June 7, 2016
The Occupational Safety Health Administration (OSHA) released a final rule, revising its Recording and Reporting Occupational Injuries and Illnesses regulation on May 12, 2016.
This revision, coming into effect January 2017, requires employers in specified industries to submit the OSHA injury and illness data (which they are already required to send) electronically and make this information publically available. OSHA’s view is that making injury information publicly available will help identify those that are at the highest risk. Unfortunately, the metrics OSHA is using to determine what constitutes as a high risk company is incomplete and likely to result in false assumptions about the level of safety within an organization being made by stakeholders such as investors and prospective employees.
OSHA’s attempt to improve workplace safety has been challenged by a number of influential leaders in the health and safety industry. These individuals share a common belief that this Final Rule will not have the desired impact on safety and are not afraid to express their opinions. Michael Belcher, President of the American Society of Safety Engineers (ASSE), has spoken out against OSHA’s final rule and claimed that it is a “step backward for safety professionals.” Belcher argues that by making injury and illness data public, OSHA is mistakenly encouraging companies to use ineffective lagging indicators as key performance metrics to benchmark their own safety performance. Leaders in the environmental health and safety (EHS) industry have been urging companies to stop using lagging indicator metrics as benchmarks for safety performance, given their inability to provide insight into current safety practices and risk levels of an organization.
Lagging indicators can only provide little insight into past performance and cannot show how a safety program is currently performing. OSHA’s assumption that companies with poor lagging indicator metrics are more risky is not always correct. And, by using lagging indicators to compare or benchmark safety performance, OSHA’s assumptions could mistakenly drive wrong behaviors amongst executives, shareholders and employees.
Let’s take a step back and ask ourselves: how do we determine risk? Determining the level of risk is complicated and cannot be simplified to one metric that can only indicate past, not present performance. Using one lagging indicator without a greater and unrelenting focus on leading indicators is inherently dangerous as it has high potential to leave workers exposed to unidentified or unmanaged hazards which could result in an incident. On the other hand, leading indicators used in a safety management system provide insight into the safety activities or preventative steps companies are enforcing to proactively reduce risk. Where lagging indicators only measure the outputs of a safety management in the past, leading indicators show the effectiveness of the management system operating today. Only because a company has had no incidents to-date, does not mean it operates in a low-risk safety environment.
Consider the following example of two companies: Company 1 – who reported having three minor workplace incidents in 2015 and Company 2 – who reported zero incidents in 2015. While Company 1 did have three incidents last year, they also have a very proactive Safety Director who takes a very hands-on approach to safety. Following the incidents, the Safety Director introduced a cloud and mobile based safety software to support a leading indicator initiative, improve data accuracy and management visibility for making better and more informed decisions. The Safety Director also used the technology to increase communication between the frontline workers and the boardroom with the hopes of improving worker participation.
Although there were three minor incidents last year, the Safety Director is now well equipped with information necessary to prevent these incidents from reoccurring. Company 2, on the other hand, also has a designated Safety Director but only because they are required to have one. The Safety Director does the minimum required to comply with OSHA and takes no additional proactive preventative risk measures. The Safety Director does, however, incentivize zero workplace incidents for his employees and this has led to workers not reporting certain workplace incidents.
If one was to only consider the illness and injury data reported to OSHA, Company 2 would appear to be a safer and better company to work for than Company 1, but do you really think Company 2 is the safer option?
The second problem with the OSHA ruling is that it is requiring companies to electronically submit their safety data when a recent BLR report found that 79% of companies are reporting and managing their internal programs without safety software. This suggests that OSHA is implementing a policy without a foundation to support it.
OSHA has identified two main reasons for making the move to electronic submission: to improve data accuracy and increase transparency so potential new hires, customers and shareholders have the opportunity to research a company’s health and safety when looking for jobs or investment opportunities. While this is great in theory, it is rather ironic that OSHA is moving to fix this issue on a public external level before addressing the fact that these two issues are the exact same ones most companies face internally in their organizations, especially when using the status quo of paper processes to manage their health and safety program. Rather than enforcing a rule which requires safety data to be submitted electronically for public display, it would be better for OSHA to use its resources to encourage companies to embrace technology internally first.
The BLR report also found that a majority of safety professionals believe that increased worker participation can improve safety performance and lead to a decrease in incidents. Technology allows for two-way communication between the on-site staff and the in office employees which can help increase worker participation in safety. Technology also provides a means of collecting more and better safety data such as leading indicators and allows seamless sharing of this information across the company. By encouraging companies to adopt technology internally first, OSHA would be able to collect better, more insightful data from companies which could then be used to enforce real, impactful change.
Although OSHA intends to use this ruling to improve workplace safety, there are major issues with publically displaying ineffective metrics and enforcing electronic submission without the foundation to support it. If workplace safety is to be truly improved, there needs to be a larger emphasis placed on proactive metrics such as leading indicators. Rather than forcing electronic submission and creating external transparency of safety data, OSHA should be encouraging companies to step away from paper processes, and embrace technology and adopt management system standards in order to improve their internal data accuracy and transparency issues before presenting this information to the general public.
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