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. 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. 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.