OSHA Injury Rate - Figures Don't Lie, But ...

Occupational and Environmental Medicine 2007;64:454-460The impact of OSHA recordkeeping regulation changes on occupational injury and illness trends in the US: a time-series analysisLee S Friedman, Linda Forst
University of Illinois at Chicago, School of Public Health, Division of Environmental and Occupational Health Sciences, Chicago, Illinois, USA
Correspondence to:Correspondence to: Dr L S Friedman University of Illinois at Chicago, 2121W Taylor St, Chicago, IL 60612, USA; lfriedman@tspri.org

"Objectives: The Survey of Occupational Injuries and Illnesses (SOII), based on Occupational Safety and Health Administration (OSHA) logs, indicates that the number of occupational injuries and illnesses in the US has steadily declined by 35.8% between 1992–2003. However, major changes to the OSHA recordkeeping standard occurred in 1995 and 2001. The authors assessed the relation between changes in OSHA recordkeeping regulations and the trend in occupational injuries and illnesses.
Methods: SOII data available from the Bureau of Labor Statistics for years 1992–2003 were collected. The authors assessed time series data using join-point regression models.
Results: Before the first major recordkeeping change in 1995, injuries and illnesses declined annually by 0.5%. In the period 1995–2000 the slope declined by 3.1% annually (95% CI –3.7% to –2.5%), followed by another more precipitous decline occurring in 2001–2003 (–8.3%; 95% CI –10.0% to –6.6%). When stratifying the data, the authors continued to observe significant changes occurring in 1995 and 2001.
Conclusions: The substantial declines in the number of injuries and illnesses correspond directly with changes in OSHA recordkeeping rules. Changes in employment, productivity, OSHA enforcement activity and sampling error do not explain the large decline. Based on the baseline slope (join-point regression analysis, 1992–4), the authors expected a decline of 407 964 injuries and illnesses during the period of follow-up if no intervention occurred; they actually observed a decline of 2.4 million injuries and illnesses of which 2 million or 83% of the decline can be attributed to the change in the OSHA recordkeeping rules."

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BrooklynDodger(s) comment:

At the national level, the Administration mirrors the facility level tactic of claiming safety and progress towards more safety by referring to the incidence rate. At the facility level, the management safety activity, which gets rated by its rate, keeps the numbers. At the national level, BLS collects the data, but OSHA enforces or doesn't enforce the rules for recording. Audits of injury data are as reliable as audits of mortgage securities.

Colleagues at UIC have served us well by conducting an academic investigation of the plausibility of reductions observed by the Bush Administration. This is one of several peer reviewed publications in the area.

This investigation used the data as provided, and assumes that facilities are following the rules. It doesn't take into account systematic efforts to discourage reporting, and suppress recording beyond what's permitted by the rules.

Determining the injury rate by census of employer recorded data is backward and wasteful. The new administration should launch a population survey, similar to the methods for measuring unemployment.