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

Abstract Background The Occupational Safety and Health Administration (OSHA) implemented a new standard in 2014 requiring employers to report nearly all work‐related inpatient hospitalizations within 24 h of the event. We examined the characteristics of the injured workers who were reported and the compliance of Michigan employers with the regulation. Methods From 2016 to 2018, we compared reports of acute nonmotor‐vehicle work‐related injuries and illnesses from two independent datasets, employer reports to OSHA and the Michigan Multi‐Source Injury and Illness Surveillance System (MMSIISS) which collects injured worker hospital records from the 134 hospitals in Michigan. We matched records from employer reports to OSHA with the MMSIISS by employee's first and last name, company name, date of injury/illness, and type of injury/illness. Results We identified 2887 workers hospitalized with severe injuries/illnesses from 2016 to 2018 in Michigan; 1260 workers were reported by employers to OSHA and 2238 workers were reported by hospitals to the MMSIISS. There was an overlap of 611 workers reported in both systems, while 649 workers were only reported by employers to OSHA and 1627 workers were only reported by hospitals to the MMSIISS. Employer compliance with the regulation over the 3 years showed a nonsignificant increase; from 42.0% to 43.6% to 45.0%. Fractures were the most frequent type of injury (1238, 42.9%), then head injuries, including skull fractures (470, 16.3%). The median length of hospital stay was 3 days. Manufacturing (709, 25.5%) and construction (563, 20.3%), accounted for the greatest number of hospitalizations. Employer‐reported cases to OSHA significantly undercounted hospitalized workers in agriculture, forestry, fishing, and hunting; construction; finance and insurance; real estate and rental and leasing; administrative and support and waste management and remediation services; arts, entertainment, and recreation; accommodation and food services; and other services except public administration. Companies with 250 or more employees were significantly more likely to comply and small companies with 10 or fewer employees were significantly less likely to comply with the reporting rule. Enforcement inspections at 465 of the workplaces where a hospitalization had occurred resulted in $1,017,835 in fines and identified 608 violations. Of the 465 inspections, 246 (52.9%) of the employers had not corrected the hazard before the inspection. Conclusions This study identified that workers sustained severe injuries and illnesses on the job and that over half of the companies where a worker suffered an injury/illness leading to hospitalization were not in compliance with OSHA's reporting regulation. Furthermore, at the time of an inspection 1–5 months later, 50% of the companies had not corrected the hazard causing the hospitalization. Improvement in the reporting of work‐related injuries/illnesses that result in hospitalization will identify more ongoing hazards in the workplace and improve where to focus preventive actions.

Studies have found that employers vary greatly in their compliance with occupational injury and illness regulations involving reporting and recordkeeping. 1,2 In the state of Washington, researchers found that 90% of employers failed to correctly record work-related injuries in the Bureau of Labor Statistics Survey of Injuries and Illnesses (BLS SOII). 3 In a survey of four states, researchers found that less than half of employers that were required to maintain an injury and illness log did so. 4   Using the first 3 full years of data, 2016 to 2018, we matched the hospitalized injuries and illnesses reported by the employer to OSHA to the hospitalized injuries and illnesses reported to the MMSIISS, by employee first and last name, company name, injury date, and type of injury. Allowance was made for slight differences in the elements used to match the workers between the two systems. For example, one reporting system might list a temporary employment agency as the employer while the other might list the host employer. In some cases, the company's parent name was listed in one system while it was listed under its DBA name (doing business as). In other cases, the hospital did not have the company name but given the other details   Table 1]) and LOS (Table 3), which is not available in the employer reports to OSHA but is only available in the MMSIISS. Where information is available for hospitalized workers regardless of which system in which they were reported, the results compare employer compliance of reporting to OSHA with the total number of 2887 hospitalizations from 2016 to 2018 for injury type (Table 2), industry type (Table 4), and company size ( Table 5).
The injured workers ranged from 15 to 92 years of age. The average age of the 2238 hospitalized workers reported to the F I G U R E 1 Overlap of two reporting systems for 2887 severe work-related injuries and illnesses: Employer reports to OSHA and hospital reports to the Michigan Multi-Source Injury and Illness Surveillance System (MMSIISS), Michigan 2016-2018. *An additional 257 injuries/ illnesses reported by employers to OSHA were not valid (e.g., motor vehicle crashes, emergency department visits only). OSHA, Occupational Safety and Health Administration.
MMSIISS and the 611 that were also reported by employers to OSHA were similar; in the MMSIISS, the overall average age was 44.4 years for males and 50.8 for females (Table 1). For those reported by employers to OSHA, the average age was 43.9 years for males and 50.0 for females. There was no statistical difference in employer compliance to report by the age of the injured worker. Reported hospitalizations more often occurred among men than women, 81.1%    were not issued any citations (Table 7). There were nine inspections associated with employer reports to OSHA that were cited for a violation of the reporting rule. In those cases, the employer reported the injury to the OSHA reporting system after the inspection began.
Eight of the inspections were initiated due to a referral from an entity other than the employer and one company was a program-related inspection.
Five narratives of injuries requiring hospitalization where an enforcement inspection was conducted.    issued a serious citation directly related to the injury for failure to ensure that a highway truck is not boarded before its brakes are set and no less than two wheels are blocked or restrained by other mechanical means to prevent the truck from movement. This hazard was still present at the time of inspection. This injury was identified only through the MMSIISS and had not been reported by the employer to OSHA.
An employee was assisting a coworker with moving a granite slab that weighed approximately 1000 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; they were issued a serious citation directly related to the injury for 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. This injury was identified only through the MMSIISS and had not been reported by the employer to OSHA. The company was cited for not reporting.
An employee was cutting branches off a tree. One of the branches that he was cutting fell on top of the employee, pinning him to the ground. The employee was hospitalized for multiple injuries.
The company was inspected 115 days after the hospitalization and issued a serious citation directly related to the injury for failing to ensure the climbing employee remained tied in until the work is completed, and he returned to the ground. This hazard was still present at the time of inspection. This injury was identified only through the MMSIISS and had not been reported by the employer to OSHA.
An employee was engaged in a roofing activity. The employee unhooked his harness, lost his balance and fell 25 feet to the ground below. The employee was hospitalized for a fractured pelvis and tailbone. The company was inspected 65 days after the hospitalization and issued a serious citation for failure to provide a training program for each employee who might be exposed to a fall hazard.
The company was given 30 days to correct the hazard. The company also was cited for four other-than-serious violations, including failure to have an accident prevention program, and failure to record recordable injuries and illnesses on the OSHA 300 injury and illness log. This injury was identified only through the MMSIISS and had not been reported by the employer to OSHA. The company was cited for not reporting.

| CONCLUSION
Employer compliance with the reporting regulation could be examined because of the MMSIISS, which is a unique surveillance tool based on the requirement in Michigan that hospitals report work-related injuries and illnesses. We used the MMSIISS data to understand the characteristics of the workers who were hospitalized for acute work-related injuries and illnesses and to evaluate employer T A B L E 6 (Continued)  There are a few potential limitations. It is possible that some of

ACKNOWLEDGMENTS
This study was supported by the National Institute for Occupational Safety and Health, under Cooperative Agreement U60-OH008466.

CONFLICTS OF INTEREST
The authors declare that there are no conflicts of interest.

DISCLOSURE BY AJIM EDITOR OF RECORD
John D. Meyer declares that he has no conflicts of interest in the review and publication decision for this article.

AUTHOR CONTRIBUTIONS
Ms. Mary Jo Reilly compiled the data and wrote the first draft of the manuscript. Dr. Kenneth D. Rosenman provided the concept idea for the manuscript and contributed substantially to the writing and edits.
Dr. Ling Wang was responsible for the statistical analyses as well as edits to the manuscript. All three authors contributed substantially to the revised manuscript.

DATA ACCESSIBILITY
Research data are not shared.

ETHICS APPROVAL AND INFORMED CONSENT
This public health activity was considered exempt by the Michigan State University Human Subjects Board.

DISCLAIMER
The contents of the manuscript do not necessarily reflect the views of the funding agency.