Evaluation of the Characteristics of Workers Injured on the Job Requiring Hospitalization and Employer Compliance with OSHA’s Reporting Requirement for these Work-Related Hospitalizations

Surveillance data is essential to identify and target prevention for all public health activity. Accurate and timely surveillance data are needed to identify causes of injury and illnesses, monitor prevention activity, plan interventions and evaluate the efficacy of these interventions. Unlike general public health surveillance, employers are a potential source of work-related injuries and illnesses surveillance data. Repeated studies have found that employers’ compliance with occupational injury and illness regulations involving reporting and recordkeeping are incomplete, missing 50 to 60% of the work-related injuries and even more of the work-related illnesses.^{2, 3} Reasons for incorrect or incomplete reporting by employers include business practices that encourage reporting low rates of injury and illness, poor organization of records and poor understanding of reporting requirements.

In 2014, federal OSHA implemented a new reporting requirement for acute severe injuries and illnesses that resulted in an inpatient hospitalization that require employers to report any employee who has an inpatient (overnight) hospitalization within 24 hours of their acute work-related injury or illness to a special hotline or online portal. Motor vehicle related work injuries are excluded. All OSHA state plans were required to adopt the new requirement. In 2015, Michigan OSHA (MIOSHA), a State-Plan state, implemented the new employer reporting requirement. In 2022, we published the first evaluation of employer compliance with the reporting requirement for hospitalizations, either at the federal or state-plan level.¹

Michigan has state regulations that require hospitals to report work-related hospitalizations. Michigan State University’s Division of Occupational and Environmental Medicine analyzed and evaluated the data collected during the first three years of these regulations. The researchers also identified factors that could strengthen the data being reported.

Using the first three full years of Michigan data, 2016-2018, we matched the hospitalized injuries and illnesses reported by employers to OSHA to the hospitalized injuries and illnesses reported by the 134 hospitals in Michigan by employee first and last name, company name, injury date and type of injury.

Important findings were:

• There were 2,887 workers hospitalized with severe injuries/illnesses from 2016-2018 in Michigan; 1,260 workers were reported by employers to OSHA, 2,238 workers were reported by hospitals. Employers only reported 1,260 of the 2,887 (43.6%) work-related hospitalizations.
• The median length of stay for the workers reported by hospitals was three days, ranging from a low of two days among workers with head injuries including skull fractures to three days for all other types of injuries. The total number of days hospitalized was 10,435 with an estimated hospital cost of $24,222,334.
• The percent of hospitalizations reported by employers did not significantly improve over the three years; 42.0% in 2016, 43.6% in 2017 and 45.0% in 2018.
• Companies with 250 or more employees were significantly more likely to comply (68.4%) and small companies with 10 or fewer employees were significantly less likely to comply (32.9%).
• Employers in manufacturing (64.7%), wholesale trade (57.5%) and public administration (66.2%) were significantly more likely to comply with the reporting requirement than employers in agriculture, forestry, fishing and hunting (8.2%); construction (38.2%); finance and insurance (21.4%); real estate and rental and leasing (27.3%); administrative and support and waste management and remediation services (33.9%); arts, entertainment and recreation (10.8%); accommodation and food services (20.8%); and other services except public administration (20.3%).
• Of the 465 inspections conducted in response to a work-related hospitalization, 246 (52.9%) of the employers had not corrected the hazard causing the injury and hospitalization prior to the inspection even though the inspection was conducted months after the hospitalization.

Two examples of the hospitalization, the hazards and the inspections follow:

1. An employee of a construction company was engaged in roofing work at a residential building. He was on a steep roof when he fell 22 feet to the concrete driveway. Emergency services were called, and the employee was hospitalized for a fractured leg. The company was inspected 181 days after the hospitalization; they were issued a serious citation directly related to the injury for failure to provide guardrail systems with toe boards, safety net systems or personal fall arrest systems when working on a steep roof. This hazard was still present at the time of inspection.

2. An employee was assisting a coworker with moving a granite slab that weighed approximately 1,000 pounds from a delivery truck to an outside storage bin. The employee was struck by the slab when it tipped forward from the forklift tines and fell on him. The employee was hospitalized for a collapsed lung, and shoulder and rib fractures. The company was inspected 83 days after the hospitalization and was issued a serious citation directly related to the injury; failure to lift or transport only a load that cannot fall out of a basket or container during the normal movements of the truck. This hazard was still present at the time of inspection.  The company was also cited for failure to provide refresher training to an operator.

Although not included in the published paper but because reporting by hospitals was also not complete, we have subsequently used capture-recapture analysis⁴ to estimate the total number of hospitalizations in Michigan for the three years. We estimate that there were another 1,505-1,953 work-related hospitalizations not identified either by the hospitals or employers.

The low compliance with the regulation was across all three years, with no appreciable improvement in compliance from 2016 to 2018. Disproportionate reporting in manufacturing, wholesale trade and public administration as well as companies with a large number of employees suggests lack of awareness of the requirement among employers less familiar with workplace safety and health issues, and/or who do not have a dedicated health and safety specialist. Better reporting lays the groundwork to fully characterize the industries where injuries and acute illnesses result in a hospitalization, which can then be used to target and evaluate preventive interventions in the workplace.

Given the usefulness of these reports to identify workplace hazards, it would be beneficial if employer compliance with the reporting requirement increased at a national level.  Our study was conducted in Michigan; we have no reason to expect that employers in other states are more or less likely to comply with the regulation.

As described in our paper, we also identified the following primary factors to strengthen the utility of the data being reported:

1. Improve compliance with employer reporting through enforcement and employer educational efforts.
2. Add hospital names to the OSHA reporting requirement.

A severe occupational injury and illness that leads to a hospitalization is an important sentinel event to capture in surveillance data. Our evaluation of the OSHA rule on the reporting of acute work-related hospitalizations showed the benefit of this reporting requirement while at the same time showed how the rule could be improved.

Kenneth D. Rosenman, MD, is a Professor of Medicine and Chief of the Division of Occupational and Environmental Medicine at Michigan State University.

Mary Jo Reilly, MS, epidemiologist, Division of Occupational and Environmental Medicine at Michigan State University.

Ling Wang, PhD, is a biostatistician and an Associate Professor in the Division of Occupational and Environmental Medicine at Michigan State University.

More information about the Michigan program can be found at: www.oem.msu.edu.

This research was conducted under research cooperative agreement award U60OH008466 supported by the Centers for Disease Control and Prevention National Institute for Occupational Safety and Health (CDC/NIOSH) under CDC funding opportunity PAR-20-312. The contents are those of the author(s) and do not necessarily represent the official views of, nor an endorsement, by CDC/HHS, or the U.S. Government. This blog is part of a series highlighting extramural research funded by NIOSH through the Office of Extramural Programs.

References

1. Reilly MJ, Wang L, Rosenman KD. Evaluation of the Characteristics of Workers Injured on the Job Requiring Hospitalization and Employer Compliance with OSHA’s Reporting Requirement for these Work-Related Hospitalizations Am J Ind Med Nov 26 2022. https://doi.org/10.1002/ajim.23447
2. Rosenman KD, Kalush A, Reilly MJ, Gardiner JC, Reeves M, Luo Z. How much work-related injury and illness is missed by the current national surveillance system? J Occup Environ Med 2006;48:357-365. https://www.jstor.org/stable/44998214
3. Boden LI, Biddle EA, Spieler EA. Social and economic impacts of workplace illness and injury: current and future directions for research. Am J Ind Med 2001;40:398-402. https://doi.org/10.1002/ajim.10013
4. Tilling K. Capture-recapture methods—useful or misleading? Intl J Epid 2001;30:12-14.