Characterization of the Selective Recording of Workplace Exposure Measurements into OSHA's IMIS Databank

Objectives: The Integrated Management Information System (IMIS) is the largest multi-industry source of exposure results available in North America. In 2010, the Occupational Safety and Health Administration (OSHA) released the Chemical Exposure Health Data (CEHD) that contains analytical results of samples collected by OSHA inspectors. However, the two databanks only partially overlap, raising suspicion of bias in IMIS data. We investigated the factors associated with selective recording of CEHD results into the IMIS databank. Methods: This analysis was based on personal exposure measurements of 24 agents from 1984 to 2009. The association between nine variables (level of exposure coded as detected versus non-detected (ND), whether a sampling result was part of a panel of chemicals, duration of sampling, issuance of a citation, presence of other detected levels during the same inspection, year, OSHA region, amount of penalty, and establishment size) and a CEHD sampling result being reported in IMIS was analyzed using modified Poisson regression. Results: A total of 461 900 CEHD sampling results were examined. The proportion of CEHD sampling results recorded into IMIS was 38% (51% for detected and 28% for ND measurements). In the models, the detected sampling results were associated with a higher probability of recording into IMIS than ND sampling results, and this difference was similar for panel versus non-panel samples. Probability of recording remained constant from 1984 to 2009 for sampling results measured on panels but increased for sampling results of single determinations of an agent. Some OSHA regions had probability of recording two times higher than others. No other variables that we examined were associated with a CEHD sampling result being reported in IMIS. Conclusions: Our results indicate that the under-reporting of sampling results in IMIS is differential: ND results (especially those determined from the panels) seem less likely to be recorded in IMIS than other results. It is important to consider both IMIS and CEHD data in order to reduce bias in evaluation of exposures in workplaces inspected by OSHA.