FEDERAL AGENCY INJURY AND ILLNESS DATABASE

Purpose

The systematic collection of information on occupational injuries and
illnesses experienced by Federal workers will provide the Occupational
Safety and Health Administration (OSHA) and all Federal Executive Branch
agencies a snapshot of current health and safety conditions, a tool to
monitor improvements, and a mechanism to compare Federal employees’
injury and illness experiences with those of private sector workers. 
These occupational injury and illness data are not currently available
across Federal agencies.  OSHA proposes to compile such data from the
applicable injury and illness recordkeeping requirements for Federal
agencies under 29 CFR Part 1904, which became effective on January 1,
2005.  These data will provide critical information to improve the
health and safety of Federal employees.  

OSHA would use such a database to:

Aggregate injury and illness data across the federal government 

Calculate injury and illness rates for the next iteration of SHARE

Determine the types of safety and health training federal agencies need

Identify the most hazardous federal establishments

Federal agencies would use such a database to:

Identify how injury and illness rates in their agency compare among
subcomponents and with other agencies

 Compare injury and illness rates for certain job series in their
agencies with job series injury and illness rates across the federal
sector

Generate OSHA injury and illness forms—Agencies without existing
electronic data collections systems, will be given the option of using
an OSHA provided simple database that would provide such forms.

The Bureau of Labor Statistics (BLS) and the National Institute of
Occupational Safety and Health (NIOSH) would use such a database to:

Conduct more detailed assessments of Federal injury and illness data

Expand comparison of private and federal sector injury and illness rates

Calculate injury and illness rates for different job series

Background

OSHA revised the recordkeeping requirements for federal agencies to
collect better information about the incidence of occupational injuries
and illnesses, and to improve employee awareness and involvement in the
recording and reporting of job-related injuries and illnesses.  OSHA
issued a final rule (69 FR 68793) on November 26, 2004, which took
affect on January 1, 2005 and made the federal sector’s recordkeeping
and reporting requirements essentially identical to the private sector. 
This rule amended the basic program elements under 29 CFR Part 1960,
Subpart I, to make pertinent private sector recordkeeping requirements
under 29 CFR Part 1904 applicable to all Executive Branch federal
agencies.  

These recordkeeping rules require federal agencies to use the following
three forms (or equivalent): 

OSHA Form 300, Log of Work-Related Injuries and Illnesses, 

OSHA Form 300A, Summary of Work-Related Injuries and Illnesses, 

OSHA Form 301, Injury and Illness Incident Report.  

Whereas the recordkeeping rule did not require OSHA or the agencies to
implement a system that could aggregate the data, doing so would
significantly increase the usefulness of the data for the individual
agencies and for OSHA.  Currently, OSHA’s inability to compile and
analyze injury and illness data for federal employees has limited its
ability to assess federal agencies’ occupational safety and health
(OSH) programs.  OSHA would like to be able to use the recordkeeping
data in its evaluation of federal agencies’ OSH programs. 
Furthermore, OSHA would like to see federal agencies use their
recordkeeping data to help improve their OSH programs, but some agencies
do not yet have a system in place that allows them to do so.  

One reason the rule change was promoted was so that federal injury
experience could be compared with that of the private sector. 
Currently, private sector data is collected and reported by the BLS
through an annual survey of a sampling of worksites.  BLS has employers
complete a survey, either on-line or on paper, which collects data from
the OSHA 300, 300A and 301 forms.  Until there is a mechanism put in
place to compile and analyze federal agency data, OSHA, BLS and NIOSH
will not be able to make a reliable comparison between private and
federal sector worksites.  

Proposed Database Elements

The database would contain information taken directly from the three
required OSHA recordkeeping forms.  The data taken from the OSHA 300
forms would contain a list of each injury that occurred at a federal
establishment, including:

the job title of the employee, 

the date the injury occurred, 

where the injury occurred,

a brief description of the injury,

the number of days the injured was away from work or on restricted duty,
and

type of illness.

Data taken from the 301 forms would provide more detailed information
for each of the injuries from the 300 forms.  Data taken from the OSHA
300A forms would identify the total number of the injuries for each
establishment, and the average number of employees and total number of
hours all employees worked at the establishment during the year.

Process for Collecting the Injury and Illness Records

Agencies would first be required to provide OSHA with a list of their
“establishments”, as defined for occupational injury and illness
recordkeeping purposes in 29 CFR Parts 1960 and 1904.  OSHA, in
conjunction with federal agencies, would assign a unique identifier to
each establishment, so that the data could be aggregated and still
maintain the agencies organizational hierarchy.

Agencies would have four options for transmitting their data to the
database.

Agencies with electronic recordkeeping data collection systems would be
provided the file structure and file transfer protocol to allow them to
electronically transmit their injury and illness data to the database
annually.  

Agencies without such systems would be provided with a simple database
structure they could use to collect and track their injury and illness
on a day-to-day basis.  This system would allow agencies to generate the
OSHA injury and illness forms.  In addition this database would have the
file structure and file transfer protocol in place to allow agencies to
electronically transmit the required data at year’s end.  

If agencies did not have a data collection system in place and chose not
to use the database structure OSHA provided, they would be required to
submit their data through a web-based data entry form on an annual
basis.

If agencies are unable to electronically transmit their injury and
illness records, they will be able to send OSHA a paper copy of those
records.

Other Database Feature

The database would also include a web-based query system to allow OSHA
and federal agencies to analyze the data.  The query system would be
designed to maintain the privacy of individual cases.  While OSHA would
have access to all the information, individual agencies would only have
access to case data from their own agency and aggregate data from the
database.

Rule Changes and Clarifications

A number of minor regulation changes and clarifications are needed for
OSHA to successfully collect this data.  The following rule changes and
clarifications will require consultation with FACOSH and approval by the
Department of Labor’s Policy Planning Board and OMB.

When OSHA changed the recordkeeping requirements in 2004, the preamble
to the rule change did not clearly state whether or not OSHA would
collect injury and illness data on a recurrent basis.  Since Executive
Order 12196 states that OSHA’s major program elements for federal
agencies are contained in 29 CFR Part 1960, OSHA decided to make a rule
change to clearly state it would be collecting this data.  The rule
change will be similar to the data initiative language for the private
sector (29 CFR Part 1904.41).

The rule change will also include changing the date that the federal
agencies’ annual reports are due to OFAP.  Given the OSHA
recordkeeping data is kept on a calendar year basis, agency annual
reports can no longer be due on January 1 of each year if they are to
include this information.

The preamble to the rule change on collecting the OSHA recordkeeping
data will clarify that volunteers are considered federal employees under
Part 1960 and, therefore, covered by the recordkeeping requirements for
federal agencies.

A rule change or OSHA Instruction will require that agencies use OPM job
series for the “Job Title” on the OSHA 301 Form.  In addition
agencies will have to identify volunteers with a “V” before the job
series and grade.

 

 These requirements do not diminish or modify in any way a federal
agency’s responsibilities to report or record injuries or illnesses as
required by the Office of Workers’ Compensation Programs.

 PAGE   

FACOSH Recordkeeping Subcommittee 

Statement of Purpose for a Federal Agency Injury and Illness Database

August 21, 2007

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FACOSH Recordkeeping Subcommittee 

Statement of Purpose for a Federal Agency Injury and Illness Database

October 3, 2007

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