July 6, 2004

OSHA Docket Office

Washington, D.C.

RE: Nationwide Site-Specific Targeting (SST-04) Program, and Bloodborne Pathogens Standard; Extension of the OMB Approval of Information-Collection Requirements

General Comments

Data reported to Bureau of Labor Statistics (BLS) must be relevant, current, accurate, complete, and impartial to provide the highest statistical quality. Reporting agencies such as Occupational Safety and Health Administration (OSHA) are required to accurately report the data source, the data collection method, the data received, or entries on reporting forms, written or electronic.

The partnership between BLS and OSHA provides a snapshot picture of health and safety data for employers and employees. The data are used to define the nature and extent of occupational health and safety problems, provide a baseline for use in evaluating efforts to solve existing health and safety problems and improve the health and safety of employees. Although BLS is the principal fact-finding and collection agency for the Federal government, all other agencies issue their own guidelines for data collection. Therefore, the American Association of Occupational Health Nurses (AAOHN) supports OSHA's attempt to reassess the relevance, accuracy, timeliness, and completeness of the statistical data collection and reporting process of Site-Specific Targeting (Directive CPL 02) and Bloodborne Pathogens (29 CFR 1910.1030).

Specific Comments

Site-Specific Targeting Program Docket No. C-08

It appears that the primary purpose of the SST-04 is to develop criteria that will be all-inclusive and allow OSHA to classify worksites for primary or secondary comprehensive safety and health inspections. OSHA's workplace site inspections would focus on those establishments (main or branch sites, etc.) with the highest injury and illness rates. This tactic appears to be appropriate and would help employers recognize problems and develop proactive solutions to prevent future occurrences. However, the established criterion for determining the worksite selection is very detailed and complicated making it difficult to understand.

Part of the criteria is based on Lost Workday Injury and Illness (LWDII) and Days Away from Work Injury and Illness (DAFWII) rates, but in the future, Days Away, Restricted, or Transferred (DART) rates will replace LWDII. Therefore, we question why OSHA is using the LWDII and DAFWII rates to establish the degree of compliance. Since DART is more inclusive of time away from work, the replacement should provide more accurate and complete worksite data.

The Association suggests that OSHA focus more attention to the most common types of injuries/illnesses (data from OSHA log) and related cost, and establishment/industry reporting of injuries/illnesses. OSHA should look at three to five years of data collection for a more comparative history of injury/illness rates as well as establishment/industry rates, citations and improvements, and for indicators for trends analysis.

Bloodborne Pathogens Standard; Extension Docket No. ICR 1218 - 0180 (2004)

The Association applauds OSHA for its proposed action to incorporate the Needlestick Safety and Prevention Act (NSPA) information collection requirements into the Bloodborne Pathogens (BBP) Standard. When the BBP Standard was revised in 2001 to include NSPA, inclusion of the collection requirements would have minimized the extra burden imposed on employers.

Maintaining one OSHA log for all work-related injuries and illnesses, whether needlestick or otherwise, will decrease the burden of collection and reporting for the employer, OSHA, and BLS. Therefore, the Association recommends one OSHA log, which will include necessary data for BBP and NSPA since they ultimately report the same data.

The Association supports OSHA's recommendations to incorporate the NSPA information collection requirements into the BBP Standard. However, having the BBP Standard and NSPA requirements in place, i.e., engineering controls and exposure control plan, will not totally eradicate exposure due to human error and consequently there will always be a need for reporting.

Conclusion

AAOHN is dedicated to improving the health and safety of employees as well as ensuring that the collection and reporting of statistical data concerning the health and safety of the employees is accurate and appropriate. The data are vitally important for targeting prevention and program planning activities and services.

AAOHN appreciates the opportunity to provide input on these issues and we will continue to support efforts that promote safe and healthful work environments. Please feel free to contact us at (919) 966-0979 for clarification or additional information.

Sincerely,

Susan A. Randolph, MSN, RN, COHN-S, FAAOHN

President, AAOHN

cc: AAOHN Board of Directors

Ann R. Cox, AAOHN Executive Director