Response to OMB's Questions

Questions about the Survey of Occupational Injuries and Illnesses

Please provide responses to the concerns raised in the public comments that OMB received from AOL.

In this response, please include responses that address the following:

• Has the Solicitor of Labor reviewed the concerns raised by the AOL comments and do they concur that BLS is conducting the survey in accordance with the OSHA regulations?  SOL did not review BLS' written response to the AOL comments prior to them being sent to OMB.  Nevertheless, we did consult with SOL on the response and the response reflects SOL guidance.  SOL does concur that BLS is conducting the SOII in accordance with the OSHA regulations.

• In the stratified random sample design for the SOII, would BLS be able to publish meaningful estimates by state for the size and industry cells containing AOL if establishments in that cell were selected with high probability (e.g., 80 or 90%), but not with certainty? Units selected with certainty contribute zero to the sampling error. The current sample has a certainty cutoff in which larger establishments are selected as self-representing during estimation. If units, normally selected with certainty, were sampled as non-certainties and if there was a sufficient number of establishments in the sampling cell, then some of the establishments in the cell would not be sampled and the sampling errors of individual estimates would be larger. In the State of Virginia, sampling the cell with AOL with an 80% or 90% probability would still result in AOL being selected with certainty. Therefore, there would be no impact on the sampling error for this cell.

• Has BLS examined the burden for establishments in partially exempt industries, in terms of their review of instructions, training personnel, and developing systems to collect and maintain the information? For exempt industries, BLS uses the same burden estimates for transferring information from records to the BLS9300 as are used for non-exempt industries. We do not believe there is any difference between exempt and non-exempt industries in the work required to transfer this information. BLS also uses the burden estimates used by the Occupational Safety and Health Administration (OSHA) for the recording of information on the OSHA300, OSHA300A, and OSHA301 forms. This latter burden information is used in our burden estimates for exempt industries. OSHA states that their estimate of burden includes time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. BLS has not examined burden for establishments beyond this. BLS states in the clearance package for this survey, “The recordkeeping practices require only manual recording of information, thereby, no systems work would be required. Employers who have chosen to keep records electronically need only access them for survey purposes.”