Workplace Safety and Health: Actions Needed to Improve Reporting of Summary Injury and Illness Data

GAO-21-122 Published: Jan 27, 2021. Publicly Released: Feb 18, 2021.
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Fast Facts

About 3.5 million workers suffered job-related injuries and illnesses in 2018. Employers must report data on work-related injuries and illnesses to the Occupational Safety and Health Administration each year. OSHA uses the data to target high-risk workplaces for inspections.

But employers did not report data for more than 50% of workplaces that met the reporting criteria, so OSHA may not know which have the highest injury and illness rates. OSHA hasn't evaluated the effectiveness of its procedures to encourage and enforce compliance with reporting requirements and lacks a plan to correct deficiencies. We recommended that OSHA address this.

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What GAO Found

GAO's analysis of Occupational Safety and Health Administration (OSHA) data showed that the number of recordkeeping violations OSHA cited fluctuated over 15 years (see fig.). An April 2012 federal court decision (that effectively limited the time period for citing these violations) and a January 2015 expansion of OSHA's rule for reporting severe injuries and illnesses coincided with, and were cited by, OSHA staff as key factors explaining these fluctuations.

Number Recordkeeping Violations OSHA Cited by Fiscal Year

Number Recordkeeping Violations OSHA Cited by Fiscal Year

Employers did not report any summary injury and illness data on more than one-half of their establishments that GAO estimated met the reporting requirements (see table).

Estimated Compliance with Summary Injury and Illness Reporting Requirement

Calendar year Estimated establishments that met summary injury and illness reporting requirements Establishments whose employers submitted summary injury and illness data
    Number Percent
2016 451,000 159,000 35%
2017 454,000 189,000 42%
2018 459,000 212,000 46%

Source: GAO analysis of U.S. Census Bureau County Business Patterns data and Occupational Safety and Health Administration (OSHA) summary (300A) injury and illness data. Establishments in all 50 states and the District of Columbia reported these data. Data rounded to the nearest thousand. | GAO-21-122

OSHA has limited procedures for encouraging compliance with this reporting requirement and for penalizing non-compliance. For example, OSHA officials told GAO that they identified nearly 220,000 employers in 2019 who may not have reported their data and mailed reminder postcards to about 27,000 of them. OSHA also cited 255 employers for failure to report their data from mid-December 2017 through September 2019 after OSHA conducted on-site inspections. OSHA uses the summary injury and illness data to target high-risk establishments for certain comprehensive inspections. Because OSHA has not evaluated its procedures, it does not know the extent to which its efforts may be improving injury and illness reporting or what other efforts it should undertake. Absent more complete information, OSHA is at risk for not achieving its objective of targeting inspections to establishments with the highest injury and illness rates.

Why GAO Did This Study

In 2018, about 3.5 million workers suffered job-related injuries, and illnesses and 5,250 died on the job, according to Bureau of Labor Statistics data. Employers are required to record work-related injuries and illnesses, promptly report severe injury and illness incidents to OSHA, and certain employers are required to report summary injury and illness data electronically on an annual basis. GAO was asked to review how OSHA addresses recordkeeping violations, and implements its rule for reporting summary data.

This report examines: (1) how and why recordkeeping violations changed from fiscal years 2005 through 2019 and (2) the extent to which employers report summary injury and illness data and OSHA has taken steps to ensure compliance with this requirement.

GAO analyzed 15 years of OSHA recordkeeping violation data and compared OSHA and Census data to estimate how many employers complied with summary reporting requirements. GAO also reviewed agency procedures and relevant federal laws and regulations and interviewed OSHA headquarters officials and staff at seven OSHA area offices, selected for geographic dispersion and varying amounts of recordkeeping violations.

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GAO recommends OSHA evaluate procedures for ensuring reporting of summary data and develop a plan to remediate deficiencies. OSHA generally concurred with our recommendation.

Recommendations for Executive Action

Agency Affected Recommendation Status
Occupational Safety and Health Administration
Priority Rec.
This is a priority recommendation.
The Secretary of Labor should evaluate OSHA's current procedures for ensuring that employers electronically report their annual 300A injury and illness data to OSHA when required and implement a plan to remediate identified deficiencies. This should include its efforts related to: (1) encouraging employers to comply with the 300A reporting requirement; and (2) citing employers for non-compliance with this reporting requirement. (Recommendation 1)
OSHA generally agreed with this recommendation. The agency is currently reviewing how it encourages employers required to submit 300A data to do so and how it addresses non-compliance. This includes evaluating the use of postcards to encourage potentially non-compliant employers to submit their data and reviewing the effectiveness of the on-line tools it uses to publicize this reporting requirement within its regulatory community. As of March 2022. the agency was also developing a computer match to better identify employers who are not complying with this reporting requirement for enforcement action during OSHA's regular inspection process. It does not include, however, developing such actions outside of the regular inspection process. We will close this recommendation when OSHA has evaluated and developed plans to: 1) better encourage employers required to submit this data to do so and 2) more fully take enforcement action against employers who are required to submit this data, but do not.

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