Employer Compliance with OSHA Requirement to Report Amputations, Updated Findings from a Massachusetts Study

Tuesday, June 6, 2017: 10:50 AM
420B, Boise Centre
Kathleen Grattan , Massachusetts Department of Public Health, Boston, MA
Letitia K. Davis , Massachusetts Department of Public Health, Boston, MA
Michael Fiore , Massachusetts Department of Public Health, Boston, MA
Elise Pechter , Massachusetts Department of Public Health, Boston, MA
James Laing , Massachusetts Department of Public Health, Boston, MA

BACKGROUND: Work-related amputations are serious, sentinel occupational health events; many of the hazards that lead to these injuries are well-understood and easily prevented. The MA Department of Public Health (DPH) has statutory access to work-related amputation reports and identifies cases through workers’ compensation (WC) claims and other data sources. Since January 2015, OSHA has required employers in federal OSHA states to report all severe work-related injuries, including amputations. We compared our sentinel case reports of amputations with those reported to OSHA by employers to assess employer compliance with the new regulation and to understand factors influencing reporting in the first 18 months after the regulation went into effect. This analysis expands on earlier findings from a pilot study.

METHODS: The Occupational Health Surveillance Program (OHSP) receives weekly reports of WC lost time (≥ 5 days) claims for reportable conditions, including work-related amputations. Amputations occurring in the private sector between 1/1/15 and 6/2/16 (study period) were identified using the WC nature of injury code. OSHA maintains a database (OSIR) of all severe injuries reported by employers. For this study, OSHA provided DPH with a file of all amputations reported to OSHA by MA employers with date of injury/event during the study period. The OHSP and OSIR files were linked using date of injury/event, with manual review of employer information to generate a total count of unique amputation cases. Percent of both total cases and the most serious (WC) cases that were reported to OSHA by employers were computed overall and by establishment size and industry sector.

RESULTS: There were 175 unique amputations identified. Of these, 53% were reported by employers. Twenty-two percent were identified by both OHSP and OSIR reports; 47% by OHSP reports only and 31% by employer reports only. Employer reporting of amputations varied by industry with the highest percentage occurring in the Construction industry sector. Mid-sized and smaller employers (< 50 employees) reported a higher percentage than their larger counterparts. Restricting cases to the most serious (cases identified through WC), employers filed 38 of 120 (32%) with OSHA.

CONCLUSIONS: Findings suggest substantial underreporting of work-related amputations by MA employers, consistent with previous studies in MA and other states. This study demonstrated the feasibility of using sentinel data to assess employer reporting patterns that may inform OSHA outreach, compliance assistance, and enforcement priorities, and provided new insights about the use of OSIR data for these purposes.