Occupational injury recordkeeping among BLS sampled establishments and implications for national surveillance

According to multiple studies, Bureau of Labor Statistics (BLS) non-fatal occupational injury and illness data fail to include eligible cases identified in other data sources. To identify possible explanations for BLS's incomplete case capture, we interviewed Washington State respondents to the 2008 BLS Survey of Occupational Injuries and Illnesses (SOII). Topics covered during the semi-structured in-person interview included: knowledge of OSHA recordkeeping requirements; data sources used to complete the SOII; and company use of injury and illness data. Respondents were selected for participation based on employer size, industry, number of business locations within the state, and completeness of injury reporting based on a record match of SOII and WA WC data. We conducted 113 interviews in 2011. Knowledge of OSHA recordkeeping regulations ranged from low, generally among smaller establishments and those partially exempt from OSHA recordkeeping requirements, to a detailed understanding among larger manufacturing and construction establishments. Respondents with less OSHA recordkeeping knowledge were more likely to rely on WC claims data to complete the BLS survey (p<0.001). We found no association between incomplete injury reporting and OSHA recordkeeping knowledge or use of WC data for SOII. Establishments with incomplete injury reporting were more likely to use occupational injury and illness data as a measure of individual job performance (p=0.002). Performance incentives tied to company injury and illness data explains a portion of the incomplete case capture; disorganized recordkeeping and lax participation in the BLS survey likely contribute to inaccuracies in the BLS occupational injury and illness surveillance data.