Attachment 1 Procedures_Manual_CY07.pdf

VERSION

13.0

Log Data Collection Initiative

PROCEDURES MANUAL

2007 Log Data Collection

May 2008 U.S. Department of Labor Occupational Safety and Health Administration Office of Statistical Analysis

May 2008 OSHA Log Data Collection Initiative

Procedures Manual i

PHONE, FAX, and E-MAIL DIRECTORY

POLICY/FINANCIAL ISSUES

Phone Fax E-mail

OSHA Joe DuBois 202-693-1875 202-693-1631 dubois.joe@dol.gov

Dave Schmidt 202-693-1886 202-693-1631 schmidt.dave@dol.gov

Ethel Jackson 202-693-1871 202-693-1631 jackson.ethel@dol.gov

RECORDKEEPING ISSUES

Phone Fax E-mail

OSHA Dave Schmidt 202-693-1886 202-693-1631 schmidt.dave@dol.gov

TECHNICAL ISSUES

Phone Fax E-mail

ERG Log Data Helpline 603-595-1615 603-594-0170 603-594-0571 logdata@erg.com

Meg Vrablik 603-595-4480, Ext.: 625

603-594-0170 603-594-0571 meg.vrablik@erg.com

Karen Boisjoly 603-595-4480, Ext.: 637

603-594-0170 603-594-0571 karen.boisjoly@erg.com

Marie Jorgensen 603-595-4480, Ext.: 636

603-594-0170 603-594-0571 marie.jorgensen@erg.com

OSHA Log Data Collection Initiative May 2008 ii Procedures Manual

LOG DATA COLLECTION SUPPLIES

Phone Fax Email

OSHA Shirley Lashley 202-693-1878 202-693-1631 lashley.shirley@dol.gov

Alabama Connecticut Delaware Georgia Kentucky Maine Maryland Massachusetts Mississippi New Jersey North Carolina Tennessee Vermont Virginia West Virginia

Linda Townsend 202-693-1885 202-693-1631 townsend.linda@dol.gov

Arizona Arkansas California Hawaii Indiana Iowa Kansas Louisiana Michigan Minnesota Missouri Nevada New Mexico Oklahoma Texas Utah Washington Wisconsin

Procedures Manual iii

TABLE OF CONTENTS

SECTION 1 INTRODUCTION

1.1 OVERVIEW OF THE LOG DATA COLLECTION INITIATIVE . . . . . . . . . . . . . . . . . 1-1

Why Will OSHA Collect These Data? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 Who Will Collect These Data? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 Who Will Provide These Data? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-3

1.2 OVERVIEW OF DATA COLLECTION PROCEDURES . . . . . . . . . . . . . . . . . . . . . . . . 1-5

Collecting State’s Role . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-5 OSHA’s Role . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-6

SECTION 2 THE OSHA DATA COLLECTION FORM

2.1 OVERVIEW OF THE OSHA DATA COLLECTION . . . . . . . . . . . . . . . . . . . . . . . . . 2-1

Establishments on Both the BLS List and the OSHA List Identified as Overlap Establishments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2 Establishments on the OSHA List but Not on the BLS List . . . . . . . . . . . . . . . 2-2 Establishments on Both the OSHA List and the BLS List but Not Identified as Overlap Establishments . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2

2.2 CONTENTS OF THE DATA COLLECTION FORM . . . . . . . . . . . . . . . . . . . . . . . . . . 2-3

Cover Page . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-3 Introductory Letter . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-4 Summary of Work-Related Injuries and Illnesses . . . . . . . . . . . . . . . . . . . . . . . . 2-4 Information About the Person Completing the Form . . . . . . . . . . . . . . . . . . . . . 2-4 iv Procedures Manual

TABLE OF CONTENTS (cont.)

SECTION 3 INITIAL MAILING OF DATA COLLECTION FORMS

3.1 DATA COLLECTION MATERIALS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1

3.2 PRE-MAILING PROCESSING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1

Removing Duplicate, Out-of-Scope, and Out-of-Business Establishments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1 Confirming Return Address Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-2

3.3 ASSEMBLING THE INITIAL MAILING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-2

SECTION 4 PROCESSING DATA COLLECTION FORMS

4.1 CHECKING IN DATA COLLECTION FORMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1

Receiving Responses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1 Assigning Status Codes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-2 Electronic Submissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-3

4.2 POST OFFICE RETURNS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-3

4.3 EDITING DATA COLLECTION FORMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-5

4.4 ENTERING DATA COLLECTION FORMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-5

Establishment Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-6 Injury and Illness Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-6 Data Comparison . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-6 Bypass Codes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-7 Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-7

Procedures Manual v

TABLE OF CONTENTS (cont.)

SECTION 5 CHECKING EDIT CONDITIONS, VERIFYING RESPONSES, AND

CORRECTING DATA

5.1 OVERVIEW OF EDIT CONDITIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1

Edit Criteria for Type I Conditions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1 Edit Criteria for Type II Conditions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1 Edit Criteria for Type III Conditions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-2

5.2 CHECKING EDIT CONDITIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-9

5.3 VERIFYING AND/OR CORRECTING DATA COLLECTION FORMS . . . . . . . . . . . 5-11

5.4 EMPLOYER’S ONSITE LOG SUMMARY VS.

THE OSHA DATA COLLECTION FORM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-13

SECTION 6 NONRESPONSE FOLLOW-UP

6.1 NONRESPONSE FOLLOW-UP BY MAIL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1

6.2 NONRESPONSE FOLLOW-UP BY TELEPHONE . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-2

6.3 OPTIONAL THIRD MAILING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-3

SECTION 7 PROCESSING ELECTRONIC SUBMISSIONS AND USE OF SUPPORTING

WEB SITES

7.1 OSHA’S LOG DATA COLLECTION WEB SITE . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-1

7.2 LOG DATA COLLECTION SUPPORT WEB SITE . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-2

Timeline . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-2 Software . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-3 LDCS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-3 Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-3 Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-3 News & Notices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-3 vi Procedures Manual

TABLE OF CONTENTS (cont.)

SECTION 7 PROCESSING ELECTRONIC SUBMISSIONS AND USE OF SUPPORTING

WEB SITES (CONT.)

7.3 PROCESSING ELECTRONICALLY SUBMITTED DATA . . . . . . . . . . . . . . . . . . . . . . 7-4

Daily Notification of Electronic Submissions . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-4 Printing Edit Condition Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-4 Generating Summary Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-4

SECTION 8 MONITORING THE PROGRESS OF THE DATA COLLECTION

8.1 OVERVIEW OF DATA COLLECTION ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . 8-1

Priorities for Data Collection Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-1 Expectations for Data Collection Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-2

8.2 DATA COLLECTION MONITORING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-2

Collection Status Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-2 Data Quality Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-3

8.3 DATA COLLECTION PROGRESS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-3

FREQUENTLY ASKED QUESTIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . FAQ-1

APPENDIX A LOG DATA COLLECTION PROCEDURES FLOW DIAGRAMs

APPENDIX B OSHA WORK-RELATED INJURY AND ILLNESS DATA

COLLECTION FORM, 2007 (FORM 196B)

Procedures Manual vii

TABLE OF CONTENTS (cont.)

LIST OF TABLES

Table 1.1 Collecting States . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-2 Table 1.2 Exempt Industries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-4

Table 4.1 Tracking Status Codes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-8

Table 5.1 Edit Criteria for Type I Conditions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-2 Table 5.2 Edit Criteria for Type II Conditions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-3 Table 5.3 Acceptable Ranges of Average Hours Worked for

Type II Condition ST2(08) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-4 Table 5.4 Bypass Codes for Type II Conditions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-6 Table 5.5 Edit Criteria for Type III Conditions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-8

Procedures Manual 1-1

To meet many of its program needs, the Occupational Safety and Health Administration (OSHA) has undertaken an effort to collect data on injuries and illnesses attributable to work-related activities in private-sector industries. To facilitate this process, OSHA has developed the Log Data Collection System (LDCS), a Web-based application (with a PC component) for entering information into a database and tracking and monitoring the data collection process. This document provides an overview of the data collection procedures. A separate LDCS Users Manual was developed as a guide to using the Web-based LDCS.

SECTION 1

INTRODUCTION

1.1 Overview of the Log Data Collection Initiative

Why Will OSHA Collect These Data?

The objective of OSHA’s Log Data Collection Initiative is to compile occupational injury and illness information from establishments in selected high-hazard industries. Information collected through the data collection initiative will allow OSHA to calculate work-related injury and illness rates. OSHA will use the data as a basis for targeting intervention programs (e.g., inspections, outreach, technical assistance, leveraging) and to measure the success of Agency efforts to help reduce the number of workplace injuries and illnesses. Successful implementation of the data collection initiative is critical to OSHA’s programmatic efforts and the Agency’s need to comply with data requirements tied to the Government Performance and Results Act (GPRA).

Who Will Collect These Data?

The Log Data Collection System (LDCS) is modeled after the Bureau of Labor Statistics (BLS) Survey of Occupational Injuries and Illnesses, Part 1 (Annual Survey). All states participating in the BLS Annual Survey were given the opportunity to collect data for OSHA. Not all of them opted to participate. Table 1.1 lists the states that are collecting data for OSHA and indicates which states are collecting data for nonparticipating states.

Section 1 May 2008

1-2 Procedures Manual

Table 1.1 Collecting States

Collecting State Collecting for Nonparticipating State(s)

Alabama Arkansas California Connecticut Delaware Georgia Hawaii Indiana Iowa Kansas Kentucky Louisiana Maine Maryland Massachusetts Michigan Minnesota Mississippi Missouri Nevada New Mexico North Carolina Oklahoma Tennessee Texas Utah Vermont Virginia West Virginia Wisconsin

OSHA

ERG*

DC, PA (ZIP 156-166)

NH, PA (ZIP 150-155, 167-177), RI

PA (ZIP 190-196)

OH (ZIP 441-443, 445)

OH (ZIP 434-435, 444, 446-458)

CO, ID, MT, NE, ND, SD

OH (ZIP 430-433, 436-440), FL (ZIP 344, 346-347, 349)

FL (ZIP 322, 324-328)

PA (ZIP 178-189)

FL (ZIP 320-321, 323, 329-342), IL (ZIP 600, 604, 624-628),

U.S. Post Offices NJ, NY, IL (ZIP 601-603, 605-623, 629), Central Collection Employers

* An OSHA contractor serving as a collecting state.

Procedures Manual 1-3

Who Will Provide These Data?

This year OSHA will collect data from approximately 80,000 establishments nationwide.

Employers are not required to keep OSHA injury and illness records for any establishment classified in the SIC codes listed in Table 1.2. Therefore, all industries except those listed in Table 1.2 are in scope of the OSHA data collection. Additionally, establishments under Mine Safety and Health Administration (MSHA) jurisdiction, public sector establishments in federal states and establishments with fewer than 10 employees are out-of-scope of the OSHA data collection.

Data solicitations will be sent to establishments in the following categories:

• Approximately 1/3 of the 140,000 establishments in non-construction industries with 40 or more employees.

• Establishments that were nonrespondents in CY 2006.

• Establishments with an inspection or consultation visit for performance measurement.

• All establishments with an LWDII rate or DART rate of 7.0 or higher in previous data collections.

• Public sector establishments identified by State Plan State Offices.

1-4 Procedures Manual

Table 1.2 Exempt Industries

SIC

Code

Industry Description SIC Code

Industry Description

Hardware Stores Meat and Fish Markets Candy, Nut, and Confectionary Stores Dairy Products Stores Retail Bakeries Miscellaneous Food Stores New and Used Car Dealers Used Car Dealers Gasoline Service Stations Motorcycle Dealers Apparel and Accessory Stores Radio, Television, & Computer Stores Eating and Drinking Places Drug Stores and Proprietary Stores Liquor Stores Miscellaneous Shopping Goods Stores Retail Stores, Not Elsewhere Classified Depository Institutions (banks & savings institutions) Nondepository Institutions (credit institutions) Security and Commodity Brokers Insurance Carriers Insurance Agents, Brokers, & Services Real Estate Agents and Managers Title Abstract Offices Holding and Other Investment Offices Photographic Studios, Portrait Beauty Shops Barber Shops Shoe Repair and Shoeshine Parlors

Funeral Service and Crematories Miscellaneous Personal Services Advertising Services Credit Reporting and Collection Services Mailing, Reproduction, & Stenographic Services Computer and Data Processing Services Miscellaneous Business Services Reupholstery and Furniture Repair Motion Picture Dance Studios, Schools, and Halls Producers, Orchestras, Entertainers Bowling Centers Offices and Clinics of Medical Doctors Offices and Clinics of Dentists Offices of Osteopathic Physicians Offices of Other Health Practitioners Medical and Dental Laboratories Health and Allied Services, Not Elsewhere Classified Legal Services Educational Services (schools, colleges, universities and libraries) Individual and Family Services Child Day Care Services Social Services, Not Elsewhere Classified Museums and Art Galleries Membership Organizations Engineering, Accounting, Research, Management, and Related Services Services, Not Elsewhere Classified

Note: Companies with SIC Codes listed above should be coded OS (out-of-scope) in LDCS.

Procedures Manual 1-5

1.2 Overview of Data Collection Procedures

Collecting State’s Role

The collecting state’s role in data collection involves mailing the forms, entering collected data, and conducting follow-up contact as needed. Specifically, the collecting state is responsible for:

• Reviewing the database of selected establishments to identify duplicate entries and entries for establishments that are out-of-business or out-of-scope for this collection effort.

• Mailing data collection forms to establishments. This includes providing postage for mailout envelopes and preaddressed, postage-paid return envelopes.

• Receiving post office returns, verifying addresses, and remailing surveys to the establishments where a new address was found.

• Checking in and entering information from data collection forms into the OSHA database using LDCS.

• Reviewing the Daily ES and COMP Auto-Run Reports within the LDCS Report Generation menu.

• Recontacting establishments by phone, fax, or mail to verify and/or correct questionable data.

• Conducting a second mailing for establishments that fail to respond to the initial data collection mailing within 30 days (again providing postage for mailout envelopes and preaddressed, postage-paid return envelopes).

• Conducting telephone follow-up with establishments that fail to respond within 30 days of receiving the second mailing.

• Correcting establishment records that have questionable or incomplete data identified in the monthly data quality reports.

• Monitoring the progress of the data collection to meet OSHA milestones.

1-6 Procedures Manual

OSHA’s Role

OSHA’s role in the data collection is to provide overall program management and support for the data collection effort. OSHA is responsible for determining data collection policies;

administering resources; and planning, developing, and directing all electronic data collection and processing operations. Specifically, with support from its contractor, OSHA is responsible for:

• Determining the data collection effort’s goals and requirements.

• Allocating financial and other resources.

C Interacting with collecting states.

C Interacting with Congress, other government agencies, and interest groups.

C Designing, developing, testing and providing technical assistance for LDCS.

C Issuing a procedures manual and technical instructions for LDCS.

C Interacting with contract printers.

C Identifying establishments from which states will collect data.

C Providing states with data collection forms, survey labels, and mailing envelopes for initial, second, and optional third mailings.

C Establishing and maintaining a Web-based collection site for survey respondents.

C Reviewing the database on a monthly basis to identify data quality issues.

Procedures Manual 2-1

SECTION 2

THE OSHA DATA COLLECTION FORM

2.1 Overview of the OSHA Data Collection

To the extent possible, OSHA will integrate its collection of data on occupational injuries and illnesses with the BLS data collection effort. BLS collects data for its annual survey from a sample of all private-sector industry establishments. The BLS survey solicits summary information on occupational injuries and illnesses in all surveyed establishments. In addition, the BLS survey collects information on the demographics and circumstances of a sample of the injuries and illnesses that required recuperation away from work. The information collected is used to generate aggregate statistics on occupational injuries and illnesses at the state and national levels.

For program targeting purposes, OSHA needs worksite-specific data that BLS is unable to provide. Because OSHA collects data from all establishments that meet certain criteria (e.g., industry, size group, and injury/illness rate), some of the establishments from which OSHA requires data will also be included in the BLS sample. BLS estimated that four percent of the establishments from which OSHA requires data will be included in the BLS Annual Survey. Therefore, BLS will conduct a computer search to identify establishments on both the BLS list and the OSHA list.

Three groups of establishments are included in OSHA’s data collection effort:

• Establishments on both the OSHA list and the BLS list (i.e., overlap group).

• Establishments on the OSHA list but not on the BLS list (i.e., non-overlap group).

• Establishments on both the OSHA list and the BLS list but not identified as overlap establishments.

OSHA will rely on the following approaches to collect data from establishments.

The OSHA data collection form is modeled after the BLS Annual Survey, Part I. Two versions of the OSHA data collection form have been developed:

(1) a form for establishments on both the BLS Annual Survey list and the OSHA list of establishments in selected high-hazard industries and (2) a form for establishments exclusively on the OSHA list. Both forms are processed in the same manner.

Section 2 May 2008

2-2 Procedures Manual

Establishments on Both the BLS List and the OSHA List Identified as Overlap Establishments

Establishments in the overlap group will receive a six-page data collection form soliciting information required by OSHA as well as information collected in Part I of the BLS Annual Survey.

This overlap form (OSHA Form 196A) is titled OSHA Work-Related Injury and Illness Data Collection Form, 2007. When the establishment has completed this form, it should return the appropriate pages (pages 3a and 4a) to BLS’s state agency with the survey package in lieu of Part I of the BLS Annual Survey and should return the remaining pages of the form to the OSHA collecting state (in the preaddressed, postage-paid return envelope provided by the state). Due to BLS’s confidentiality guidelines, collecting states that receive submissions on the OSHA Form 196A will process them in the same manner as responses received on the OSHA Form 196B.

Establishments on the OSHA List but Not on the BLS List

Establishments on the OSHA list but not on the BLS list (i.e., the non-overlap group) will receive a four-page form soliciting data specifically required by OSHA. This non-overlap form (OSHA Form 196B) is titled OSHA Work-Related Injury and Illness Data Collection Form, 2007, and a copy of this form is presented in Appendix B. The establishment should return pages 1, 3, and 4 of the form to the OSHA collecting state (in the preaddressed, postage-paid return envelope provided by the state).

Establishments on Both the OSHA List and the BLS List but Not Identified as Overlap Establishments

OSHA and BLS use different computer files to determine which establishments to include in their data collections; moreover, the process for identifying establishments included in both lists may not be comprehensive. Thus, some establishments that should be in the overlap group will receive both the OSHA form and the BLS survey. To alleviate the double burden to these establishments, OSHA and BLS have developed the following procedures:

• OSHA and BLS will sequence the mailing of the collection instruments.

• The BLS Annual Survey will include instructions for establishments that have already responded to the OSHA information request. The instructions state that these establishments can return to BLS a photocopy of the completed OSHA form rather than complete the corresponding questions on Part I of the BLS Annual Survey.

• The OSHA data collection form includes instructions for establishments that have already received the BLS survey. The instructions state that these establishments can either complete the OSHA data collection form or return a photocopy of pages 1 and 2 of the completed BLS survey form to OSHA.

Procedures Manual 2-3

• BLS will update its database, flagging matching records to avoid double contact in the future.

2.2 Contents of the Data Collection Form

The overlap form (OSHA Form 196A), which collecting states will send with the BLS Annual Survey to overlap establishments, and the non-overlap form (OSHA Form 196B), which states will send to non-overlap establishments, include the following elements. (See Appendix B for a copy of the OSHA Work-Related Injury and Illness Data Collection Form, 2007.)

Cover Page

The cover page of the OSHA data collection form includes the OSHA logo, the data collection form title and year, OMB number, and a statement about the reporting burden. The label will present the following information:

Upper portion of label

• Establishment’s Dun & Bradstreet (DUNS) number (labeled ID NUMBER).

• Establishment’s password for accessing the data collection Web site, if the company chooses to respond via the Internet.

• Barcode representation of establishment's ID number.

• Collecting state’s return address.

• Collecting state’s telephone number, which the establishment could use to call in questions.

• Collecting state’s fax number, which the establishment could use to send the completed form.

• Collecting state’s email address (optional), which the establishment could use to submit questions.

Lower portion of label

• Establishment’s approximate number of employees.

• Establishment’s SIC code.

• Establishment’s NAICS code.

• Establishment’s reporting site address.

• Establishment’s name.

• Establishment’s mailing address.

• The form will be addressed to “Safety Manager or HR Manager.”

Section 2 May 2008

2-4 Procedures Manual

Introductory Letter

The second page of the data collection form is an introductory letter that describes the nature of the data collection effort and solicits the establishment’s cooperation with OSHA and the collecting states. The letter also introduces the electronic reporting option and provides the Web site address. The letter refers the establishment to the collecting state’s telephone number on the cover for obtaining additional information. The introductory letter also describes the types of information requested by the form and provides instructions on completing the form.

Summary of Work-Related Injuries and Illnesses

Page three of the data collection form requests establishment specific information, including annual average number of employees and the total number of hours that employees worked during 2007, that the respondent will copy from their completed 2007 Summary of Work-Related Injuries and Illnesses (OSHA Form 300A). It also requests information on conditions that might have affected the number of employees or the hours they worked (e.g., a strike or a shutdown).

Page four of the data collection form requests the following information from the respondent’s completed 2007 Summary of Work-Related Injuries and Illnesses (OSHA No. 300A):

• Number of Cases (including the total number of deaths, total number of cases with days away from work, total number of cases with job transfer or restriction, and total number of other recordable cases).

• Number of Days (including total number of days of job transfer or restriction and total number of days away from work).

• Injury and Illness types (including injuries, skin disorders, respiratory conditions, poisonings, hearing loss, and all other illnesses).

Information About the Person Completing the Form

At the end of the data collection form is a section entitled Sign and return this form, which asks for the printed name, title, telephone number, fax number, email address, and signature of the person the collecting state should call with questions about the information provided. This section also requests the date the form was completed. This contact information is important to the success of the data collection effort because it facilitates the verification of questionable data.

Procedures Manual 3-1

OSHA will send mailing labels, data collection forms, and mailout envelopes to each collecting state for the initial and follow-up mailings. The collecting state will prepare and send the data collection forms by first class mail to all establishments in the database provided by OSHA, except to those identified as duplicate, out-of-scope, or out-of-business establishments. The state will then assign the ML status code in the database for each mailed form.

SECTION 3

INITIAL MAILING OF DATA COLLECTION FORMS

3.1 Data Collection Materials

OSHA will send each collecting state OSHA Data Collection Forms for twice the number of establishments the state is contacting and mailout envelopes for 1½ times the number of establishments to accommodate both initial and follow-up mailings. OSHA will also provide mailing labels. States will provide their own preaddressed, postage-paid return envelopes. Also, states will pay the postage for the initial and follow-up mailings of the data collection forms, as well as the postage for the return envelopes. Additional supplies are available upon request for states that opt for a third mailing. OSHA will notify all states when to begin the initial mailing of the data collection forms (196A and 196B).

The collecting state will send an OSHA Form 196A to all establishments on both the BLS list and the OSHA list by first class mail. The collecting state will send an OSHA Form 196B to all non-overlap establishments by first class mail. The package will contain the data collection form with the establishment mailing label affixed and the preaddressed, postage-paid return envelope.

Due to BLS’s confidentiality guidelines, all data submissions (196A or 196B) will be processed in the same manner.

3.2 Pre-mailing Processing

Removing Duplicate, Out-of-Scope, and Out-of-Business Establishments

While OSHA has attempted to remove establishments that were identified as duplicate, out-of-scope, or out-of-business in previous collections, collecting states should review their database of selected establishments to identify duplicate, out-of-scope, or out-of-business establishments as time allows. These establishment records should be marked as such in the database using the LDCS Survey Tracking function. For definitions of duplicate, out-of-scope and out-of-business

Section 3 May 2008

3-2 Procedures Manual establishments refer to Section 4 and the Frequently Asked Questions section at the end of this manual. The state will mail data collection forms to all establishments that were not marked as duplicate, out-of-scope, or out-of-business.

Confirming Return Address Information

LDCS includes a separate Windows-based application to generate and print mailing labels for the initial and follow-up mailings. Collecting states should install the Log Data Printing System (LDPS) on each computer used for the collection following the installation instructions provided in the LDCS Users Manual. Prior to the start of the data collection initiative, each state was asked to provide OSHA with address information. Before printing any establishment labels, each collecting state should confirm that its return address information has been entered into LDPS correctly, and that the label includes all appropriate return address information. To view and edit return address information, follow the procedures outlined in the LDCS Users Manual.

3.3 Assembling the Initial Mailing

Using LDPS, the collecting state will generate a mailing label for each establishment that will receive a data collection form. The mailing labels will print four to a sheet. A sample mailing label is provided in Appendix B. It is advisable to send labels to the printer in small batches (approximately 20 pages) rather than sending the entire group to the printer, in cases there are jams or other printer problems. The initial mailing of the data collection forms will be addressed to “Safety Manager or HR Manager.” Subsequent mailings can be addressed to the contact name provided in the database if desired. To generate mailing labels follow the instructions provided in the LDCS Users Manual.

After printing the mailing labels, the collecting state will affix each mailing label to the front cover of an OSHA Work-Related Injury and Illness Data Collection Form, 2007, fold the form in thirds, and place the form and a postage-paid return envelope in the mailout envelope provided by OSHA.

Be sure the mailing address and return address are readable through the windows of the mailout envelope. The collecting state will then seal the envelope and affix first-class postage.

After assembling the mailing, the collecting state will use the LDCS Survey Tracking function to assign the ML (mailed) tracking status code to each mailed form. Once the initial mailing has been completed, it is good practice to search the database for any DUNS that might remain in the BLANK status code to be certain that all establishments in the database have been mailed the initial data collection form. For instructions on Survey Tracking and the LDCS Search function refer to the LDCS Users Manual.

Procedures Manual 4-1

When a collecting state receives a data collection form from an establishment or a returned form from the U.S. Postal Service, it must record this information in LDCS. During this check-in process, the state assigns an appropriate tracking status code for each survey. After checking in data collection forms, the state will perform limited editing on the submitted forms and then will enter the information on these forms into the OSHA database.

SECTION 4

PROCESSING DATA COLLECTION FORMS

4.1 Checking In Data Collection Forms

When the collecting state receives a data collection form from an establishment, the state must record the receipt of the form in the database using the LDCS Survey Tracking function. The collecting state should check in all mailed or faxed data collection forms as the collecting state receives them.

Receiving Responses

OSHA allows establishments to respond to the Log Data Collection Initiative in the following ways:

• Mail responses to the collecting state.

• Fax responses to the collecting state.

• Email responses to the collecting state.

• Phone in responses to the collecting state (if state staff are willing to transcribe answers provided by the establishment).

• Electronically input and submit data via the Internet (www.osha.gov/form196/cy07.htm).

Section 4 May 2008

4-2 Procedures Manual

Assigning Status Codes

Table 4.1 presents a complete list of the LDCS tracking status codes. For additional information on using status codes refer to the Frequently Asked Questions.

If the establishment indicates on its returned data collection form that this site is no longer in operation, the state should assign a final status code of OB (out-of-business) to the establishment record. If the establishment indicates that it is exempt from recordkeeping or otherwise out of the scope of the data collection (e.g., establishment is under MSHA jurisdiction, or is a state agency in a federal state) the state should assign a final status code of OS (out-of-scope) to the establishment record.

If the establishment states that it is a holding company or corporate headquarters and employs office/sales personnel only, the state should assign a final status code of OO (office only) to the establishment record. OSHA created the OO status code to separate holding companies and corporate offices, which are out-of-scope, from the rest of the database.

If the establishment indicates that it received more than one form for the same location, the state should verify the information and assign a final status code of DU (duplicate) to the form that was not completed. LDCS will require the state to enter the duplicate DUNS when assigning the DU status code. Whenever possible, the state should assign the DU status code to the higher of the two DUNS numbers. For example, if 002123456 is a duplicate of 123456789 the state should enter data for DUNS number 002123456 and assign the DU status code to DUNS number 123456789.

If the establishment indicates that due to extraordinary circumstances (e.g., factory fire, new establishment owner) injury and illness records for 2007 are not available, the state should verify the information and assign a final status code of RU (records unavailable) to the establishment record.

The RU status code signifies that data are not available for the current collection, but may be available for subsequent collections. If an establishment was in operation during the collection year, but has since gone out-of-business or is in the process of closing and the records for the collection year are in storage and difficult, if not impossible to retrieve, the state should assign the OB status code to this establishment record since data cannot be collected from this establishment in subsequent collections.

It is important to note, that bankruptcy is not the same as out-of-business. The state should assign the RU status code to establishments that have declared bankruptcy and cannot provide the requested data, but are still in operation. However, establishments that have closed due to bankruptcy should be coded OB.

Note: It is necessary to fully document the reasons in the comments field when assigning establishments the OB, OO, OS, or RU tracking status codes. Sample documentation is provided in Table 4.1.

Procedures Manual 4-3

The state should assign a tracking status code of CI (checked in) to all other forms returned with data. If, at check-in, the DUNS number is not found or is illegible, the LDCS Search tool can be used to determine the establishment’s DUNS number. Refer to the LDCS Users Manual for instructions on using the LDCS Search tool. After the correct DUNS number is determined, the user should write the number on the first page of the data collection form.

The Survey Tracking function alerts users who are checking in a form that has already been checked in or electronically submitted. The system will not let the user check in such a form because a record already exists for this DUNS number.

Electronic Submissions

Establishments may submit data electronically via the Internet. The processing of electronic submissions is covered fully in Section 7 (Processing Electronic Submissions and Use of Supporting Web Sites). When OSHA receives an electronic submission for a particular DUNS, LDCS will automatically assign the ES (electronically submitted) status code to the establishment record.

Because data for electronic submissions are entered and confirmed by the establishment, such submissions bypass the double data entry procedure and are advanced immediately to the Edit Condition Report (see Section 5). Overnight, LDCS will automatically run the ECRG procedure for all electronic submissions received that day. The results of this ECRG auto-run will include electronic submissions received up to midnight of the previous day and will be available from the LDCS Report Generation function. The Daily ES Auto-Run Report will include the establishment’s DUNS, current status, submitted date, ECRG auto-run date, batch, business name, and state.

The Daily ES Auto-Run Report will include a link to the ES Auto-Run Duplicate Data Report. This report contains the list of electronically submitted DUNS that could not be processed automatically by the system because injury and illness data already exist in the database. If establishment information for a given DUNS number has already been entered manually, LDCS will not import data a second time electronically. In this situation, states should click on the DUNS of the data that could not be imported and compare the electronically submitted data to the hard copy data that already exist in LDCS.

4.2 Post Office Returns

Some of the mailing addresses for the data collection forms will be incorrect. When the U.S.

Postal Service returns forms to a collecting state, the state should take steps to confirm or correct the mailing address as described below.

The collecting state should identify post office returns by assigning a tracking status code of PO (post office return) to the establishment. When the collecting state assigns a PO status code to an establishment, LDCS will prompt the user to enter into the comments field a brief description of the post office return (e.g., “forwarding order expired” or “insufficient address”). The state should later update the comments field to include information on efforts to remail the survey ( e.g., 4-4 Procedures Manual

“address updated per telephone call to establishment;” or “phone number is disconnected; no listing with directory assistance or the Internet”).

After assigning the PO status code to all surveys returned by the Post Office, the state should generate a Post Office Return Report. Refer to the LDCS Users Manual for instructions on generating the Post Office Return Report. The Post Office Return Report contains establishment information, including DUNS number, SIC, NAICS, employment, the date the PO status code was assigned, and establishment address information. The state can use this report as a worksheet to correct establishment addresses.

Next, the state must investigate each address to determine if a correct mailing address exists.

Verifying a correct address may involve calling the establishment or finding the address in a local telephone directory or on the Internet. The state must resolve post office returns by performing one of the following procedures:

• The state verifies that the original mailing address is correct and remails the form and assigns a tracking status code of PRM (remailed to correct address).

• The state determines the correct address and updates the mailing address information using the Address Updating feature in LDCS. The state prints a new mailing label using the Log Data Collection System Printing Application (LDPS), affixes the new label to the form, remails the form with a preaddressed, postage-paid return envelope, and assigns a tracking status code of PRM.

Note: After entering address changes into LDCS, the state must use the “Load Address Information” feature under System Tools to export data to LDPS and print new mailing labels. Refer to the LDCS Users Manual for instructions on using the LDCS System Tools.

• The state determines that the establishment is out-of-business or otherwise not operating, assigns a final status code of OB (out-of-business), and indicates the date the establishment closed in the comments field. Establishments should only be marked OB when it is confirmed that the site is no longer in operation. If the state is unable to contact an establishment, the correct status code is UM (unmailable, no new address found).

• If correction or verification of the address is not possible, the state assigns a final status code of UM (unmailable, no new address found) and indicates the reason for assigning this status code in the comments. Correction and verification are considered “not possible” if the state is unable to contact the establishment (e.g., phone number has been disconnected and no other number is found via directory assistance or the Internet) and makes several attempts to find the correct address using state records or other publicly available information sources.

• The state determines that the establishment does not meet recordkeeping requirements, is under MSHA jurisdiction, or is a state agency in a federal state, Procedures Manual 4-5 assigns a final status code of OS (out-of-scope), and indicates the reason for this status in the comments field.

• The state determines that the establishment is a holding company or is a corporate headquarters facility that employs only office/sales workers, assigns a final status code of OO (office only), and indicates the reason for this status in the comments field.

• The state determines that the establishment received more than one form for the same location, assigns a final status code of DU (duplicate), and enters the duplicate DUNS into LDCS.

Once the address has been updated in LDCS, the system will automatically note the date of the change of address. This date will be displayed on the bottom of the first data-entry screen (Establishment information was last modified on xx/xx/xxxx). By noting the date of a change of address, this information could aid collecting states in determining a more recent survey, in the event two surveys are returned from a company with the same DUNS but different addresses.

4.3 Editing Data Collection Forms

Editing is limited to the following activities:

• Crossing out superfluous words (e.g., “approximately”).

• Replacing any words that represent numbers with numerals (e.g., replace “none” with “0”, and “two” with “2”) for questions that require a numeric response.

• Changing fractions and decimals to whole numbers, by rounding to the nearest whole number.

With the exception of the types of editing presented above, the state should never cross out or correct any information on the data collection form prior to data entry; even obviously incorrect information must be entered as is. The state will resolve incorrect information during data verification (through the Edit Condition Report and follow-up telephone calls) and will include information that is subsequently obtained about the submitted data in the comments field of the establishment record.

4.4 Entering Data Collection Forms

The LDCS Data Entry function is used to enter information provided on the form, including establishment information (site address, mailing address, SIC, NAICS), injury and illness data, and comments.

The Data Entry function uses a double data entry procedure to eliminate typographical errors from the database and to minimize the number of errors caused by the misinterpretation of

4-6 Procedures Manual data. The procedure is designed to accommodate an initial entry of responses into a master (or “primary”) database and a duplicate entry of the same data into a duplicate (or “secondary”) database. Whenever possible, different workers should perform each data entry step. The system will automatically assign a tracking status code of DE1 (primary data entry) when the initial entry of responses is complete and a tracking status code of COMP (secondary data entry and data compared) when the second entry of responses is complete and compared with the primary record.

Only forms that have a previous tracking status code of CI (checked-in) can be data entered.

Establishment Information

All surveyed establishments are instructed to make any necessary corrections to the establishment business name, mailing address, site address, SIC, and NAICS printed on the label attached to the form. Data entry personnel will enter the corrected address, business name, NAICS, SIC and other information on the cover page of the form into the database using the Data Entry function. In primary data entry, the original establishment information is presented on the screen and can be edited to reflect changes rather than being completely re-entered. In secondary data entry, the information saved in the primary record is displayed on the screen and should be verified and corrected if necessary. If any of the address information has been changed, the date of the change will display on the bottom of the first Data Entry screen and the Address Updating screen.

Injury and Illness Data

All injury and illness data reported on the data collection form should be entered into the database using the LDCS Data Entry function. Refer to the LDCS Users Manual for more information on entering injury and illness data. The Data Entry screen was designed to correspond with the paper data collection form. Data entry personnel should enter values in the numeric fields, check boxes to select appropriate options, and enter text in the appropriate spaces. Data Entry personnel can also enter comments through the Data Entry screen.

Data Comparison

OSHA requires double data entry to ensure the accuracy of the data entered into LDCS.

Some of the data elements do not need to be entered twice, including address information and establishment respondent information. It is the responsibility of the secondary data entry person, however, to verify that the information entered in the primary record, as displayed on the screen, is correct. Because data submitted electronically were entered by the establishment and confirmed by the establishment, secondary data entry is not necessary.

When secondary data entry is completed and the record is saved, each entry is compared with the value stored in the primary data record. If any values in secondary data entry differ from those entered during primary data entry, the system will prompt the user to correct any discrepancies. All discrepancies must be corrected before the data record can be saved.

Procedures Manual 4-7

If the user is unable to determine the correct value of a data element because the entry is illegible on the form, assistance should be sought from another staff member. If the discrepancy still cannot be clarified, choose the most logical value and flag the data for a follow-up telephone call.

Bypass Codes

LDCS performs a series of checks on establishment information following data entry comparison. This process reviews the data and reports any information that does not fit the data collection parameters. If an edit condition report is generated, the state should contact the person who signed the data collection form to correct and/or explain any data anomalies. If an Edit Condition Report contains Type II errors (see Section 5 for more information on edit condition checks and bypass codes), the Bypass function will be available from the Data Entry function. If a bypass code is used, documentation must be included in the comments field. Use of a bypass code alone is NOT sufficient documentation to explain the outlying data. LDCS will prompt the user for documentation when a bypass code is selected. Refer to Section 5 for sample documentation to explain the use of a bypass code.