Dr. GOUGH. National Center for Health Statistics, was done with money that was set aside for evaluation activities in the Department of Health and Human Services. That was a small bit of money, so I think the cost of ensuring that death certificate data is more accurate and more useful would be small.

Mr. FRANK. One question that came up when Mr. McKernan was talking to the people from NIOSH was the extent to which NIOSH's approach appears to be the traditional one that they have used, which is cooperation with the States, depending on them for the data gathering. There is an awfully strong Federal interest in this, both from the humanitarian and the cost control point of view.

Is it satisfactory to rely on this kind of cooperative approach, waiting for the National Association of State Epidemiologists or is there some role here for some Federal enactments, either administrative or statutes that say "We want this data and we would like you to send it to us the best you can"?

Mr. KRONEBUSCH. Well, the current vital statistics system is a cooperative effort between States and the Federal Government and because the Federal Government is one partner, I am sure that legislation or appropriations on the Federal side would certainly be appropriate. I don't know and personally can't say whether it is absolutely necessary, but it is certainly appropriate.

Mr. FRANK. Is it your feeling, if we were to significantly increase the quality of the data collection here about occupational illness that some logical inferences could then be drawn about public policy? That is, would we then be able to say with regard to workplace conditions, "Let's change this and let's change that and maybe have a positive impact on the illness rate"? Presumably,

we

Mr. KRONEBUSCH. It is certainly the very first step. Developing data systems to measure the incidence and prevalence of occupational illness takes you the first step toward control. Whether or not controls actually then get applied is the second step, and that involves its own issues concerning Federal policies concerning regulatory issues and so on, but it is certainly a very important first step.

Mr. FRANK. Conceptually, out of that data collection would come some notions of how you would reduce illness. Now, whether or not they could be enacted, what that cost would be, would be other problems, but that would presumably yield us some proposals on how you could reduce illness.

Mr. KRONEBUSCH. Yes, certainly that is the first step.

Mr. FRANK. Based on where we are now on the state of the information here, which is not overwhelming, are we in a position to say that we have had much of an impact on occupational illness with the legislative and administrative effects of the last few years

or

Mr. KRONEBUSCH. Given the large uncertainties in just the absolute magnitude of the occupational illness problem, it is our judgment that it is absolutely impossible to measure trends. You can look at specific types of diseases and specific exposure situations and make judgments concerning——

Mr. FRANK. If there is some progress with a couple of—

Mr. KRONEBUSCH [continuing]. Progress in those specific instances.

For the overall incidence of occupational illness, I don't think you can actually measure whether we have had an impact on it yet or not.

Mr. FRANK. I thank you and will turn it over to Mr. McKernan. I become more convinced as we talk that for our money's worth, some relatively modest investment in improving the data collection in occupational illness promises to have the best leverage in ultimately dealing with that health care cost problem than anything we have talked about. A relatively small amount seems likely to go a very long distance.

Mr. McKernan.

Mr. McKERNAN. Just to follow up on that briefly, are there examples in which there may be some data that has been received nationally from various States that if other States had been furnishing that type of information, we might really be able to look at some trends and do the research that would make a difference?

Mr. KRONEBUSCH. We really don't have any specific examples of a State that has been providing particular information that would be more useful to apply nationally. Sorry, we don't have any examples of that.

Mr. McKERNAN. OK. I think that what the chairman and I are getting at is that it seems to us and we are certainly not the experts in this field, but it seems to us that this whole data-gathering process is one that sort of is loosely coordinated and if there were perhaps a little bit more direction from the Federal Government into exactly what it was that people had seen that they felt they needed more data on, that if there were some way of getting more of the States to be looking for that and to be reporting that in, that it would be easier to reach conclusions on these types of illnesses. Are we just off base on that or is that a problem?

Mr. KRONEBUSCH. I think you are probably onto an important issue that the Federal Government needs to be involved and needs to provide direction, especially for the large numbers of industries and occupations that spread across this Nation.

Specific States can address specific industries and occupations that occur in their area and may be of special concern to them, for example, coal mining in West Virginia. But there are a large number of industries and occupations that are spread throughout the United States and that, on a State-specific level, you are not going to be able to get very much useful information unless you do it collecting all the States nationally.

Mr. McKERNAN. I guess that is the point I was making. If you got some information in dribs and drabs from two or three States that had these particular types of industries, I gather there is no real way to send the word out except by talking to the various State epidemiologists to say, "We are afraid there is some kind of a trend here and we need more information on these types of illnesses in your States."

I mean, there doesn't seem to be a way to put that on a list of things that they are going to be submitting to you at this point, but rather, it has to sort of be done, "Gee, if you happen to come up with something along this line, would you send it to us?" It seems

like more structure might make it easier for you to do the research that is necessary and then put out the word to those States that have those types of industry.

Mr. FRANK. Thank you. Thank you very much, Mr. Kronebusch. Next we are going to hear from Dr. Janet Norwood, who is the Commissioner of Bureau of Labor Statistics and whom I haven't seen since I represented your mother-in-law in the State legislature. Dr. Norwood, nice to see you again.

STATEMENT OF JANET L. NORWOOD, COMMISSIONER, BUREAU OF LABOR STATISTICS, U.S. DEPARTMENT OF LABOR

Ms. NORWOOD. Thank you very much, Mr. Chairman. It is a pleasure to be here.

Your concern this morning is with the quality of data in the field of occupational safety and health and since the Bureau of Labor Statistics has responsibility-within the Department of Labor-for the survey of occupational safety and health, I would like to emphasize to you that this is something that we have concerns about, too.

The reputation of BLS rests on the quality of the work that we do in all areas of our activities. The Bureau has long been concerned with the maintenance of quality in all of our programs, including issues involved in survey design, data collection, processing and error structure.

Over the last few years, we have developed a program which we believe can serve as a prototype across the Bureau for the management of the quality of our statistical programs. We have begun in the price area and we are currently having put in place a rather comprehensive system in our producer price area, and currently expanding that into the CPI revision activities.

The important thing about these activities is that the programs are intended to follow all parts of the survey operation, from the definition of the concept through the survey process itself to the publication of results. Quality control of the entire management of a survey is an important step, not only toward the goal of developing statistical estimates of sampling and nonsampling error, but also toward the goal of more efficient allocation of program re

sources.

Now, in the case of occupational safety and health, quality management consists, it seems to me, of two major tasks: The first task is the full responsibility of the Bureau of Labor Statistics. It begins with the design of the most appropriate conceptual and statistical methodology for the development of data and the steps required to see that the survey design is fully and accurately carried out.

It includes a system of regular review processes, as well as special survey measurement and analyses, to ensure that the data are accurately and properly collected. This work also frequently involves research on concepts and clarification of definitions to ensure that the survey properly represents the phenomenon to be measured.

The second task is the assessment of such nonstatistical matters as the maintenance of the recordkeeping system. The quality of that system is important because the safety and health records kept by establishments are the source of the survey data gathered by the Bureau.

However, the role of the BLS in this second task is more limited than it is in the first. As the statistical arm of the Department of Labor, BLS assists the Department's Occupational Safety and Health Administration by clarifying definitions, responding to inquiries about what is to be recorded, and helping as best we can to bring about consistency in the application of the recordkeeping rules.

But we are a statistical agency. We do not engage in regulatory or enforcement activities.

Now, the first task-that is, the quality management of the survey design and implementation process-is one that BLS customarily carries out. It draws on our special expertise and experience. We believe that we have developed a very good statistical design and implementation program for our OSHA survey, including a probability sample of some 280,000 units with very high response rates, a detailed program for screening and editing all reported data, an ongoing review and monitoring of State grant agencies' procedures and the publication of sampling errors for survey estimates.

We use the current state of the art in these activities and, Mr. Chairman, we are extremely proud of these aspects of the safety and health survey. Of course, this doesn't mean that our procedures are perfect or that they should not be periodically reviewed. Even though the overall survey meets today's high statistical standards, we believe that from time to time, special investigations should be undertaken to check on the effectiveness of ongoing operations.

Now, the second task is a much more difficult one. The group of Government and outside experts who advised the Department of Labor more than a decade ago on establishing a recordkeeping system, agreed that the most feasible source of occupational safety and health data is the employer. BLS must rely on each company to record injuries and illnesses and to classify them properly.

As a result, the problem of maintaining accuracy and consistency in the recordkeeping system is greater than in our direct data collection. This dependence is not unique to the OSHA survey, or to this field.

Payroll and earnings data have been gathered successfully from employers for many decades, but the recording of illnesses and injuries is not an ordinary part of business accounting. The recording of occupational illnesses and injuries frequently relies on judgments by persons who often have no special training for the job. For company-supplied data on safety and health to be valid for statistical purposes, they must be reported and classifed in a uniform way. What is a recordable injury or illness? How does one determine whether an injury or illness is occupationally related? How are days lost through occupational injuries and illnesses measured? These questions must be answered consistently by all firms.

But such distinctions, which may at first blush seem to be clearcut and simple, often prove to be very difficult in practice. Years of responding to questions from company personnel have made that fact very clear to us. We have tried to provide supplementary guidelines to help safety officers and others who keep records in establishments to report information accurately, and we have consulted with management and with labor on clarifying these guidelines.

But thousands of new firms enter our survey every year,_and new people have to learn how to keep the records properly. Pressure of other work may lead to oversights or errors in transcription. Moreover, some firms and trade associations have devised their own guidelines for the recording of illnesses and injuries that are not fully consistent with those laid out by the Bureau.

Employees are also an important part of the reporting system. Do they always report minor accidents? If an employee does not feel well, does he or she report the illness? Reporting may sometimes seem simply too much trouble or, as a matter of self-esteem, many workers may be disinclined to report ailments that are not serious.

On the other hand, employees are concerned about their own safety and health, and one would expect them to have an interest in cooperating with the recordkeeping system.

In recent years, a new factor has given rise to concern. OSHA has concentrated its inspection efforts on those firms in hazardous industries with lost workday case injury rates above the average for manufacturing industries. This strategy makes a lot of sense, but it has raised the question of whether it also may give a firm an incentive to reduce reporting of injuries.

We do not know whether underreporting is, indeed, occurring and if so, whether the extent of such underreporting could be large enough to affect the accuracy of the survey. We also might say that we don't know whether overreporting is occurring.

Understandably, the accuracy of the recordkeeping is important in assessing the accuracy of the survey.

Now, another issue that concerns us, and that concerns the committee here this morning as well, is the reliability of data on occupational illness. This is a very troublesome issue and one that is presently, in my view, intractable.

While there is usually little ambiguity about whether an accident has taken place, as opposed to whether and how an injury should be recorded, there is always great uncertainty about the incidence of illness. Some illnesses, such as cancer and asbestosis, may be latent for years before symptoms appear. A worker may not get sick until long after he has retired, and thus, the case may never show up in the OSHA data.

We are aware of no practical way to detect such latent illnesses in our survey. Moreover, similar symptoms may arise from a multiplicity of causes.

A respiratory ailment may be caused by a virus encountered on the job or off the job; exposure to toxic substances may happen on the job, in the home, in an outdoor environment or in a combination of all three. Causation is difficult to determine.