Recordkeeping Requirements:

OSHA requires all private sector employers subject to the Act, with exceptions noted below, to prepare and maintain records of occupational injuries and illnesses. This information must be recorded on the Log and Summary ("OSHA 200") and the Supplementary Record ("OSHA 101") or an acceptable substitute.

In addition, all employers covered under the Act must report to OSBA within 48 hours any accident that results in one or more fatalities or the hospitalization of five or more employees. All such employers must also maintain any medical records required by OSHA's various health standards ́and must allow employees access to these records. Furthermore, all employers covered under the Act are required to maintain records if they are selected to participate in the BLS Annual Survey of Occupational Injuries and Illnesses.

Certain categories of employers have been exempted from having to keep the OSHA Log and Supplementary Record either by Act of Congress or by Agency administrative action. Thus, small businesses with ten or fewer employees were first exempted from keeping routine job safety and health records as a result of a direction from one of the Appropriations Committees; this exemption was subsequently adopted in an Agency rule. For several years, small farms (with ten or. fewer employees) have been exempted in OSHA's annual appropriations from all provisions of the Act, including recordkeeping and reporting provisions. In addition, employers in certain very low-hazard service industries, such as banks and

real estate, have recently been relieved of the requirement of keeping the OSHA Log and Supplementary Record. They still, of course, must report all accidents including fatalities and

multiple hospitalizations.

OSHA requires that employers allow inspection and copying of their records by authorized Federal and State governmental The OSHA 200 form must also be made avail

representatives.

able for examination and copying by employees, former employees, and their representatives. Each employer must post an annual summary of the OSHA 200 and leave the summary posted in the workplace from February 1 to March 1 every year. ployees thus have an opportunity of ensuring the accuracy of the information posted.

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All States operating Federally approved State programs, or "Plans," under section 18 of the Act, also participate in the BLS Survey and must have in place virtually identical injuryillness reporting requirements. Most States follow Federal OSHA ́s administrative policies concerning recordkeeping.

OSHA Inspection Data:

Since its inception in 1971, Federal OSHA has conducted more than 750,000 workplace inspections. OSHA compliance officers file detailed reports of on-site investigations, and the Agency's field offices maintain for several years voluminous case files for each inspection. Information on workplace

hazards and toxic exposures gathered during these workplace visits is a valuable resource for the Agency.

OSHA's automated Integrated Management Information System (IMIS) provides ready access to the results of all inspections conducted by the Agency. This system allows OSHA to monitor the performance of each Area and Regional office in virtually every aspect of the enforcement program. OSHA can easily retrieve data on such topics as the number of inspections, citations, violations, and employer contests. The IMIS system also produces information on the number and type of air samples and measurements made by OSHA industrial hygienists. OSHA data-collection capabilities will increase in the next few years as the Agency completes development of this newly improved computerized system.

Another source of information about OSHA's health inspections is the Agency's Salt Lake City Laboratory where all samples for toxic exposures taken by OSHA compliance officers are analyzed. This information is computerized and so is readily available. The system contains summaries of OSHA health inspection results grouped according to their 4-digit Standard Industrial Classification (SIC) codes. The Agency can thus provide data concerning the number of OSHA health inspections in each SIC code, and the average number of health violations per inspection, including serious health violations. This system also contains Cata on the sampling results

gathered by OSHA during inspections within each SIC code, providing statistics such as the total numbers of samples analyzed for a particular substance and the percentage of samples that exceeds OSHA's permissible exposure limits. FY 1983, 43,145 samples were sent to the Laboratory and 115,058 analyses were performed.

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Particular Problems with Illness Statistics

It is necessary to note a problem with statistics on occupational illnesses. There is no feasible way at present to determine a possible cause-and-effect relationship between many illnesses and workplace conditions. Among the reasons for this are the following: First, there may be a very long latency period (as long as forty years in some instances) between exposure to certain toxic substances and onset of effects. Second, employees may change place of employment and occupation many times in a working lifetime. Third, exposures may occur at home, on the job, or elsewhere. Fourth, there may be exposures to a mix of substances, some of which affect the same target organ of the body. Fifth, it may be that life style or heredity, rather than environment, is the causative agent in some cases. Additionally, lack of expertise and experience in diagnosing occupational disease may have contributed to underrecording of work-related illnesses. Insufficient awareness of this problem among employers, employees and the public also may have inhibited the

identification and recognition of many diseases as being Occupational in origin. To look for definitive data, then, on the extent of all occupational illnesses from records kept by employers--or by employees or even physicians in general practice for that matter--may not be realistic.

Because of the difficulties just noted, there are very wide variations in the estimates of chronic and latent occupational illnesses such as cancer. A draft report by the Office of Technology Assessment on health and safety control technologies in the workplace acknowledges this problem, and I quote: "With few exceptions, it is now impossible to know how many human cancers are caused by exposure to a substance." A sample of the studies on the fraction of cancers caused by workplace exposure reveals estimates that range from 23 to 38 percent (in a 1978 study of the Department of Health, Education, and Welfare), to 4 percent (in a June 1981 article in the Journal of the National Cancer Institute).

Having said all this, however, let me go on to state that the illness incidence data which OSHA has, and which are estimated by BLS from its Annual Survey provide a reliable index of recognized occupational illnesses such as dermatitis. The trends in incidence rates of recognized occupational diseases help us learn what actually occurs in the workplace and assist us in carrying out our mission.