In response to a June 21 letter from the American Trucking Associations (ATA), OSHA has issued an interpretation on how employers should record driver injuries and determine incident rates, according to Stuart Flatow, director of occupational safety and health for ATA.
ATA asked questions on how employers should record and report total hours worked for truck drivers and the recordability of certain injuries and illnesses occurring to over-the-road truck drivers. The issue of recordability and hours worked is especially significant for motor carriers due to the Site-Specific Targeting Plan, which prioritizes worksite-specific OSHA inspections based on injury and illness data submitted to the agency by employers.
Under a 1995 rule, selected employers must respond to OSHA's request for site-specific injury and illness data to the agency via an OSHA-supplied data form. The data submitted by employers is taken directly from OSHA Form 200 and includes, among other things, total hours worked by employees. This information is needed to determine injury and illness incidence rates per 100 full-time employees based on a 40-hour workweek over a 50-week period.
Because truck drivers usually do not work a standard 40-hour workweek, many motor carriers have unknowingly inflated the incidence rates they have submitted to OSHA. This artificial inflation can lead to increased inspections and to the perception that driving a truck is a "high hazard" occupation.
According to OSHA's March 6 response letter to ATA, motor carriers need to determine the actual total number of hours worked by a driver vs. those hours spent in normal living activities such as eating and sleeping. In addition, OSHA stated that injuries to drivers that occur in sleeper berths or while showering at rest stops would not be considered recordable injuries.
In recognizing that over-the-road truck drivers present a unique situation, OSHA has included a worksheet for employers in the trucking industry to fill out to determine driver incidence rates. Those worksheets will be included with the data collection forms that OSHA sends to selected employers. The agency does not require that the worksheets be submitted with the data forms, but suggests that they be used as a tool to determine incidence rates.