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
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.
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
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)
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