

                                       
                                  MEMORANDUM
                                       
Date:	March 2, 2023
From:	Susan Day, Hui Zhou, and Natalie Rodman, Eastern Research Group, Inc.
To:	Tom Mockler, DSG/OSHA
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Subject:	OSHA Recordkeeping Standard - Research Tasks
ERG researched the following three questions in support of the OSHA Recordkeeping FEA.

 How much time would companies need to spend to modify their own custom software to be compliant with the OSHA Recordkeeping rule?

Best professional judgement was provided by ERG' Chief Solution Architect based on ERG's experience with prior ITA data collection. For the following two items with a data upload (or batch upload) method via OSHA ITA online application, the amount of time required may be:
 Batch upload the data to the ITA using commercial software (e.g., https://osha300online.com/)
 Response: if the online form follows OSHA 300 Log reporting criteria, the effort will be less by sending the log data to OSHA via predefined CSV or Excel file.
 LOE: 8~16 hours
 Batch upload the data to the ITA using their own software
 Response: this one may vary depending on the software and tracking tools used to keep the logs (e.g., legacy system versus modern system). The effort may be in the range of 20~50 hours.

 What is the appropriate BLS OCC and wage for the person(s) responsible for modifying custom software?

The appropriate Bureau of Labor Statistics (BLS) code is 15-1252: Software Developers and national wage estimates are shown in the tables below.

Employment estimate and mean wage estimates for Software Developers
                                Employment (1)
                              Employment
RSE (3)
                               Mean hourly
wage
                             Mean annual
wage (2)
                                 Wage RSE (3)
                                   1,364,180
                                     0.7 %
                                    $ 58.17
                                   $ 120,990
                                     0.4 %
Source: https://www.bls.gov/oes/current/oes151252.htm




Percentile wage estimates for Software Developers
                                  Percentile
                                      10%
                                      25%
                                 50%
(Median)
                                      75%
                                      90%
                                  Hourly Wage
                                    $ 30.99
                                    $ 43.69
                                    $ 58.05
                                    $ 73.06
                                    $ 81.04
                               Annual Wage (2)
                                   $ 64,470
                                   $ 90,870
                                   $ 120,730
                                   $ 151,960
                                   $ 168,570
Source: https://www.bls.gov/oes/current/oes151252.htm

 How many licenses do vendors typically sell to companies for aftermarket software 

From our current research, it seems that aftermarket software vendors' pricing is typically based on a number of workers often organized by tier (i.e., 1-5 workers has a cost of $X, 6-15 workers has a cost of $Y, etc) OR based on a number of users. The vendors ERG spoke with described selling to companies with a handful to hundreds of users and 35 to over 25,000 workers.

One vendor stated that the price of licenses is based on the number of users, specifically tiers of users (0-25, 50-250, etc.) and that the range of licenses sold per company is 1-8,000 licenses. The vendor noted that over 10,000 licenses becomes very complex (from the IT standpoint). The vendor also explained that larger parent companies purchase the licenses and then can distribute to individual establishments. Typically, each establishment is not purchasing the licenses for themselves.  However, individual establishments can purchase these licenses on their own if they want (perhaps they want to have a small group as a tester, or a certain location has a higher need for safety). 

This vendor also clarified an early statement made regarding the percent of employers using software to meet OSHA recordkeeping requirements.  The vendor clarified that 30-40% of employers using software apply to ALL software, not just aftermarket software. For context, the vendor's estimate was based on a Daily Advisor safety survey he was a part of, which involved roughly 2,000 respondents. 

This vendor also confirmed there is a hybrid software option. Because of the open API, large companies that do their in-house recordkeeping can purchase some features from these vendors. 

During our past research we also learned the following that suggests some pricing is by location/site. 

Vendor A
::Employers pay $96 per year, per location.
:: 5 locations or less are billed annually.
:: 6 or more locations can be billed monthly. 

Vendor B
Offers 3 packages:
1) Starter (25 sites & departments; pick any 3 of the 9 features, which includes Incident Reporting Hazard Identification and OSHA 300 Logs (USA)).
2) Professional (50 sites & departments; pick any 6 of the 9 features, which includes Incident Reporting Hazard Identification and OSHA 300 Logs (USA))
3) Unlimited (unlimited sites & departments)

Vendor B provided the following additional details on their packages. 
 There is a standard administrative package and a "light user" package where only tracked individuals are included (not all employees). For example, if a company has 1,000 employees, but only 200 need to be tracked for safety reasons, they can just pay for those 200.
 The minimum number of licenses sold would be around 20, but the representative did not have a sense of the range or average. 
 From a location standpoint, the licensing is essentially unlimited. Therefore, if there are multiple locations, a company would not be paying per-site. 


