Usefulness of BLS Survey to U.S. Semiconductor Industry

In evaluating the usefulness of the BLS recordkeeping system with respect to a particular industry, it is important to understand the limits of that system. 

Firstly, the system is sustained by the thousands of the nation s employers who are required (by OSHA regulation) to maintain the OSHA-200 log and OSHA-101 (or equivalent form) supplemental data form. Despite OSHA s view that the records provide employers with a valuable resource for analyzing the work injury and illness experience of their work force, many employers view the system as an encumbrance or, worse, a required nuisance. This assessment of the system on the part of employers is unfortunate, but understandable. The reasons for this viewpoint by employers are many and are varied. It is sufficient in this context simply to understand that the system has been maintained over the past two decades by individuals who have little at stake in its success and who would care little if it completely failed. The fact that organized labor has, likewise, placed little importance on increasing the effectiveness of the OSHA/BLS recordkeeping system simply underscores this perspective. Hence, the roots of the present system provide little support other than what is mandatorily required by OSHA regulation. For this reason, only the required minimal effort is expended by employers to maintain the system s required records. Even that minimal effort often falls short in maintaining the detailed supplemental case form (OSHA-101 or equivalent). 

Thirdly, OSHA recordkeeping mechanics tend to complicate what is, in essence, really a very simple procedure. Requirements for (i) recording distinctions between injuries and illnesses on the OSHA-200 log, (ii) for placing X s in various columns on the log and (Hi) for carrying forward individual sheet totals of cases and work loss days to aimual totals are fraught with possibilities for errors. 

From this perspective, it may seem incongmous that these records could be of prime, practical significance to estimating the work injury and illness experience of the U.S. semiconductor industry, much less the nation s woik force. However, because the BLS recordkeeping system is considered credible by the federal and individual state governments, and because it is used both to target OSHA inspections and to determine the work injury and illness experience of employees in individual workplaces, it must be included in any employer s plan of injury and illness surveillance. 

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