OSHA Instruction STP 2.12B May 4, 1992 Office of State Programs

Subject: State Program Requirements for Statistical Information on the Incidence of Occupational Injuries and Illnesses by Industry; on the Injured or Ill Worker; and on the Circumstances of the Injuries or Illnesses

A. PURPOSE. This instruction sets out criteria for State statistical reporting systems as required by 29 CFR 1902.3(k) and (l).

B. SCOPE. This instruction applies to all States with plans approved under Section 18 of the Occupational Safety and Health Act.

C. CANCELLATION. OSHA Instruction STP 2.12A, September 14, 1979, is canceled.

D. ACTION. The Regional Administrators shall immediately provide copies of this directive to the designated State agencies in their regions and ensure that States follow the procedures set out below.

E. EXPLANATION. This instruction replaces STP 2.12A, to reflect changes in the BLS Statistical program as a result of the Redesigned Occupational Safety and Health Survey (ROSH). State programs must also incorporate the changes made by ROSH. States are expected to complete information on calendar year 1991 in accordance with the previous instruction.

F. PROCEDURES.

1. Any State actively and satisfactorily participating in the BLS sponsored redesigned annual survey of occupational injuries and illnesses and the BLS Census of Fatal Occupational Injuries shall be considered to be meeting the requirements of 29 CFR 1902.3(k) and (l).

2. Any State which chooses not to participate in the BLS sponsored redesigned annual survey of occupational injuries and illnesses and the BLS Census of Fatal Occupational Injuries shall notify the Regional Administrator and submit a plan change describing its alternative system. Any alternative system must be approved by both OSHA and BLS prior to the discontinuance of participation in the BLS survey and implementation of the alternative. An alternative system must provide for reports (consistent with the BLS schedule for publication) on: (1) the incidence of OSHA recordable injuries and illnesses by industry, classified in accordance with the Standard Industrial Classification (SIC) Manual currently in use by BLS, to the three digit level in nonmanufacturing and four digits in manufacturing for industries which are numerically important; (2) the characteristics of the injured and ill workers which are collected in the BLS program (including the industry, occupation, age, sex, and tenure); (3) the circumstances of the event (nature of the injury/illness, part of body affected, primary and secondary sources, and event or exposure coded to the most current standardized codes established by the BLS); and (4) the number of days away from work and number of days of restricted activity classified by worker characteristic and case circumstances. These reports shall:

a. Have private employee and industrial coverage identical to the BLS statistical program plus complete public sector (State and local government) coverage.

b. Be based upon a statistical data collection system that meets BLS' tests for completeness, validity, reliability and proper use of statistical techniques. (BLS will advise OSHA and the State participants of the adequacy of the State data collection system.)

c. Present all data elements and estimates associated with those elements using table formats identical to those required by BLS. (See the BLS Redesigned Occupational Safety and Health (ROSH) Survey Operating Manual, and the BLS Census of Fatal Occupational Injuries State Operating Manual.) Each of these data elements must be in accordance with the definitions found in Title 29 part 1904 of the Code of Federal Regulations, the BLS survey form, and the BLS operating manuals referenced here, as well as OSHA recordkeeping guidelines and instructions.

d. Include industry employment hours worked.

e. Have absolute values and incidence rates as defined in the BLS manuals, referenced in (c) above.

f. Meet other requirements which may be necessary to generate State data comparable to National and State estimates produced by the BLS. States choosing not to participate in the BLS program will not be subject to requirements that are more stringent than those of BLS. (For more complete information concerning the above, see the BLS manuals referenced in (c) above.)

G. BACKGROUND. Section 18(c)(7) of the Act and 29 CFR 1902.3(k) and (l) require States implementing their own occupational safety and health plans to ensure that employers covered by the plan will maintain records and make reports to the Assistant Secretary in the same manner and to the same extent as if the plan were not in effect and to provide reports containing statistical information pertaining to work-related deaths, injuries and illnesses. In addition, States are required by section 18(c)(8) of the Act and 29 CFR 1902.3(l) to provide reports necessary for the evaluation of the effectiveness of individual State programs as compared to the Federal program. States must provide statistical data on injuries and illnesses at the State level for the purposes of State plan evaluation.

While States are not required to participate in the BLS survey, they must provide uniform data concerning the incidence of injuries and illnesses as set out in section F, above. Experience has shown that it is very difficult for States to develop and implement their own statistical reporting systems on injuries and illnesses which meet all the guidelines in section F. Although participation in the BLS survey is not required, it has proved to be the most feasible option.

Dorothy L. Strunk Acting Assistant Secretary

Distribution: National and Regional Offices State Designees 18(b) State Monitors