspections OSHA conducted from fiscal  years 2003 through 2007.
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. The SOII is a coordinated federal- state 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.
Number of injured and ill workers (in millions)
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 employment. more workers it defines as being in high hazard industries. 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. worksites, OSHA included 20,000 construction worksites in its 2008 ODI.  OSHA has also proposed including worksites with 30 or more employees  in the ODI, instead of using the current threshold of 40 or more employees.
Until 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.
Based on its analysis of OSHA’s records audits of employers’ 2003, 2004,  and 2005 injury and illness data, Eastern Research Group, Inc. 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). 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.
section_title: DOL Verifies the Injury and Illness Data in the ODI, but OSHA Does Not Always Collect Information from Workers, and Excludes Certain Industries
paragraphs: 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.
subsections: section_title: OSHA Does Not Require Inspectors to Interview Workers during Records Audits
paragraphs: 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  employers on their injury and illness logs. As noted in our previous work,  there are potential risks in relying solely on employer-reported data.  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.
section_title: Lack of Timeliness in Conducting Interviews with Workers Can Affect Their Usefulness
paragraphs: 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  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—2½  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.
section_title: OSHA’s ODI Universe Excludes Eight High Hazard Industries
paragraphs: 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  1998. 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.
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  rate for measuring workers’ injuries and illnesses. 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.
section_title: BLS Does Not Verify Employer-reported Data in the SOII, but Has Undertaken Actions to Improve the Quality and Completeness of the Data
paragraphs: 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.  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 self- employed were not included in the SOII.
In response to questions about the accuracy of the employer-reported SOII  data, BLS has taken several actions designed to improve the quality and  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. 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  certain injuries such as amputations and carpal tunnel syndrome. 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.
section_title: 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
paragraphs: 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.
subsections: section_title: Various Disincentives May Discourage Workers from Reporting and Employers from Recording Injuries and Illnesses
paragraphs: 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  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 work- related 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. 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.
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.
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.
section_title: Lack of Understanding of OSHA’s Recordkeeping Requirements and Other Factors May Also Affect the Accuracy of the Injury and Illness Data
paragraphs: 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  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.
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  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.
section_title: Conclusions
paragraphs: 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.
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  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.
section_title: Recommendations for Executive Action
paragraphs: 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.
section_title: Agency Comments and Our Evaluation
paragraphs: 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.
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.
section_title: Appendix I: Scope and Methodology
subsections: section_title: Review of the Department of Labor’s Efforts to Verify the Accuracy of Employer-Reported Injury and Illness Data
paragraphs: 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).
subsections: section_title: Analysis of OSHA’s Audits of Employer Injury and Illness Records
paragraphs: 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.
section_title: Interviews of OSHA Inspectors Who Audit Employers’ Injury and Illness Records
paragraphs: 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 (state- plan states). 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  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.
section_title: Analysis of the Methods OSHA Uses to Select Worksites for Records Audits Using the ODI Universe
paragraphs: 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. 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 ) 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  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.
section_title: Discussions with Stakeholders of Factors That Affect the Accuracy of Employers’ Injury and Illness Records
paragraphs: 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. 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.
section_title: GAO Survey of Occupational Health Practitioners
paragraphs: 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.
subsections: section_title: Study Population, Sample Frame, and Sample Design
paragraphs: We designed and implemented a dual mode survey (mail and Web-based)  to obtain information from occupational health practitioners. We obtained  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.
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.
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).
section_title: Developing the Questionnaire, Content, and Question Wording
paragraphs: 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.
section_title: Data Collection and Nonresponse Follow-up
paragraphs: 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. 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.
section_title: Population Estimates and Sampling Errors for Probability Samples
subsections: section_title: Weighting Survey Response
paragraphs: 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    w denotes the weight for the hth occupational practitioner group,    N denotes the population for the hth occupational practitioner group,    n denotes the total number of survey responses for the hth practitioner    h denotes practitioner group: 1 = physicians, 2 = physician assistants, and  3 = nurse practitioners.
section_title: Population Estimates and Confidence Intervals
paragraphs: 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:  R = (Σw Σ y hi) / (Σw Σ xhi)    w denotes the sample weight for the hth stratum,    y hi 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).
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.  We obtained the 95 percent confidence intervals of  our population estimates by using methods detailed in Cochran and  Hansen, Hurwitz, and Madow, 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®.
section_title: Nonsampling Errors
paragraphs: 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  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  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.
section_title: Statement of Compliance with Generally Accepted Government Auditing Standards
paragraphs: 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.
section_title: Appendix II: Survey Instrument for Occupational Health Practitioners
section_title: Appendix III: Selected Questionnaire Results
paragraphs: 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).
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).
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).
section_title: Appendix IV: OSHA’s Forms for Recording Work-Related Injuries and Illnesses
section_title: Appendix V: High Hazard Industries Included in ODI Universe as of August 2009
subsections: section_title: Food Crops Grown Under Cover
section_title: Appendix VI: Comments from the Department of Labor
section_title: Appendix VII: GAO Contact and Staff Acknowledgments
subsections: section_title: Staff Acknowledgments
paragraphs: 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.
section_title: Related GAO Products
paragraphs: 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 Establishment- Specific 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.