Note to Reviewer - SOII Recontact Survey

September 9, 2014

NOTE TO THE REVIEWER OF:	OMB CLEARANCE 1220-0141
FROM:	Robin Kaplan Research Statistician Polly Phipps Senior Survey Methodologist Office of Survey Methods Research

SUBJECT: Submission of materials for cognitive pre-testing of a survey on record-keeping practices in the Survey of Occupational Injuries and Illnesses (SOII)

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.

We will be conducting in-person and phone interviews with establishment respondents who completed the 2013 SOII. These interviews are being undertaken to explore how establishments handle “late cases” in the SOII. These include injuries and illnesses that occur late in the calendar year, cases reported or discovered after the establishment has responded to the SOII, and injuries or illnesses that are initially not recordable but become recordable at a later date.

We plan to interview respondents from 25 establishments. The BLS estimates that the total burden will be 26.7 hours.

If there are any questions regarding this project, please contact Robin Kaplan at (202) 691-7378 or Polly Phipps at (202) 691-7513.

Cognitive Pre-Testing to Explore Late Cases in the Survey of Occupational Injuries and Illnesses (SOII)

I. Background and Purpose

The Survey of Occupational Injuries and Illnesses (SOII) is a mandatory establishment survey conducted by the Bureau of Labor Statistics (BLS) that generates annual estimates of the number and rate of nonfatal workplace injuries and illnesses. Under the Occupational Safety and Health Act (OSH) of 1970, most employers are required to keep a log (the OSHA 300 log) of injuries and illnesses that occur throughout the year.

Recent studies by outside researchers have pointed to an undercount in the number of workplace injuries and illnesses reported to SOII by employers. In its continuing effort to understand more about a potential undercount of injuries and illnesses and to identify steps that can be undertaken to improve SOII data collection, BLS would like to explore possible reasons for this potential undercount by interviewing establishments who completed the 2013 SOII.

We plan to interview 2013 SOII respondents on timing issues, or “late cases” in the SOII. Potential issues related to undercount include injuries and illnesses that occur late in the calendar year, cases reported or discovered after the establishment has responded to the SOII, and injuries or illnesses that are initially not recordable but become recordable at a later date. For example, results from past BLS undercount research indicates that injuries and illnesses occurring late in the calendar year may not be added to an employer’s OSHA 300 log before SOII data collection occurs early in the following calendar year. Therefore, SOII would not capture these injuries and illnesses during the course of regular data collection. In addition to late cases, a number of other factors may contribute indirectly at the undercount, such as recordkeeping practices, knowledge of OSHA recordkeeping rules, use of temporary help workers, and other establishment characteristics. Thus, we will also ask questions about these topics and other issues related to the undercount.

The results of this research will help to refine how to ask questions about late cases and determine how establishments handle them in terms of recordkeeping. We are also interested in testing respondent understanding and recall on whether any of these types of late cases occurred during the 2013 collection period specifically, to assess whether it might be possible to determine the extent to which late cases contribute to a potential undercount during a specific reference period.

The larger goal of this study is to use the results of the cognitive testing to develop a survey instrument that can be used with a larger sample of employers to investigate reasons for and the scope of underreporting due to such late cases (this larger study would be conducted in 2015). If the results of this project indicate that respondents add or update information after SOII data collection, BLS could evaluate changes to future SOII data collection processes that would improve the accuracy of the SOII estimates. 

II. Methodology

The proposed study will be conducted using 5 in-person interviews for pre-testing and information-gathering purposes, followed by 20 telephone interviews. SOII respondents in the Washington D.C. area will be selected into the study based on industry, employment size, and multi-establishment status.

• Size (Small = 1-10, 11-49; Medium/Large = 50-249, 250+)

• Industry (construction; manufacturing; 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

• Non-exempt industries (11 or more employees, industries shaded below).

Establishment industry	Employment size	Multi-establishment status
Construction	1 small; 2 medium-large	1 multi; 1 non-multi
Manufacturing	1 small; 2 medium-large	1 multi; 1 non-multi
Trade, transportation, and utilities	1 small; 2 medium-large	1 multi; 1 non-multi
Information	1 small; 1 medium-large	1 multi; 1 non-multi
Financial activities	1 small; 1 medium-large	1 multi; 1 non-multi
Professional and business services	1 small; 1 medium-large	1 multi; 1 non-multi
Education and health services	1 small; 2 medium-large	1 multi; 1 non-multi
Leisure and hospitality	1 small; 2 medium-large	1 multi; 1 non-multi
Other services, except public administration	1 small; 1 medium-large	1 multi; 1 non-multi
Public administration	1 small; 1 medium-large
Total = 10 industry groups	Total = 25 establishments sampled

The instrument (Attachment 1) has been designed to question respondents about general company background, their background and role as respondent, as well as the following subject areas:

• The types of information, forms, and records that are used when reporting injuries and illnesses,

• Characteristics of the establishment that might be correlated to record-keeping practices and undercount issues, including the use of temporary help workers, recordkeeping knowledge and training, reliance on workers compensation records to complete the OSHA 300 logs,

• General estimates of the frequency of late cases that occur due to:

  • Timing (e.g., injuries reported too late to include in the SOII, or injuries that occurred late in the calendar year)

  • Type of injury (e.g., those with a delayed onset, injuries that worsened over time and became recordable at a later date)

  • Recordkeeping practices (e.g., company does not routinely update the logs, company waits until workers comp claims are accepted to record cases, extent of respondent’s recordkeeping knowledge)

• Specific estimates of the frequency of late cases, as they occurred in the 2013 SOII reporting year, and

• Hypothetical vignettes aimed to assess the respondents’ understanding of recordkeeping practices that are related to undercount and late cases.

Attachment 1 includes the interview protocol and examples of the types of questions we will ask respondents. Respondents will be recruited by telephone (see Attachment 2). Respondents agreeing to in-person interviews will be asked at the time of visit whether taping is acceptable, following the protocol in Attachment 3.

III. Burden Hours

We expect that the in-person interviews will take approximately 60 minutes and the telephone interviews 40 minutes (5 X 60 minutes, and 20 interviews X 40 minutes). We expect recruitment to take approximately 10 minutes, with up 50 establishments contacted. Total burden is 26.7.

Establishments contacted	50
Total Recruitment Minutes (10 minutes x 50 contacts)	500 minutes
Establishments interviewed in-person (60 minutes each)	5
Establishments interviewed by phone (40 minutes each)	20
Total Interviewing Minutes in-person	300 minutes
Total Interviewing Minutes by phone	800 minutes
Total Minutes	1600
Total burden hours	26.7

IV. Payment

Participants will not receive payment for this study.

V. Confidentiality

For face-to-face interviews, participants will be asked to sign a consent form (Attachment 4).

For telephone interviews, the following Privacy Act statement and confidentiality assurance will be relayed to the respondent during recruitment as well as in the introduction script at the beginning of the interview. Respondents will be informed the interview is voluntary and the information collected will be used for internal research purposes only.

“Your voluntary participation is requested to help BLS understand business records and their use in designing a more effective long-term approach to collecting and publishing these new data types. The purpose of this call is for internal purposes only. Information related to this study is confidential and will not be released to the public in any way that would allow identification of individuals or establishments. 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.”

V. Attachments

1. Draft employer protocol/instrument

2. Solicitation protocol

3. Personal interview taping protocol

4. Consent Form

Attachment 1. Employer Interview Protocol

Introduction

Thank you for agreeing to participate in our study of workplace injury and illness recordkeeping. We are talking with people about how companies gather, record, and use information about workplace injuries and illnesses. We will start out by discussing your company’s general recordkeeping practices, and then ask some questions specifically about recordkeeping during the 2013 calendar year and the 2013 BLS Survey of Occupational Injuries and Illnesses (SOII).

We will use the information you provide us to improve the BLS survey. The information you provide us today is very important. As mentioned previously, everything we discuss today is strictly confidential and your participation is voluntary. This survey is being conducted under OMB Control Number 1220-0141. 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?

Background and Company Demographics

First, I’d like to get a little background on the company. What does (Company Name) do/make exactly? About how many workers are employed at your company?

Employee roles

We are interested in how your company records information about workplace injuries and illnesses.

1. Can you tell me about who has primary responsibility for workplace injury and illness

reporting in your company?

• Respondent

• Other company safety and health employee, specify: __________

• TPA, other external claims manager

• Other, specify: ____________

2. Who typically completes or assists with recording and completing the OSHA 300 log and the BLS Survey of Occupational Illnesses and Injuries?

   • Respondent

   • Other company safety and health employee, specify: __________

   • TPA, other external claims manager

   • Other, specify: ____________

3. Did your company keep an OSHA 300 log during 2013?

   • Yes

   • No

   • DK

4. Was 2013 the first time (you’ve personally/other person) completed the BLS Survey of Occupational Injuries and Illnesses?

   • Yes

   • No

   • Did not complete SOII

   • DK

   • Other, specify: _______________

5. When your company is NOT participating in the BLS survey, do you keep an OSHA 300 log?

   • Yes

   • No

   • DK

6. Does a Third Party Administrator assist with your company’s workers’ compensation claims management?

   • Yes

   • No

   • DK

7. Is your company self-insured for workers’ compensation claims/insurance?

   • Yes

   • No

   • DK

Now we have some general questions about OSHA 300 recordkeeping

8. When an injury or illness occurs, how do you determine whether to record the incident on your OSHA 300 log? (Clarify if necessary: the final/official log).

Specify: ___________________

• All injuries (would that include injuries and illnesses where the worker does not go to the doctor? Cases that do not end up as a WC claim?)

• All filed WC claims

• All accepted WC claims

• All injuries and illnesses that require medical treatment (clarify: does that include cases that do not end up as a WC claim?)

• Follow OSHA criteria

• Computer software decides

• Other, specify: _________________

9. Where does your company get the information needed to complete the OSHA 300 log?

   • Company report completed by the employee/supervisor

   • WC report of accident or other claim/insurer information (including info from TPA)—

   • Doctor’s report

   • Other, specify:_________________

10. Does your company get information for the OSHA 300 log from Worker’s Comp records?

    • Yes

    • No

1. (If yes), what information is provided?

• Date of injury

• Number of days away from work

• Injury type

• Worker name

• Injury location

• Treatment location

• None

2. (If no), where does your company get this information?

Specify: ________________

11. In general, how long after an injury or illness is reported to your company does it get recorded on the OSHA 300 log?

    • Within 1 day

    • Within 1 week

    • Within 1 month

    • End of year

    • When claim decision is made

    • When claim is filed

    • Other, specify: __________________

12. Where does your company usually get the number of days away from work for the OSHA 300 log?

    • Payroll data

    • WC Time loss data

    • Calendar (paper or computer)

    • Supervisor

    • Other, specify: __________________

1. Does the number of days away from work include all calendar days or is it limited to days of missed work or scheduled shifts?

• Calendar days

• Scheduled shifts/days

• DK

• Other, specify: __________________

Now I have a few questions about OSHA 300 recordkeeping and worker’s compensation reporting.

In general, how frequently would you say your company encounters the following situations? Have you:

	Almost never	Rarely	Sometimes	Often
Recorded case(s) on the OSHA 300 log that were not workers’ compensation claims
Recorded cases on the OSHA 300 log that were denied workers’ compensation benefits
Accepted workers’ compensation cases that were not included on the OSHA 300 log
Added cases to a previous year’s OSHA 300 log

Now we have some general questions about recordkeeping practices for the BLS Survey (SOII) at your company.

Since the BLS survey covers a calendar year, there are a number of common reasons we don’t capture all of the injury and illness cases on the survey. We’ve identified a number of these reasons for these “late cases” by talking to other companies. We were wondering whether any of these types of timing issues have happened at your company as well.

13. Has your company found out about an injury or illness too late to include in the BLS survey?

    • Yes

    • No

1. Can you tell me about that?

2. (If yes) How frequently would you say this happens?

• Never

• Rarely

• Sometimes

• Often

14. Do you update these “late cases” in the OSHA logs?

• Yes

• No

• DK

15. If yes, what do you update in your OSHA logs? (Check all that apply)

• Injury and illness descriptions

• Information about an injury

• Number of days away from work

• Case classification like from Job transfer to Days away from work

• Case classification like a change from medical only to time loss

• Worker’s comp claim successfully protested

16. Does your company ever experience any difficulties in updating or adding late cases? If so, what are they?

2013-specific questions

Now we are interested in learning about the process in which your company handled submitting the 2013 BLS Survey of Occupational Injuries and Illnesses. All questions will apply to injury and illnesses that occurred during the 2013 calendar year.

Our records indicate your company submitted the BLS survey on [2014 DATE SUBMITTED]. I just asked you some questions earlier about how your company handles “late cases” in general. Now, we are interested in knowing whether any of these things happened during the 2013 calendar year. Please note that you would have received this survey in January 2014.

17. During the 2013 calendar year, was your company notified of any injuries or illnesses that were reported too late to include in the BLS survey?

    • Yes

    • No

1. (If yes) Do you know how many? __________

18. As mentioned, sometimes late cases occur during to the timing of the injury. Did any of the following timing issues happen during the 2013 calendar year?

	Yes	(if yes) How many?	No
An injury occurred late in the 2013 calendar year
The onset of an injury was determined to be during the 2013, after you submitted the BLS
An employee delayed in reporting the injury, after you submitted the BLS survey
An employee filed a claim for 2013 after separating from your company

19. Sometimes late cases occur due to the nature of the injury. Did any of the following happen at your company during the 2013 calendar year?

	Yes	(if yes) How many?	No
The status of an injury changed after you submitted the 2013 BLS survey due to cumulative or recurring injury (probe for: CTS, hearing loss, soft tissue injuries, sprains/strains, and other injuries with a long latency period)
An old injury worsened, and an old case became recordable during the 2013 calendar year

20. A final reason late cases occur is due to recordkeeping. Were any cases left off the 2013 BLS Survey for the following reasons during the 2013 calendar year?

	Yes	(if yes) How many?	No
A case was pending WC at the time of submitting the 2013 BLS survey and was not included
An old claim got accepted for WC after submitting the 2013 BLS survey
The person in charge of recordkeeping changed during the 2013 calendar year
An error occurred in recordkeeping

21. During the 2013 calendar year, did your company…

	Yes	No	Example?
Update the number of days away from work on a previous year’s log?
Cross-check to see whether workers’ compensation claims were also included on the 2013 OSHA 300 log?
Receive workers’ compensation claims filed after the close of the BLS survey?

22. Focusing on the time interval from when you submitted the BLS Survey on [2014 date], and the time BLS received it [2014 date]… Were there any other changes to the information submitted in the 2013 BLS Survey that you can think of?

Recordkeeping vignettes

Now we have some questions about different hypothetical scenarios about recordkeeping. We are not evaluating you or your company. These questions are just meant to get your honest feedback regarding what recordkeeping decisions you think your company might make in the following situations.

23. Let’s say an employee sprained his ankle at work on Friday. His doctor recommended he take 2 days off from work. He was not scheduled to work on the weekend, and he returned to work on Monday.

1. Would your company consider this an OSHA-recordable injury?

• Yes

• No

• DK

2. (If yes) would you record any days away from work?

   • Yes

   • No

   • DK

3. (if yes) How many? _____

24. Let’s say an employee cut her thumb and had stitches in December. Her thumb became infected in January, resulting in days away from work, after your company already submitted the BLS survey. Do you think your company would…

    • Record this as a new injury

    • Update the old injury

    • Not record

    • DK

    • Other, specify: ________

Now we have some more general questions about record-keeping in your company

25. Have/has (you/person with primary responsibility from 5) received formal training on OSHA recordkeeping, such as classes, seminars, or online courses?

    • Yes

    • No

    • DK

26. [If yes] When did (you/person with primary responsibility from 5) last receive formal OSHA recordkeeping training? ______

    • Within the past 12 months

    • 1-3 years ago

    • 4-5 years ago

    • More than 5 years ago

    • DK

Now we just have a couple final questions about your company before we finish up.

27. Does your company use temporary workers hired through a temp help agency?

    • Yes

    • No

    • Not now, but in the past

    • DK

1. (If yes) Did you include any temporary help workers’ injuries or illnesses on the OSHA 300 log during the 2013 calendar year?

   • Yes (If yes, how many?)

   • No

   • DK

2. Did you include any temporary help agency workers’ injuries or illnesses on the BLS Survey?

   • Yes (If yes, how many?)

   • No

   • DK

28. Are any workers in your company covered by a union or collective bargaining agreement?

    • Yes

    • No

    • DK

Debriefing questions:

• Do you have any general thoughts or comments about this survey, the SOII, or injury and illness recordkeeping?

Attachment 2. Telephone Solicitation Protocol

1. Call person completing the SOII survey for the 2013 reference year.

2. Hello, my name is (NAME). I am calling for the U.S. Department of Labor, Bureau of Labor Statistics. Is (INITIAL CONTACT NAME) there? Our records show that you are the person that completed the 2013 Survey of Occupational Injures and Illnesses. Are you the person who prepares this report?

 YES

 NO

The Bureau of Labor Statistics is conducting a study to better understand workplace injury and illness recordkeeping. We need your help to make our data better. We are interested in talking to you about your experiences with the BLS survey, your company’s general recordkeeping practices, as well as some of your recordkeeping specifically during the 2013 calendar year. As such, it would be helpful if you could consult your OSHA 300 log and Worker’s Compensation logs from the year 2013, during our interview, if available.

I realize you are probably very busy, but would you have a little time in the next month to assist us with this study? It would be very valuable to us if we could [meet in person/talk on the phone] with you. We estimate it will take you an average of 40 minutes to participate in this research.

As you may know, the Bureau of Labor Statistics is an independent statistical agency and 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 (Title 5 of Public Law 107-347), the information you provide to the BLS will not be disclosed in identifiable form without your informed consent.

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. Without this currently-approved number, we could not conduct this survey. (Expiration: February 28, 2015). 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.

3. IF RESPONDENT AGREES:

• Two people from our research team will [travel to your establishment to talk with you / call you over the telephone]. Which day between [date] and [date] would be best for you?

APPT DAY: ____________________________________________

• What might be the best time of day for our [in-person visit / phone call]?

APPT TIME: _______________________(about 40 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.

• [If in-person] Confirm mailing address and tell respondent we will send a letter describing more about our meeting. 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.

Recruitment Appointment Reminder Call or Email

Call establishment two or three days before the scheduled interview to remind them of the following:

• interview time and date

• let them know who will be there from BLS

• Give them the appropriate phone # for BLS staff in case there is a last minute problem.

Attachment 3. Personal Visit Interviews

Taping Statement and Consent Form

Anonymity and Taping

With your permission, we would like to audiotape our discussions. We like to use a recorder so we can refer back to it while report writing. Would you mind if we tape this session?

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. Your participation is voluntary, and you can decline to answer any questions. A standard procedure in this kind of interview is to obtain your written consent to participate. Here is a consent form and statement that tells you more about your rights as a participant. Please sign both copies and keep one for yourself.

U.S. Department of Labor

Bureau of Labor Statistics 2 Massachusetts Avenue, NE, Room 1950 Washington, DC 20212

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. The Privacy Act notice on the back of this form describes the conditions under which information related to this study will be used by BLS employees and agents.

During this research you may be audio and/or videotaped, or you may be observed. If you do not wish to be taped, you still may participate in this research.

We estimate it will take you an average of 60 minutes to participate in this study.

Your participation in this research project is voluntary, and you have the right to stop at any time. If you agree to participate, please sign below.

Persons are not required to respond to the collection of information unless it displays a currently valid OMB control number. OMB control number is 1220-0141, and expires February 28, 2015.

------------------------------------------------------------------------------------------------------------

I have read and understand the statements above. I consent to participate in this study.

___________________________________ ___________________________

Participant's signature Date

___________________________________

Participant's printed name

___________________________________

Researcher's signature

OMB Control Number: 1220-0141

Expiration Date: February 28, 2015

PRIVACY ACT STATEMENT

In accordance with the Privacy Act of 1974, as amended (5 U.S.C. 552a), you are hereby notified that this study is sponsored by the U.S. Department of Labor, Bureau of Labor Statistics (BLS), under authority of 29 U.S.C. 2. Your voluntary participation is important to the success of this study and will enable the BLS to better understand the behavioral and psychological processes of individuals, as they reflect on the accuracy of BLS information collections. 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.