The head of Norfolk Naval Shipyard's safety division has drawn union criticism for blaming employes for an increase in injuries and encouraging supervisors to discipline careless workers.

"We will never be able to reverse the upward trend of employes injuring themselves or other employes as long as we, the supervisors, keep calling their disobeying of written or oral orders 'accidents,' " Mark Davis, director of occupational safety and health, said in a memo distributed this month.

"The word 'accident' implies that no one was at fault," Davis said in the memo. "But the truth of the matter is that, in most cases when employes injure themselves or their fellow employes, they have violated written or oral policies or procedures."

Union officials said the memo is an attempt to discourage employes from reporting injuries to keep official numbers down. Shipyard spokesman Joe Law said the memo was not intended to intimidate.

The shipyard experienced its safest year in this decade when injuries and illnesses fell to 22.1 per 100 man-years during 1986. That record improved again during the first six months of 1987, when the yard reported an average of 18.65 injuries and illnesses per 100 man-years. However, when the rate jumped up in the third and fourth quarters to more than 22 injuries and illnesses per 100 man-years, officials became concerned, Law said.