Note to Reviewer

February 4, 2013

TO THE REVIEWER OF: OMB NO. 1220-0141

Cognitive and Psychological Research

FROM: Polly Phipps

Senior Survey Methodologist

Office of Survey Methods Research

SUBJECT: Submission of materials for testing on

reporting days away from work injuries and illnesses

in the Survey of Occupational Injuries and Illnesses

(SOII) and Workers’ Compensation claims data

Please accept the enclosed materials for approval under the OMB clearance package number 1220-0141 “Cognitive and Psychological Research.” In accordance with our agreement with OMB, we are submitting a brief description of the research, and the materials to be used in the research at least two weeks prior to the beginning of the study.

Four state partners will be testing a telephone questionnaire with establishment respondents who complete the SOII. The questionnaire explores reasons for differences in reporting of days away from work illnesses and injuries in the Survey of Occupational Illnesses and Injuries and Workers’ compensation claim data.

We plan to test the questionnaire with respondents from up to 80 establishments (20 per state). The maximum number of burden hours is estimated to be 40 hours.

If there are any questions regarding this project, please contact Polly Phipps at (202) 691-7513.

Attachments

Testing a Questionnaire Exploring Differences in the Survey of Occupational Injuries and Illnesses (SOII) and Workers’ Compensation claims data

I. Purpose

The goal of this study is to test a telephone instrument that explores possible reasons for differences in reporting days away from work injuries and illness between the SOII and State Workers’ Compensation claims data. Studies comparing the two data sources suggest that there are differences, and the differences may be associated with a lower count of injuries and illnesses in the SOII. Since SOII respondents are requested to complete the survey using Occupational Safety and Health Administration (OSHA) logs and supplemental reports, we focus on both OSHA forms and the SOII in our protocol.

II. Methodology & Participants

The proposed test will be conducted via telephone interviews by four state partners who will be testing a telephone questionnaire with establishment respondents who complete the SOII. The state partners will review and summarize the results. In cooperation with OSMR staff, a final questionnaire will be developed based on test responses.

SOII respondents from the States of Minnesota, New York, Oregon, and Washington will be selected into the test based on employment size, industry, and multi-establishment status.

• Employment Size (1-10, 11-49, 50-249, 250-999, 1000+)

• Industry (natural resources and mining; construction; mining; trade, transportation, and utilities; information; financial activities; professional and business services; education and health services; leisure and hospitality; other services, public administration )

• Multi-establishment or not

The instrument (Attachment 2) has been designed to question respondents about general company background and workplace practices, the role of persons involved in injuries and illness recordkeeping, and OSHA and SOII recordkeeping practices. Potential respondents will be recruited by telephone (Attachment 1).

III. Subject and Burden Hours

The BLS estimates that the total burden will be 40 hours. Testing will begin in February and continue through April 2013. We expect that the telephone interviews will take approximately 30 minutes.

IV. Confidentiality

Respondents will be informed as to the voluntary nature of the study. Information related to this study will not be released to the public in any way that would allow identification of individuals except as prescribed under the conditions of the Confidential Information Protection and Statistical Efficiency Act of 2002 (Title 5 of Public Law 107-347) and other applicable Federal laws.

V. Attachments

1. Telephone solicitation protocol

2. Draft employer test instrument

Attachment 1. Telephone Solicitation Protocol

1. Call person completing the SOII survey for the reference year.

2. Suggested Script

Hello, my name is (NAME). I am calling for the Bureau of Labor Statistics and (State agency). Is (INITIAL CONTACT NAME) there? Our records show that you are the person that completed the 2010 Survey of Occupational Injuries and Illnesses. Are you the person who prepares this report?

 YES

 NO

We need your help to make our data better. We are interested in talking to you about your experiences with the BLS survey, OSHA recordkeeping, and your thoughts on differences between the BLS, OSHA, and Worker’s Compensation reporting and recordkeeping. This study is not part of any type of enforcement action and we are not conducting an OSHA inspection. Per federal law, we will not and cannot share any information with OSHA.

The BLS, its employees, agents and partner statistical agencies will use the information you provide for statistical purposes only and will hold the information in confidence to the full extent permitted by law. In accordance with the Confidential Information Protection and Statistical Efficiency Act of 2002 (Title 5 of Public Law 107-347) and other applicable Federal laws, your responses will not be disclosed in identifiable form without your informed consent.

We estimate it will take you an average of 30 minutes to participate in this research.

Your participation in this research project is voluntary, and you can decline to answer any questions. This survey is being conducted under OMB Control Number 1220-0141. This control number expires on February 28, 2015. Without OMB approval and this number, we would not be able to conduct this study.

I realize you are probably very busy, but would you have a little time to assist us with this study? There is nothing you need to do to prepare.

3. IF RESPONDENT AGREES:

• Begin with telephone questionnaire, if possible.

• Otherwise schedule an appointment.

• Which day between [date] and [date] would be best for you?

APPT DAY: ____________________________________________

• What might be the best time of day?

APPT TIME: _______________________(about 30 minutes)

• I called [PHONE NUMBER]. Is this the best phone number to use to reach you?

□ Yes

□ No → Correct the information here: ____________________

• We’ll give you a reminder call or email about our appointment a day or two before the interview.

• Confirm mailing address. Also get, email for possible reminder.

_______________________________________________

_______________________________________________

_______________________________________________

Email: _________________________________________

• If you need to reach me for any reason, you can call me at [number]. Again, my name is [name]. Do you have any questions for me? Thank you very much for your time. We look forward to talking with you.

Attachment 2. Employer Questionnaire

Date: ________

First, the caller establishes contact with the person who completes the SOII and makes sure it’s a good time to conduct the interview using the telephone solicitation script.

Thank you for agreeing to participate in the BLS study of workplace injury and illness processing. Our goal is to learn more about how companies handle recordkeeping for the OSHA Log and the BLS Survey of Injuries and Illnesses, as well as WC claims, since sometimes these are different things.

Everything we discuss today is strictly confidential and your participation is voluntary. If at any point you don’t understand a question, feel free to ask for clarification. Do you have any questions for me before we get started?

COMPANY

Ok, first I have a few questions about the company:

1. The unit we selected for this survey is (unit description and/or address). We show the (2011/2012) annual average employment of this unit as (employment). Does that sound about right? Yes No, specify:

2. Are the employees all located at (sampled unit description/address) or does the employment number cover other locations? (unit description/addresses) GO TO Q4 Other/multiple locations

3. IF OTHER/MULTIPLE IN Q2: Can you tell me a little about the locations, including the approximate number of employees?

   Location	Number of employees	Description
   Selected unit description/address
   Additional location
   Additional location

4. Do you have additional locations in (state name)? Yes No

5. Do you have locations in other states? Yes No

6. Thinking about the employees at (sampled location), approximately what percent are full time? __________ Part-time? ________ DK Other, specify:

7. Does your company employ temporary workers through a temporary staffing agency? Yes No Not now, but has in past DK

   1. IF YES, Are they normally supervised by staff within the company? Yes No DK

8. Does your company lease employees? Yes No Not now, but has in past DK

   1. IF YES, Are they normally supervised by staff within the company? Yes No DK

9. Are any employees covered by a union or collective bargaining agreement? Yes No DK

   1. IF YES, approximately what percent of employees are covered? ____________

10. Does the company compete or apply for contracts or subcontracts? Yes No DK

1. [IF YES] Are any of the following injury or illness measures included in any bid submissions or applications for contracts/subcontracts?

OSHA total recordable injury rate or DART

WC experience factor

Other:_________________

No

DK

EMPLOYEE ROLES

Ok, thank you. Now, let’s move on to employees that deal with workplace injury and illness reporting, starting with your position:

11. First, I have a question about your role in workplace injury and illnesses reporting. Do you complete (or oversee the completion of) the:

    1. OSHA 300 log Yes No

    2. Workers compensation claims Yes No

    3. BLS survey of occupational injuries and illnesses Yes No

    4. Any other injury or illness recordkeeping Yes No

Specify: ___________________________________

12. Do other persons complete (or assist in completing) the:

    1. OSHA 300 log Yes No

    2. Workers compensation claims Yes No

    3. BLS survey of occupational injuries and illnesses Yes No

    4. Any other injury or illness recordkeeping Yes No

13. Who has primary responsibility for completing the OSHA 300 log?

Respondent

Other company safety and health employee, specify title: _______________

TPA, claims mgr

Other, specify: _________________________

1. Is that individual located at the (sampled location) work site? Yes No

14. Do employees dealing with injury and illness reporting received formal training on OSHA recordkeeping, such as classes, seminars, or on-line courses? Yes No (GO TO Q17) DK (GO TO Q17)

15. About how long ago did any employees receive OSHA recordkeeping training? Within the past 12 months 1-3 years ago 4-5 years ago More than 5 years ago? DK

16. Who conducts the OSHA recordkeeping training that your employees have attended? Company staff OSHA State/local government agency TPA/Insurance Company/Retro Trade association College/university Private company/consultant Other_________

INJURY REPORTING AND PROCESSING

Ok, thank you. Now I have a few questions on how your company keeps track of injuries:

17. When you are not participating in the BLS survey, do you keep an OSHA 300 log? Yes No DK

18. How do you track your workplace injuries and illnesses?

Paper/pencil

Electronic spreadsheet

Specialized injury software program

Other, specify: _________________________

None of above/don’t track

DK

19. IF INJURY SOFTWARE PROGRAM:

1. What injuries/illnesses are entered into the program? WC OSHA 300 Other __________________

2. Does the program determine when an injury/illness is recordable on the OSHA log? Yes No

3. IF YES, do you or anyone else ever override the program’s decision? Yes No

20. What type of workers’ compensation insurance does your company have? Self-insured with Third Party Administrator (SAIF/list other state funds) Private insurance co. Other _________

OSHA RECORDKEEPING

Thank you – I think we’ve covered everything for that area. Now I have a few questions about OSHA recordkeeping.

21. Are any of the following sources of information used to complete an OSHA 300 log entry?: company report completed by employee/supervisor WC report of accident or other claim information Doctor’s report Other, specify:

22. Are any of the following OSHA 300 log items provided by a TPA/WC manager or by using WC sources Date of injury Number of days away from work Injury type Worker name None

23. When are injuries/illnesses recorded on the OSHA 300 log? Within 1 day of injury Within 1 week of injury Within 1 month of injury End of year When claim decision is made Other, specify:

24. Who is involved in determining whether an injury or illness is OSHA-recordable? Respondent Supervisor Company risk management Insurer TPA Computing system Other, specify:

25. Now, I have a few questions on differences between the OSHA log and workers’ compensation reporting.

    1. Do you put any cases on the OSHA log that are not workers’ compensation claims? Yes No DK

       1. IF YES, can you give me an example of one case?

2. Would you ever have an accepted WC claim for your company that was not included on your OSHA 300 log? Yes No DK

   1. IF YES, can you give me an example of one case?

3. Do you include any cases denied by your workers’ compensation carrier on the OSHA 300 log? Yes No DK

   1. IF YES, can you give me an example of one case?

Now I have a few more questions on the OSHA log.

26. IF YES IN Q7, If a temporary worker hired through a temp-help agency was injured, would you include them on your OSHA 300 log? Yes No DK

27. IF YES IN Q8, would you include injuries of leased employees on your OSHA 300 log? Yes No DK

28. Do you ever go back and add cases to a previous year’s OSHA log? Yes No

    1. IF YES, can you give me one example of a case?

29. Do you ever go back and update the number of days on a previous year’s log? Y es No

    1. IF NO, why not?___________

30. Have you ever been notified of an injury or illness occurrence at your company at a much later date? Yes No

    1. IF YES, Was there a reason for the late notification? Yes No

    2. What was the reason for late notification?

SOII RECORDKEEPING

31. Now I have a few questions on the BLS Survey of Injuries and Illnesses. Was (SURVEY YEAR) the first time you’ve personally completed the BLS Survey of Occupational Injuries and Illnesses? Yes No Did not complete SOII

32. IF MULTI-UNIT: Are you responsible for completing the survey for any other company location? Yes No

33. Which injuries and illnesses do you include in the BLS survey?

All injuries

All claims

All medical visits

Follow OSHA criteria

Computer software decides

Other, specify

34. Which of the following sources of information are used to complete the BLS Survey?

OSHA 300 log OSHA 301 form Company report completed by employee/supervisor WC report of accident or other claim information Other source, specify: _____________

35. Have you ever had an injury and illness case that occurred during the BLS survey timeframe that was unknown to you until after you have sent in the survey? Yes No

    1. Can you give me one example? _____________

36. Have you used any of the following recordkeeping resources or contacts? OSHA contact OSHA recording keeping website BLS contact BLS survey hotline other, specify:_____________

    1. Was it helpful? Yes No other, specify:_____________

WORKPLACE PRACTICES AND RECORDING QUESTIONS

37. Now I have a few questions on your company’s workplace performance practices. Does your company use any incentives or reward programs to promote employee safety? Yes No DK

1. IF YES, what workplace injury and illness counts or rates are used to measure performance?

OSHA recordable cases WC claim any injury Hazard identification/mitigation Other, specify:

38. Are workplace injury and illness rates included as a measure of performance in:

1. Your performance reviews or evaluations Yes No DK

   1. [IF YES] Is performance based on:

OSHA recordable cases WC claims (TL cases, claim $, exp. factor) Other:________

2. Frontline supervisor performance reviews or evaluations? Yes No DK

   1. [IF YES] Is performance based on:

OSHA recordable cases WC claims (TL cases, claim $, exp. factor) Other:________

3. IF MULTI-UNIT: Are they used to evaluate individual worksites or compare them to each other? Yes No DK

   1. [IF YES] Are worksites compared using:

OSHA recordable cases WC claims (TL cases, claim $, exp. factor) Other: ___________

39. Does your establishment have a policy or practice of disciplining employees for certain unsafe practices (for example, not wearing protective gear or not notifying management of near-miss incidents?) Yes No DK

40. Does your establishment have a policy or practice of testing employees for alcohol or drugs after their involvement in injury-causing incidents (aside from any driving accidents, as required by law)? Yes No DK

41. Ok, here are a few hypothetical cases to think about. This is not a test! We just want to see the different decisions made in recording cases on the OSHA 300 log.

    1. An employee cut his arm at work on Friday. His doctor recommended he take two days off from work. He was not scheduled to work the weekend, and he returned to work on Monday.

Would you record this on the OSHA log? Yes No DK

IF YES, would you record any days away from work? Yes No DK

IF YES, How many? _______

2. A worker was engaged in horseplay at work while stacking some boxes and fell, resulting in days away from work. A month later, the workers’ compensation claim was denied.

Would you record this on the OSHA log? Yes No DK

3. A worker cut her thumb and had stitches, but did not miss any time away from work.

Would you record this on the OSHA log? Yes No DK

4. A week later, the same worker ended up missing 7 days when the thumb became infected. Would you? Record as new injury Update old injury Not record DK

5. An employee injured his ribs at work, and went to have an X-ray. The rib was not broken.

Would you record this on the OSHA log? Yes No DK

Ok, I think that covers it. Thank you so much for your time. Do you have any questions? We will process your responses within the next ### days and if we have any questions, we might call you back briefly for a clarification.