FACOSH Recordkeeping Subcommittee Meeting Minutes (FY’06)

Federal Advisory Council on Occupational Safety and Health (FACOSH)

Recordkeeping Subcommittee

May 31, 2007 Meeting Minutes

The FACOSH Recordkeeping Subcommittee met at 9:00 a.m.  in C-5515,
Conference Room 2, of the Frances Perkins Building located at 200
Constitution Avenue, N.W., Washington, D.C.

Voting Members:	Representing:

CAMILLE CARRAWAY	DHS

DEBORAH KLEINBERG	SEAFARERS INTERNATIONAL UNION

JONATHAN MULLIN	NASA

MILLIE RODRIGUEZ	AFGE

JOHN SEIBERT	DOD

COREY THOMPSON	AMERICAN POSTAL SERVICE UNION

Non-voting Members:

SHEILA BAKER	DOL

LARRY JACKSON	NIOSH

JIM KALLENBORN	OSHA

TERRY MEISINGER	SMITHSONIAN INSTITUTION

JIM MEREDITH	DOI

BRYAN RICHARDSON	DHS-TSA

DAVE SCHMIDT	OSHA

OSHA Support Staff:

DIANE BRAYDEN	OSHA-OFAP

MIKKI HOLMES	OSHA-OFAP

LAURA MILLS	OSHA-OFAP	

MICHELLE WALKER	OSHA-OFAP

Attending:

RICHARD FAIRFAX	OSHA-DIRECTORATE OF ENFORCEMENT

EDWIN G.  FOULKE, JR.	OSHA

JAMES KARCHER	DHS

Welcoming remarks

Mr. Foulke, Assistant Secretary of Labor for the Occupational Safety and
Health Administration (OSHA) and FACOSH Chair, welcomed the
Recordkeeping Subcommittee members and thanked them for agreeing to
participate on the committee.  He specifically thanked FACOSH member
Milly Rodriquez, American Federation of Government Employees, AFL-CIO
(AFGE) and Jonathan Mullin of NASA, for serving as co-chairs.  Mr.
Foulke reminded the group that effective January 1, 2005, federal
agencies began keeping the OSHA 300 records.  He noted that the
subcommittee was established with the goal of finding the most effective
way to collect, analyze, and share OSHA 300 data to reduce injuries and
illnesses in the federal government.  He emphasized that this
information would be used, in part, as a basis for establishing a
program to replace the SHARE Initiative which is scheduled to end in FY
2009.  Mr. Foulke thanked agencies for their progress in meeting the
goals of the SHARE Initiative and stressed the importance of the
subcommittee.    

At 9:15am the meeting broke for a picture of the subcommittee.  

Diane Brayden, OSHA’s Office of Federal Agency Programs (OFAP), went
over the shelter-in-place and emergency evacuation procedures.  

Call to Order

Labor Co-Chair Milly Rodriquez, AFGE, introduced herself and called the
meeting to order at 9:18 a.m.  She asked the others in attendance
introduce themselves.  

Council Organization and Procedures

Ms. Brayden provided an overview of the subcommittee’s rules and
operating procedures.  She explained that subcommittee membership needed
to consist of an equal number of labor and management members and that
the subcommittee currently consisted of three voting members from each
group.  The subcommittee is co-chaired by one labor representative by
one management representative.  Ms. Brayden explained that a voting
member needed to be on FACOSH or designated by the FACOSH member as the
alternate on the subcommittee.  However, the subcommittee also welcomed
technical experts and those from agencies who had existing systems in
place and wanted to share information.  

Ms. Brayden mentioned that she would serve as the Designated Federal
Official and Mikki Holmes would serve as the OFAP Staff Liaison to the
subcommittee.  She also stated that subcommittee meetings were open to
public and that they would be announced in the Federal Register, if
scheduled in conjunction with a full FACOSH membership meeting.  She
explained that Ms. Holmes will notify subcommittee members in the event
of any meeting cancellations or changes.  In addition Ms. Brayden stated
that attendance sheets would be passed around during meetings, and
minutes generated.  

Ms. Brayden described that any status reports would be generated for the
subcommittee by the co-chairs with extensive OFAP staff support and that
subcommittee co-chairs would present these reports to the full FACOSH
committee.  The subcommittee would make suggestions to be voted on by
FACOSH as a whole.  

Ms. Brayden then asked if there were any questions.  Mr. Mullin, NASA
asked if information discussed during subcommittee meetings could be
discussed with their agency management.  Ms. Brayden stressed that the
subcommittee meetings were open to the public and that discussions with
agency management is encouraged.  

Topics for Discussion

Recordkeeping Background/Overview

Mikki Holmes provided a brief overview of the subcommittee, discussing
how OSHA could potentially use the data.  She reviewed the purpose and
objectives for the subcommittee and factors that the subcommittee might
want to consider in their recordkeeping discussions.  The factors she
highlighted were identified in her review of the agencies’ annual
reports.  Finally Ms. Holmes identified three deliverables for the
subcommittee: an implementation plan, a final report and a PowerPoint
presentation for the September 27, 2007 FACOSH meeting.

Questions and Comments

Mr. Mullin asked Ms. Holmes if the GAO report was available to everyone.
 She replied yes, and that she could provide it to the subcommittee
along with a copy of her PowerPoint presentation.  Larry Jackson, U.S. 
Department of Health and Human Services (HHS) – National Institutes on
Occupational Safety and Health (NIOSH) asked how long the subcommittee
would run.  Ms. Holmes responded that it depended on what decisions the
subcommittee made on how best to move forward.  However, a solution
would need to be generated by December 2008 in order to meet the
scheduled expiration of the SHARE Initiative in 2009.  

Review of Members Recordkeeping Systems

Department of Homeland Security (DHS)

James Karcher explained that DHS currently has a range of systems in
place—both government and commercial off-the-shelf systems.  He said
he thought that the ideal system would integrate workers’ compensation
and safety reports—which he believed would help to reduce
underreporting.  He also thought the system should be web-based, offer
statistical/analytical reporting tools, have a modular design, and offer
return-to-work case management capabilities.

Questions and Comments

Mr. Mullin asked if DHS had ever added up the total cost of having
multiple systems for tracking injury and illness data.  Mr. Karcher
responded that DHS had not.  Ms. Rodriguez asked if DHS had a
centralized hub for storing injury and illness data.  Ms. Karcher stated
that DHS uses the OSHA website, to track their data and rates.  Mr.
Mullin asked Mr. Karcher to clarify if DHS needed a new system or a
system developed by the subcommittee.  Mr. Karcher clarified that he was
suggesting that a system be developed to track both injury and illness
data along with OWCP data and that this system be designed to figure out
which information was OSHA recordable and which was for OWCP.  

DHS—Transportation Security Administration (TSA)

Bryan Richardson described TSA’s Safety Information System (SIS), as a
commercial product that has been modified for TSA’s needs.  He said
that the system has three main modules:

The Incident Analysis Module integrates workers’ compensation and
injury and illness data and generates investigation reports and the OSHA
300 records.  The system can generate a report at any organizational
level.  In addition, reports and graphs can be customized using 60 data
filter points.

The Risk Management Assistant is the module in which inspection
information is recorded and requires that appropriate staff respond to
notices of unsafe or unhealthful conditions.  Recommendations made by
supervisors or employees are reviewed by OSH specialists who rate the
risk assessment and develop formal corrective action plans.

The Process Risk Assistant module covers developing safe operating
procedures for individual processes and assessing risks for each task.  

Mr. Richardson noted that TSA’s system uses OWCP standard coding for
injuries and illnesses and did not incorporate BLS coding.  He said the
system could generate a number of reports.

Questions and Comments

Mr. Karcher commented that DHS was closely observing how well the TSA
system performed with the possibility of implementing it
department-wide.  Mr. Mullin inquired about the access contractors had
to the information kept within the data system.  Mr. Richardson
responded that the contractor only maintained the system and was not
involved with the inputting or analyzing of data.  Mr. Mullin asked
about the duration of training for the people responsible for inputting
data.  Mr. Richardson responded that training involved watching a
two-hour on-line video.  Mr. Mullin asked what the budget was for this
system.  Mr. Richardson stated that the cost was approximately $300,000
for hosting and maintenance.  Also, Mr. Mullin inquired about the
system’s coverage.  Mr. Richardson responded that it covered 451
airports, 650 users and 54,000 employees.  A discussion ensued about the
checks and balances of the system.  Mr. Richardson stated that various
quality control mechanisms, including a close-out wizard which is
activated by not filling out all required fields, were included as part
of the system.  Mr. Jackson, NIOSH inquired about the development phase.
 Mr. Richardson responded that the system had to be reworked in 2005
when OSHA implemented the new recordkeeping requirements and that the
current version of the system had been operational since February 2006. 
Ms. Rodriquez asked how information about reported injuries and
illnesses was disseminated.  Mr. Richardson stated that an electronic
report was sent to the airport.  

Department of Labor (DOL)

Sheila Baker reviewed DOL’s SHIMs system, which she said had gone
through several iterations.  In October 2006 the system became web-based
and incorporated BLS coding.  She said the system starts with an
employee completing the OSHA 301 Incident Report Form.  This data then
populates the appropriate fields in the workers’ compensation form. 
She said that the system generated emails to the appropriate personnel
to review the files.

Questions and Comments

Mr. Seibert, U.S.  Department of Defense (DOD), asked about the first
form that was given to employees wanting to report an injury or illness
using this system.  Ms. Baker responded that the employee needed to fill
out a form which asked for 301 data.  The form asks whether they wanted
to file a workers’ compensation claim or an injury and illness claim. 
Mr. Seibert inquired as to whether the report triggered an OSHA
recordable.  Ms. Baker answered that yes it did.  Mr. Seibert asked
about what happens if a person only wanted to file a workers’ comp
claim.  Ms. Baker responded that the employee could not get to
workers’ comp claim form without filing out the 301 form first.  A
discussion ensued regarding the privacy protections of the DOL system. 
Ms. Baker stated that there was open reporting so everyone could see
when and where a reported mishap occurred, however no personal
identifiable information could be seen in the reports.  Mr. Seibert
asked about who has access to employee information in the DOL SHIMS
system.  Ms. Baker responded that she does as the system’s
administrator and “super user.”  Mr. Seibert asked if any of the
injury and illness reports contained any employee information.  Ms.
Baker answered that only the Accident Review Board reports contained
personal information.  

Department of Defense (DOD)

John Seibert explained that DOD has multiple systems that could
communicate across agencies.  He said that the systems vary in
complexity.  He explained that he thought the subcommittee needed to
determine the purpose for aggregating the data and the role of the 300
data in agencies’ OSH programs in order to define the goals of the
subcommittee.

Questions and Comments

A discussion ensued between Mr. Seibert and Mr. Mullin regarding the
high level of turnover the DOD experiences and the challenges faced by
the department in implementing injury and illness reporting systems as a
result.  Mr. Seibert stated that in his opinion DOD’s Defense
Logistics Agency is doing the best job in recording and reporting data. 
He also stated that the DOD faces a challenge with integrating all
existing injury and illness reporting systems that already exist
independently within DOD agencies into one unified system.  A discussion
ensued about how injuries sustained by contractors were accounted for in
the DOD system.  Mr. Seibert discussed how this was a complicated issue
because DOD has contractors in combat zones.  He also stated that DOD
was trying to improve safety culture with contractors as a base step.  

Jim Meredith, U.S.  Department of the Interior (DOI), pointed out that
if the purpose of the subcommittee is to work with OSHA to gather common
injury and illness information, DOD’s process of integrating its
numerous systems may be a good example.  Mr. Seibert stated that there
appeared to be two ways to go about the recordkeeping issue; 1) allow
agency input and develop one system, or 2) allow agencies to develop
their own systems with standardized data dictionaries that use BLS
coding.  Mr. Mullin emphasized the importance of quality control and
working with the Office of Workers’ Compensation Programs (OWCP) to
create a system of checks and balances.  

Deborah Kleinberg, Seafarers International Union (SIU), asked about the
structure of DOD and its subcomponent agencies.  Ms. Brayden clarified
that DOD is comprised of several subunits including the Department of
the Army, Department of the Navy, Department of the Air Force and
several other smaller agencies that support these military operations
but are independent from the active duty departments.  It was explained
that several of those support agencies use off-the-shelf products for
the collection of injury and illness data.  Mr. Jackson asked if data on
military personnel and civilian employees was collected in the same
system.  Mr. Seibert responded yes, but these individuals were tracked
differently.  Ms. Kleinberg asked if contractors were tracked as
civilian employees.  Mr. Seibert answered yes.  Mr. Mullin asked if DOD
counted contractors in their rate calculations.  Mr. Seibert responded
that they were not counted, but that DOD was looking to use its injury
and illness data in its Voluntary Protection Program (VPP).  

Ms. Rodriquez asked if any of the data collected in the 300 logs was
getting back to OSHA.  Ms. Holmes, OFAP answered that OSHA doesn’t
collect this data and that the collection of these data was one of the
main goals of the subcommittee.  

NASA

Jonathan Mullin explained that NASA had a web-based integrated real-time
information system (IRIS) that could generate OSHA 300 reports.  He said
that while workers’ compensation was a separate system OSH managers
were required to meet with their workers’ compensation counterparts on
a monthly basis to review cases to ensure IRIS was capturing all
incidents.  He said that NASA’s system captures near misses and close
calls, and serves to improve communication among safety medical and OWCP
personnel.

Question and Comments

Diane Brayden asked Mr. Mullin to explain how NASA generated reports
which included rates.  Mr. Mullin explained that the NASA system had a
real-time feed with human resources data and that this was updated at
least monthly.  He also emphasized that NASA centers were required to
validate the rates before they were posted.  

Department of the Interior (DOI)

Jim Meredith explained that DOI’s Safety Management Information System
(SMIS) was a real-time accident reporting and workers’ compensation
system.  He said it captured information for use in the analysis of
injuries and illnesses, provides causal factor information for OSH
program planning and execution and provides rapid transmission of
workers’ compensation claims.  He said the system allows for a
seamless transition from the workers’ compensation claims process to
the OSH information input.  He said that the system sends email
notifications to alert reviewers of new reports.  He indicated that the
system does not yet use BLS coding but DOI was interested in doing so.

Questions and Comments

Ms. Brayden, OFAP asked where DOI received their employment data.  Mr.
Meredith responded that they received their employment data through the
National Business Center in biweekly updates.  He stated that only
active employees could access the injury and illness tracking system.  

Mr. Meredith stated that DOI was looking into a mechanism for tracking
volunteers, and that they were having difficulty accounting for
volunteer exposure.  He explained that volunteers account for an
additional 25 to 40% exposure hours.

Mr. Mullin inquired about how DOI accounted for people who worked off
the time clock.  He explained these individuals were still experiencing
exposure.  Mr. Meredith responded that DOI strictly relied on HR data
for generating its rates.  Mr. Seibert suggested that how the hours
actually worked affected rates is a management issue and should be
footnoted by the subcommittee, but not become a focal issue.  

The meeting was adjourned at 12:03 pm for lunch.  

The meeting reconvened at 1:20pm.

OSHA, BLS, NIOSH Use of Data

BLS

Ms. Holmes explained that Kate Newman from BLS is a member on the
subcommittee but was unable to attend the meeting.  Ms. Holmes briefly
reviewed how BLS annually surveys a sample of 230,000 private sector
establishments for their OSHA 300 data and provided a handout of a
presentation Ms. Newman made at the March 2007 meeting.

OSHA

David Schmidt of OSHA explained how OSHA collects and analyzes OSHA 300
data.  Mr. Schmidt explained that OSHA first reviews the BLS survey
results to identify the high hazard industries.  Mr. Schmidt described
how OSHA collects 300A Summary data from 80,000 establishments with 40
or more employees in high risk industries which allows for establishment
specific injury and illness rates.  Those establishments are ranked. 
The top 14,000 are sent letters from the Assistant Secretary of Labor
for Occupational Safety and Health.  Those establishments are given two
or three months to contact OSHA Consultation for assistance.  Then OSHA
targets inspections to those who have not responded.  OSHA also collects
data from those establishments who have been targeted for inspection to
track progress over two to three years.  Mr. Schmidt explained that OSHA
has noticed that establishment specific rates are stable over time. 
But, for those establishments with the highest rates that receive
inspections, the reduction is 10 percent.  When establishments are
randomly selected the reduction is at most 5 percent.

Questions and Comments

Mr. Mullin inquired if OSHA tracked what has been done differently at
these establishments.  Mr. Schmidt responded that no follow-up was done
to find out the reasons why the reductions had resulted.  Mr. Schmidt
explained that this targeted inspection program ran on a three-year
basis and if an establishment met Site-specific Targeting (SST) criteria
the establishment can go through the process again.  

Mr. Seibert asked if the OSHA data was based on the OSHA records.  Mr.
Schmidt responded, yes that they used the OSHA 300A Summary data.  

Mr. Seibert asked how OSHA targeted federal establishments for
inspection.  Diane Brayden, OSHA explained that OSHA does not currently
have establishment level data for the federal government and currently
uses OWCP claims data.  Mr. Seibert inquired if the goal of the
subcommittee was to develop a consistent format to record similar data
as the private sector so a targeted inspection program could be
developed.  Ms. Brayden clarified that an inspection program would
likely be one of the uses of the data, but not the only use.  In
addition, she commented that data could be used to develop a targeted
training program because it would provide a better understanding of what
types of training were needed.  

Mr. Meredith commented that DOI was all for getting better information
to OSHA and that DOI’s problems are more systemic and need broader
initiatives.  

Ms. Baker asked how those unorganized establishments who likely needed
the most help were identified.  A discussion ensued about how employees
were tracked by establishments.  Mr. Seibert suggested that time card
data be used, similar to DOD.  However, he warned that is often hard to
determine the chain of command within HR information management systems.
 Mr. Seibert and Mr. Mullin stressed the importance of including how
accurately injuries and illnesses are recorded as part of supervisor
performance.  Mr. Meredith, DOI explained that his department uses three
different organizational codes including employee record code, code
where accident assigned, and supervisor’s location code.  Mr. Seibert
explained that establishment codes create problems for DOD because
several military agencies are often located in one establishment.  Ms.
Brayden explained that OSHA has been having difficulty tracking federal
agency data because OSHA does not know where federal agency
establishments are located or the total number of federal
establishments.  

Ms. Kleinberg asked if vessels were considered establishments.  Mr.
Seibert explained that vessels normally considered the shore office
where they were assigned as their establishment.  Mr. Richardson
explained that OWCP data was collected at the port of the ship.  Mr.
Brayden commented that the OSHA recordkeeping regulation defined what an
establishment should be and that in a situation as a ship it would have
some dependency on how independent the ship was.  For example, she
explained that if the Navy was controlling the vessel then injuries and
illnesses would be reported on the Navy log.  However, if they were
working independently then injuries and illnesses would be recorded at
their home port.   

Ms. Kleinberg stressed that an inquiry into how agencies defined
establishments may take years and asked if there were any alternatives
to defining establishments.  Mr. Seibert asked about what type of data
BLS and OSHA needed for their trend analysis.  Mr. Jackson, NIOSH
stressed that the subcommittee should not focus on overtime hours or the
establishment definition as they are not necessary to provide a decent
ballpark estimate of injury and illness rates.  

Mr. Richardson stressed the need to have the data traceable back to the
agency.  He mentioned that agencies can not reproduce or replicate SHARE
numbers very easily and this should be rectified when OSHA 300 data is
collected.   

Mr. Jackson suggested developing a set establishment coding structure
and leave it up to each agency to determine how they fit their
establishments into that formatted coding structure.  

Ms. Brayden asked what should be the smallest level for defining an
establishment.  Mr. Seibert suggested going back to each agency and
asking how they defined establishment.  Ms. Brayden agreed, but stated
that she does not feel that the subcommittee should be charged with
this.  Mr. Jackson stated that the problem was the need for a national
center for collecting data.  He suggested developing a surveillance
system that could be used government-wide.  Mr. Jackson argued that
currently there is no system in place to provide an opportunity to
compare agencies, compare with the private sector, or aggregate data for
broad scale OSH intervention.  

NIOSH

Larry Jackson explained that NIOSH is a research organization that is
capable of analyzing different types of data sets.  He provided an
example of how NIOSH had begun developing a model query system for the
federal workers’ compensation data.  He said that if OSHA or BLS was
able to collect the OSHA 300 and 301 records from federal agencies NIOSH
could potentially set up a query system that would provide agencies
analysis of their data and allow them to compare themselves to other
agencies.

Questions and Comments

Mr. Richardson asked Mr. Jackson to identify what kind of data is needed
to populate the database template described in his presentation.  Mr.
Jackson explained that he needed OSHA 300A Summary data, the 301 case
records, and the demographics of workers by FTE.  Ms. Brayden asked if
BLS and NIOSH could get together to decide what data needs to be
collected.  Mr. Jackson answered that OSHA had all of the information
off the 300 and 301 forms.  Mr. Richardson asked if NIOSH had received
data without all personal identifiers.  Mr. Jackson explained that a
security measure could be applied which allowed agencies to see only
their data.  Mr. Jackson clarified that BLS does not have an analytical
role, but a collection role.  NIOSH has an analytical role.  Mr. Seibert
suggested that agencies develop their own establishment code with an
index.  

Ms. Brayden argued that the system needed to be effective so it could
provide an incentive for cooperation.  

Mr. Seibert highlighted what he thought should be two different goals of
the subcommittee.  The first goal should be to mandate reporting and
provide data standards on how it is coded.  In addition, he explained
that for those without systems, OSHA can service candidate systems that
can be used.  Mr. Richardson suggested developing a system to receive
data from those with existing accounts with the ability to allow smaller
agencies, without existing systems, to directly enter into system.  Ms.
Baker emphasized that the data needs to be submitted quarterly,
especially for bigger agencies.  

Ms. Holmes stated the need to establish a timeline and schedule the next
meeting.  Ms. Brayden wanted to discuss the goals for next meetings. 
Mr. Seibert stated that one goal should be to develop a transition from
OWCP data to 1904 data.  Michelle Walker, OFAP stated that the goal is
to have agencies collecting OSHA 300data in a way that can be aggregated
by the close of SHARE in 2009.  Mr. Mullin asked what this meant for
agencies.  Ms. Holmes answered that it would be better to target
resources towards those agencies and training needs that needed it most
and that it could provide a mechanism for analyzing data.

A discussion ensued regarding how cooperation could be encouraged in
agencies.  Ms. Carraway, DHS emphasized the need to describe to agencies
how participation would benefit them.  Ms. Brayden stressed that the
goal was to provide a better work environment for government employees. 
Ms. Baker stated that the need is to emphasize that providing a
mechanism for something you are doing anyway, but to help it be more
efficient and faster.  Ms. Carraway stated that change management is
going to be needed at home.  

Mr. Seibert stated that the second objective of the subcommittee should
be to work with NIOSH, BLS, and OSHA to determine what data is needed. 
He also emphasized that this initiative would need to stress what
agencies would get out of sending this information to NIOSH, OSHA,
and/or BLS.  

Ms. Kleinberg asked if the objective of the subcommittee could simply be
stated as it is just a replacement or improvement to the SHARE
Initiative.  Ms. Brayden explained that it is not a replacement and that
OWCP data will continue to be collected.  Ms. Walker stressed the need
to notify all agencies that something is underway, clearly defining the
purpose and goals of this effort.

Mr. Seibert proposed that the subcommittee meet again soon.  

The next meeting was scheduled for June 14th.  

Mr. Mullin asked if there were any more comments and thanked everyone
for their insights.  

The meeting was adjourned at 3:50pm by Jonathan Mullin.  

 

 

Federal Advisory Council on Occupational Safety and Health (FACOSH)

Recordkeeping Subcommittee

June 14, 2007 Meeting Minutes

The FACOSH Recordkeeping Subcommittee met at 9:00 a.m. in C-5521,
Conference Room 4, of the Frances Perkins Building located at 200
Constitution Avenue, N.W., Washington, D.C.

Voting Members:	Representing:

CAMILLE CARRAWAY	DHS

JONATHAN MULLIN	NASA

MILLIE RODRIGUEZ	AFGE

Non-Voting Members:

SHEILA BAKER	DOL

JOE DUBOIS	OSHA-OFFICE OF STATISTICAL ANALYSIS

LUANN JENKINS	VA

JIM KALLENBORN	OSHA-DIRECTORATE OF INFORMATION TECHNOLOGY

TERRY MEISINGER	SMITHSONIAN INSTITUTION

JIM MEREDITH	DOI

BRYAN RICHARDSON	DHS-TSA

OFFICE OF FEDERAL AGENCY PROGRAMS STAFF:

DIANE BRAYDEN	OSHA-OFAP

MIKKI HOLMES	OSHA-OFAP

LEWIS LIGON	OSHA-OFAP	

MICHELLE WALKER	OSHA-OFAP

Call to Order

Management Co-Chair Jon Mullin, NASA, called the meeting to order at
9:04 a.m.  Everyone then introduced themselves.  

GAO Report

Mr. Mullin briefly reviewed the GAO report referenced in the last
meeting and said he thought it supported the work of the subcommittee. 
He asked whether the report had been the driver behind creating the
subcommittee.  Ms. Brayden indicated it was one of the factors but OSHA
had recognized the importance of this issue prior to the report.

May 31st Minutes

The May 31st minutes could not be approved because there was not a
majority of voting members present.  It was agreed that a vote for
approval would be done via email.

Topics for Discussion

Three-Stage Implementation Plan

Ms. Holmes presented a three-stage implementation plan that OFAP staff
had developed in consultation with Mr. Schmidt and Mr. Kallenborn.  The
plan includes:

Stage I—Collecting OSHA 300A Summary data

Stage II—Collecting OSHA 300 Log and 301 Incident Report data

Stage III—Helping agencies track OSHA recordkeeping data

Ms. Holmes explained that OSHA currently collects 300A data from the
private sector and Mr. Schmidt thought his office could expand that
survey to include federal worksites by CY 2009 for Stage I.  She
explained that, according to Mr. Schmidt, in order to do so OSHA would
need a list of all the federal establishments (and if available,
establishment codes).  Ms. Holmes explained that in collecting the data,
OSHA would be interested in distinguishing injuries experienced by
contractors, volunteers, and non-volunteer employees and Mr. Schmidt
said that would be feasible.  

Ms. Holmes provided more details on the staged approach.  She said that
the major first stage challenges would be for agencies to identify all
their establishments.  In addition, some agencies might have difficulty
identifying volunteers and the number of hours volunteers worked. 
Finally, she explained that Mr. Schmidt thought the cost of the data
collection would be relatively minimal if agencies could provide the
data electronically, but the cost would rise if a lot of follow-up
and/or manual data entry was required.  In addition, costs would
increase if data was collected each quarter rather than annually.

Ms. Holmes explained that for Stage II OSHA could create an on-line form
to collect the OSHA 300 and 301 data that would populate a database. 
Alternatively, OSHA might be able to adapt the existing system that BLS
currently uses.  Ms. Holmes said that the collecting of this data would
begin sometime after CY 2009 and could potentially be done in
phases—with those agencies that can provide the data electronically
doing so earlier.  Ms. Holmes said that given the type of information
collected, it was unclear whether BLS or OSHA should store the
data—since BLS was more likely to analyze much of it.  Ms. Holmes
explained that an added cost for Stage II would be the coding of the
narrative fields from the OSHA 301.  Ms. Holmes explained that Stage III
would be developing a system for agencies that currently do not have a
data collection system.  

	

	Questions and Comments

Mr. Meredith inquired if making this request from the federal agencies
would require a rule change.  Mr. DuBois said that if OSHA requests this
information, federal agencies would have to provide it, explaining that
it is part of the 1904 regulations paragraph 30 or 40 (Recorders note:
see 29 CFR § 1904.40, Providing records to government representatives).
 Mr. Mullin asked that the subcommittee members be provided with a copy
of that regulation.  

Mr. Meredith inquired why segregating volunteers was necessary when 29
CFR § 1960 treated them as employees.  Ms. Brayden said that in order
to compare federal agencies’ injury and illness rates to the private
sector, OSHA would need to be able to exclude volunteers.

Mr. DuBois said that if BLS collected the data, OSHA would have limited
access to it because of privacy issues.  Mr. DuBois said that the intent
for OSHA is not to collect any data with individual identifiers.  Mr.
Mullin asked about the Privacy Act implications for collecting this
data.  Mr. Richardson said that the “Systems of Records” permits
limited sharing of data between federal agencies.

Mr. Meredith asked if OSHA would be collecting a random sample of
establishment data.  Ms. Holmes explained that OSHA planned to collect
data from all federal establishments.  Mr. Meredith asked how the 301
data would be used.  Ms. Brayden said it would be used to identify
injury types and activities that resulted in serious injuries.  She said
OSHA would use the analysis of this data to develop training programs
and activities and target worksites to reduce hazardous conditions.  Mr.
Meredith said it was his experience in DOI that agencies had unique
injury experiences that could not be generalized, so he was not sure
OSHA would be able to conduct a meaningful analysis across the federal
government.  Ms. Brayden explained that OSHA would analyze the data in
different ways and could look at agency specific data for OSHA
evaluations of federal agencies, to identify problem areas to focus
interventions.  

Mr. DuBois said it would be helpful to define establishment at a level
that would be useful, such as tracking activities—such as firefighters
and border patrol.

Mr. Richardson said that he thought that the plan to collect all the
information was feasible.  With PII (personally identifiable
information) there would be 32 data elements and without it there would
be 24 data elements.  He said that he thought agencies could provide
work hours on a quarterly basis and a field could be created to identify
whether the hours and injuries were linked with contractors, volunteers,
or non-volunteer employees.

Mr. Mullin asked whether any document existed, explaining the various
types of establishments.  Ms. Brayden explained that OFAP was currently
working on such a document and asked committee members to email the
office with any unique examples that they want reviewed and possibly
used as examples in such a document.  Ms. Brayden requested these
examples be emailed to Ms. Holmes no later than June 19th.  Ms. Holmes
said she would send out an email reminder and also make the request to
members who were unable to attend the meeting.

Ms. Brayden explained that it would be fundamental for agencies to be
able distinguish contractors, volunteers, and non-volunteer employees
before OSHA began collecting Stage I data.  Mr. Mullin asked Mr.
Meisinger how the Smithsonian Institution tracked volunteers.  Mr.
Meisinger explained that the Smithsonian had a volunteer office that
kept track of this information.  Ms. Baker said that FECA had a formula
that agencies could use to estimate/calculate the number of hours
volunteers worked.  Ms. Holmes asked Mr. Meredith how DOI kept track of
volunteer hours.  He explained that there was a distinct set of rules
for volunteers but he was unfamiliar with them.  He said he would
research these rules.  He said that he receives annual reports on the
number of volunteer hours and said establishment personnel enter
volunteer hours at the time an injury is recorded.  Ms. Carraway urged
the committee to consider agencies that do not have a good grasp of
their volunteers or the hours they work.  Mr. Mullin questioned whether
it was cost effective to “chase” volunteer hours.  Mr. Meredith said
that it was important for DOI to identify volunteers because they have
the potential to reduce injury and illness rates for the department. 
Mr. Mullin asked whether DOI provides training for volunteers and if the
agency incurs the cost of that training.  Mr. Meredith said that DOI
does pay for volunteer training.  

Mr. Kallenborn asked whether OFAP was talking about changing the 300A
form in order to collect information on contractors and volunteers.  Ms.
Walker noted that any adaptation to forms might require OMB clearance. 
Mr. Richardson asked why OSHA had the need to separate volunteers and
contractors.  Ms. Walker explained that OSHA has received inquiries in
the past about the federal government’s safety performance compared to
that of the private sector and the separation is needed to make that
comparison.  Ms. Brayden said that OSHA would also want to see how the
injury rates for volunteers compared to those of non-volunteer federal
employees.  Mr. Richardson suggested that OFAP could use the “Job
Title” field on the OSHA 300 Log form to identify whether the person
injured was a contractor, volunteer, or non-volunteer employee.  He
suggested OFAP send a mock spreadsheet to the agencies to show them the
data elements OSHA wants to collect and get their feedback.  

Mr. DuBois said that it is critical to identify all the data processing
needs upfront.  Mr. Richardson agreed, noting that if OSHA does not
explain all the information it needs, agencies will design a system for
one set of information and be frustrated when OSHA comes back with a new
request for a different set of information.  Mr. Richardson said he did
not think the first stage was needed and OSHA could just request the 300
data and could generate the 300A data from it.  He said that agencies
would already have the 300 data since they would need it in order to
provide the 300A data to OSHA.  He said that if OSHA requests the 301
data it will have to deal with a whole other level of security to
address the PII.  

Mr. Meredith said that a benefit of switching from OWCP data to OSHA
recordkeeping data for SHARE would be that he would have more control
and understanding of the SHARE results against which the senior
management is measured.  Mr. Richardson concurred saying that this
switch would reinforce that federal agencies were now being held to
private sector standards.  He said that it would be much more helpful
for safety managers to be able to duplicate the results under the first
two SHARE goals—which they currently cannot do with the OWCP data. 
Mr. Mullin asked whether agencies would no longer need to be concerned
about OWCP data.  Ms. Baker explained that the last two SHARE goals
would continue to be based on OWCP data.  

Mr. Mullin questioned whether the SHARE results were very meaningful
given they were not well publicized.  Ms. Brayden said that OFAP would
consider increasing publicity for SHARE.  She noted that OFAP had
received final approval for the President’s report on SHARE and would
consider having a press release in the future.  Mr. Meredith suggested
that the report get sent to all the federal agencies.  Ms. Carraway
suggested developing a change management plan that included a
communication component highlighting the cost reductions and programs
that have been implemented to assist in reducing injuries and illnesses.
 Ms. Brayden suggested focusing on cost would be effective.  Ms.
Rodriguez said that highlighting best practices would also provide
positive publicity.  Ms. Carraway noted that cost/benefit language works
well with management.

Ms. Holmes reviewed the overall discussion, highlighting Mr.
Richardson’s suggestion to just collect 300 data and dropping the idea
of collecting data in stages.  She noted that besides the 300 data, OSHA
would also need the 300A data that has the SIC/NAICS code, the number of
contractors, volunteers, and non-volunteer employees and the hours
worked by these different groups. She said requesting that the data be
broken down by these categories might require OMB clearance.  She noted
that while present members had suggested there was no need to collect
the 301 data, neither BLS nor NIOSH was represented.  Ms. Brayden
suggested OFAP would have a discussion with NIOSH and BLS after the
meeting.  Ms. Holmes said that NIOSH at the prior meeting had suggested
ways it could create on-line programs that would allow agencies to
manipulate their data.  Mr. DuBois said that a web-based system could
provide immediate results.  Mr. Richardson noted that FISMA (the Federal
Information Security Management Act) requires that the agency hosting a
system has to ensure through certification and accreditation that the
system is secure.  He said that the security cost is to the host agency
and not to agencies that access the database.  Ms. Baker said that the
DOL database could be used as a model for the system that OFAP seeks to
build.  Mr. DuBois noted that OSHA had considered building a similar
system for the private sector but got push back from private vendors
interested in the same proposal. 

Establishment Identification and Coding

Ms. Holmes asked that each agency representative explain how their
respective agencies identify and code their establishments.  

Smithsonian:  Mr. Meisinger explained that each museum has a separate
OSHA log and the Smithsonian has a code for each museum and other
establishments.

VA:  Ms. Jenkins said that the Veterans Health Administration (VHA) and
the National Cemetery Administration (NCA) have a code for individual
facilities but could also identify and disaggregate the data to a much
more specific level or aggregate it up to a national level.  She noted
that the injury is logged where it occurs and not where the employee is
stationed.  

NASA:  Mr. Mullin said that NASA facilities and buildings each have a
code in the IRIS system.  He noted that even workplaces that are not
governed by OSHA are required to track injuries.

DHS:  Ms. Carraway said that in general DHS codes facilities by building
and function.  She said that there are challenges with the agencies with
more mobile workforces, such as the Secret Service and the Border
Patrol.  She said that Secret Service injuries are tracked back to the
agent’s home office.  Border Patrol agents report their injuries to
the worksite at which they occurred.  She said that FEMA creates an
establishment code for each disaster site but once the site ceases to
exist the records go to the region that managed the disaster even if the
disaster did not actually occur in that region.  She said that the Coast
Guard uses a mishap system for tracking injuries. 

DOI: Mr. Meredith said an injury is assigned to the accident location. 
He said that the SMIS coding system has several levels so he does not
dictate to the subagencies how to define establishment.  He said
generally the bureaus go down to the lowest major organization level,
such as the field office level.  He said a national park could go down
to the park level or get as specific as the maintenance shop at the
park.  He said he can review the data at whatever level he chooses and
could provide a data dump at the OSHA defined establishment level.  He
said that the establishment coding is based on the personnel pay system
for which he gets weekly downloads.  He said that sometimes the coding
gets changed without his knowledge and he has to make system updates. 
He said in providing a data dump to OSHA he would use different codes to
avoid the random changes that occur to the other coding system.  He said
the challenges for DOI are the temporary establishments such as
firefighting and emergency response teams (DOI had 5,000 people assigned
to Katrina) that generally report injuries back to the home log. 

A break was taken from noon until 1:15PM.  At 1:15 Ms. Rodriguez called
the meeting to order.

TSA: Mr. Richardson said that the coding for tracking injuries was based
on the organizational/personnel structure that could be broken down to
seven levels—which could link an injury to a specific checkpoint at a
particular airport.  He said that he would go down to the fourth level
to reach OSHA’s definition of establishment—the first level being
TSA, the second level being the regional office, the third level being
the hub-airport and the fourth level being the airport.  Mr. Richardson
said that if an injury to an employee does not occur at his/her home
airport, a manager can manually input the data and link the injury to
worksite where it occurred.  He said the logs/records are available to
people with authorization.  For example a manager for an airport can
review that airport’s logs.

DOL:  Ms. Baker said that DOL had a similar coding to that of DOI and
TSA.  She said that SHIMS only allows for five organizational levels
even though the coding is based on seven layers.  Ms. Baker said that
agencies can view data at whatever level they choose.  

Questions and Comments

Ms. Holmes asked if those present could provide data to OSHA for the
OSHA definition of establishments.  Everyone said that with
clarification of the definition of an OSHA-defined establishment they
thought they could provide data in the required format in the timeframe
that OFAP is proposing.  Ms. Carraway noted that she was not sure
whether other agencies not present could do so.  Mr. Meredith said that
the sooner OFAP could get the memo out requesting information on
agencies establishments the better.  The memo would give agencies a
heads up on what OSHA is planning and also provide early feedback to
OSHA if some agencies were having difficulty with the request.  Members
said they thought it best if the memo be sent to the DASHOs to raise the
importance of this request.  Mr. Richardson noted that if agencies
currently do not have a system to code their establishments OSHA could
apply OPM’s POI (personnel office indicator).

Ms. Brayden asked if agencies would want to report data on a quarterly
or annual basis.  Mr. Meredith said that quarterly reporting would help
legitimize OSH managers work/analysis within their agencies.  Ms. Baker
also noted that the two OWCP SHARE goals would probably continue to be
calculated on a quarterly basis and it would be consistent that the new
OSHA recordkeeping goals be calculated in the same manner.  

Ms. Brayden noted that OSHA would have to confirm agencies’
establishment coding on an annual basis.  

Timeline for Subcommittee and Proposed Projects

Ms. Holmes reviewed the timelines that had been discussed.  She said
that OFAP would be requesting, through a memo to DASHOs (sent out
sometime this summer), a list of establishments with optional codes from
each agency by January 1, 2008.  She said that OSHA would develop a
system to collect OSHA recordkeeping data which agencies would have to
start using by CY 2009.  She said developing a system for agencies
without one would occur sometime after CY2009.  

Ms. Holmes suggested a subgroup composed of a BLS representative, a
NIOSH representative, OSHA IT representatives, Mr. Richardson and Ms.
Baker meet to discuss a system design for collecting the OSHA
recordkeeping data.  The subcommittee members agreed and asked they be
briefed on the meeting.  Ms. Holmes said she would schedule the meeting
with the subgroup for sometime in late June or early July.  

Ms. Holmes reminded the subcommittee of the three deliverables for the
subcommittee—a timeline, a PowerPoint to FACOSH and a report on the
subcommittee findings.  She said that the timeline could be incorporated
into a PowerPoint for the September 27th FACOSH meeting.  She said that
the report could be presented in stages as the portions of the project
are complete.  She explained that the report could be oral. 

Next Meeting—Teleconference

The subcommittee tentatively proposed a teleconference for July 31st. 
Ms. Holmes said she would confirm this date and provide dial-in
information once she checked on the availability of the members who were
not present.

The meeting was adjourned at 3:35 PM.

Federal Advisory Council on Occupational Safety and Health (FACOSH)

Recordkeeping Subcommittee

July 31, 2007 Meeting Minutes

The FACOSH Recordkeeping Subcommittee had a teleconference at 1 p.m. on
July 31, 2007.  OFAP staff met for the teleconference in N-3112, of the
Frances Perkins Building located at 200 Constitution Avenue, N.W.,
Washington, D.C.

Voting Members:	Representing:

CAMILLE CARRAWAY	DHS

DEBORAH KLEINBERG	SIU

JONATHAN MULLIN	NASA

MILLIE RODRIGUEZ	AFGE

JOHN SEIBERT	DOD

COREY THOMPSON	APSU

Non-Voting Members:

JIM KALLENBORN	OSHA-DIRECTORATE OF INFORMATION TECHNOLOGY

TERRY MEISINGER	SMITHSONIAN INSTITUTION

KATE NEWMAN	BLS

JIM MEREDITH	DOI

BRYAN RICHARDSON	DHS-TSA

DAVE SCHMIDT 	OSHA-OFFICE OF STATISTICAL ANALYSIS

Office of Federal Agency Program Staff:

DIANE BRAYDEN	OSHA-OFAP

MIKKI HOLMES	OSHA-OFAP

LAURA MILLS	OSHA-OFAP	

MICHELLE WALKER	OSHA-OFAP

Call to Order

Management Co-Chair Jon Mullin, NASA, called the meeting to order at
1:07 p.m.  Everyone then introduced themselves.  

June 14th Minutes.

All voting members approved the minutes from the June 14th meeting.

Topics for Discussion

Data System Proposal from Subgroup

Ms. Holmes explained that the subgroup had proposed developing a
BLS-type system and then developing a NIOSH-type web based query system
that would allow agencies to query their own agencies’ data.  Mr.
Mullin asked how often data would be collected and Ms. Holmes said it
would be an annual data collection effort.  

Mr. Seibert suggested that the data system proposal should be more
formal and include the purpose(s) of the system and how different groups
would use the system.  Mr. Seibert asked whether the purpose of the
system was for smaller agencies to be able to query their injury and
illness records.  Ms. Rodriguez said she thought the main purpose of the
system was for OSHA to be able to collect injury and illness data that
agencies are already required to collect.  Ms. Newman said she thought
the data gathered by the system would provide information about how the
federal agencies compared to the private sector.  Mr. Seibert suggested
that a statement of purpose identify how different groups would use the
database.

Mr. Seibert asked whether this system would allow smaller agencies
without their own internal databases to use this system on a day to day
basis and allow them to generate the required OSHA forms.  Ms. Brayden
said that this system would not provide that type of service and said
she did not think that funding allowed OSHA to pursue such a system. 
Following the teleconference Ms. Newman explained that the subgroup had
in fact discussed this issue and that Mr. Richardson had developed an
Access database prototype to specifically address this issue.  She said
that she thought that the roll out of the BLS-type data collection
database would include an Access-type data base for smaller agencies. 
She said she envisioned it to be formatted to allow the appropriate data
transfers.  If agencies then chose to modify the system they would then
be responsible for ensuring the appropriate specifications to transfer
the required data.

Mr. Meredith asked whether agencies would be able to see aggregate data
for different occupational series.  Ms. Newman said that she assumed BLS
would provide that type of data.  She noted that the private sector data
allows comparisons using gender, job series, etc.   Mr. Schmidt said
that the OSHA inspection database is set up so that certain data is
exposed to the public and thought a similar setup could be achieved with
the federal recordkeeping database.  

Rule Changes

Ms. Holmes explained that OFAP staff had met with the DOL solicitors who
recommended a simple rule change to specify federal agency collection of
recordkeeping records on an annual basis.  She explained that the
language for the rule change would mimic the private sector regulations.
 She said in addition to this change, the preamble would include
language reminding federal agencies that volunteers are considered
employees for injury and illness recordkeeping purposes.  She said that
the rule change would include instructions for agencies to identify
volunteers under the “Job Title” on the OSHA 300 form.  Mr.
Meisinger asked whether or not the rule change would require that
federal agencies identify contractors listed on the logs.  Ms. Holmes
explained this would not be required since it is not required for the
private sector.  Ms. Holmes also said that the rule change would request
that federal agencies use the OPM job series and grade level for the
“Job Title”.  Mr. Meisinger said he was not sure agencies would be
able to assign an OPM job series to volunteers since they may do a
variety of activities.  Finally, Ms. Holmes explained that the rule
change would eliminate the January 1 due date for the annual report
since the recordkeeping data is maintained on a calendar year basis, as
opposed to the current OWCP data which is maintained on a fiscal year. 
Mr. Seibert asked for further explanation for this change.  Ms. Brayden
explained that given the OSHA records are maintained on a calendar year,
agencies would need time after January 1 to analyze the data and prepare
it for an annual report.  

Establishment Guidance Update

Ms. Holmes explained that OFAP is finalizing the guidance explaining how
federal agencies should be defining their establishments for OSHA
recordkeeping purposes.  Mr. Mullin requested the draft be shared with
the subcommittee members and Ms. Brayden agreed to do so.

Presentation for FACOSH

Ms. Holmes explained that she would be drafting a PowerPoint
presentation for the FACOSH meeting which had now been re-scheduled
(tentatively for October 11th).  She said that she would share the draft
presentation with subcommittee members prior to the FACOSH meeting and
welcome their input.

Tasks:

Mr. Mullin asked for a review of what was agreed upon during the
teleconference.  Ms. Holmes said she would provide the subcommittee with
a high level statement of purpose for the data system, a draft of the
establishment guidance and draft of the FACOSH presentation.  Mr. Mullin
said that an statement of justification was also needed.  Ms. Holmes
said she would try to develop a “statement of justification”, once
she understood what it should contain.  Mr. Seibert said he would send
Ms. Holmes an example of a “Statement of Requirement Document”
(SORD).

 

The meeting was adjourned at 2:05 PM.

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