Newsletter | PROSAFE Solutions | Atlanta Safety Consultants

Moderating the use of Discipline in a Positive Safety Culture

Organizations benefit from having clear and concise ways to address common issues like tardiness, absenteeism, theft, substance abuse, violence, harassment, and other violations of company standards.   Discipline is often used to accomplish this.   In a document published by the Society for Human Resources Management, discipline is described as a way to “address conduct issues such as poor work performance or misconduct to encourage workers to become more productive workers and to adapt their behavior to company standards and expectations.”    Also if discipline is applied consistently and documented accordingly, this can help defend organizations against grievances, EEOC charges, OSHA whistleblower allegations and wrongful termination lawsuits.  That’s all good.  And it might seem intuitively obvious to include unsafe acts, as behaviors worthy of discipline.  But after carefully analyzing numerous safety-related disciplinary events in light of current research about human performance, it’s become increasingly apparent that using discipline as a reaction to safety infractions often does more harm than good.

The rationale for disciplining workers for safety infractions often follows this thought process: 1) the worker broke a safety rule or did something unsafe, 2) the worker was aware of the safety rule, 3) the worker’s actions had, or could have had, serious consequences, and 4) other workers have been disciplined for similar infractions.    This approach isn’t much different than disciplining for other fundamental workplace rules.  But before rushing to judgment, there are some critical issues that must be understood in order to use discipline effectively in a positive safety culture.

Issue # 1: Discipline is punitive  

Despite assurances from some well-meaning Human Resource professionals that the purpose of discipline is not to punish or embarrass workers, traditional discipline is still punitive in nature.   Common forms of discipline – typically doled out in a progressive fashion – include counseling, written warnings, suspensions and termination.  Depending on the circumstances, discipline may also include a demotion or job transfer.  Do any of these consequences sound positive to you?

The word discipline has been closely associated with punishment since the 13th century when it was used to describe chastisement of a religious nature.  The Oxford English Dictionary describes the verb discipline as follows: To punish, chastise, or reprimand (a person), esp. with the intention of correcting or altering subsequent behavior.  This is closely related to the notion that crime must be followed by punishment.  After all, without punishment, there would be chaos and disorder. 

Unfortunately, far too many workers end up being punished for safety “crimes” that were either a result of simple human error and/or system induced.  The reason for this is rooted in our reactions to failure.   When an unsafe act or outcome occurs, a natural reaction for the observer is to focus on what the worker should have done or could have done, rather than trying to understand why he/she acted in the way they did.   And when trying to understand why somebody did something unsafe, research shows that observers are more likely to ascribe (and emphasize) causes to internal or personal factors, rather than external or situational factors.   This is especially true in Western culture where we place great emphasis on personal responsibility.  These tendencies perpetuate a superficial understanding of human error and can lead us to blame the worker simply because he/she did something unsafe.

Issue # 2: Disciplining human error is an exercise in futility

Human error is inadvertent.  It’s where a "planned sequence of mental or physical activities fails to achieve its intended outcome” (Reason).    To understand why punishment doesn’t work, let’s begin by describing three basic types of human errors: slips, lapses and mistakes.

A slip can be thought of as an unintended or unplanned action. For example, over-tightening a bolt or turning a switch the wrong direction.  Slips are considered “errors of commission” that usually occur when a simple, routine physical action goes awry.   Even the most skilled and experienced people are susceptible to these inadvertent errors.   A lapse is an “error of omission”.  For example, missing a step in a lockout/tagout procedure or forgetting to unplug a heater.  As tasks become more repetitive and familiar, they can be performed with less conscious attention and the easier it is for the mind to be occupied with other thoughts.  Slips and lapses are execution errors, and they are quite common.  In your everyday activities you can expect to make four to five inadvertent execution errors per hour.  

Consider delivery drivers who are required to operate commercial trucks and make timely delivery of goods to customers on specific routes.  For some drivers in the industry, it’s not unusual to make 50 – 75 stops a day.  Every time the truck is parked, the driver is responsible for securing the vehicle and applying the parking brake so the vehicle doesn’t roll away.  Is it conceivable that the driver might forget to put the brake on?  Of course it is.  And it has led to numerous vehicle accidents all over the country.  This kind of mental lapse has nothing to do with skills, knowledge judgment or motivation.   You simply can’t prevent lapses by disciplining drivers.   The only proven way to minimize these types of errors are through controls like task and fatigue management, reminders, checklists, alarms or warning devices.

Another type of human error is the mistake, when somebody does the wrong thing believing it to be right. Mistakes result from failures in thinking, where the worker takes action as planned using deliberate thought processes, but it doesn’t pan out.  For example, when a worker tries to apply a rule that was successfully used before in a similar situation.   Or when a worker lacks expertise for a given situation and has to analyze and plan based on limited time and resources. Humans are prone to mistakes when tasks become more difficult and complex.

Disciplining workers for committing errors will not prevent the recurrence of slips, lapses and mistakes.  Human error is not a violation. So don’t treat it as such.

Issue # 3: All violations are not the same

Violations occur when a worker knowingly deviates from safe operating procedures.   Violations are certainly the most disturbing of all human failures due to their very nature as deliberate actions that contradict established protocols.    For example, taking shortcuts or failing to follow safety procedures.  On the surface, a violation might seem deserving of discipline. After all it was intentional!  And the worker knew better!  But in most cases, very few people are culpable or malicious in their intent. Most are blameless and were actually trying to do their best in an imperfect system.  As it turns out, the majority of safety violations are system-induced.

Do you remember Domino’s famous “30 Minutes or It’s Free” guarantee?  Introduced in 1979, this slogan was familiar to millions of people looking to have hot, fresh pizza delivered to their doorstep.  It became a popular slogan and a cornerstone of success for Domino’s.  But by the summer of 1989, after a 17-year old delivery driver lost his life in a fatal crash after skidding off a wet road, the press picked up on the story and many periodicals began publishing stories about their drivers’ accidents and questioning the safety implications of this policy.  After dozens of lawsuits were filed by relatives of workers killed while delivering pizzas, many critics, including the National Safe Workplace Institute, urged Domino’s to abandon their 30-minute promise.   An underlying presumption was that franchise operators and their drivers faced pressure to deliver pizzas, thus inducing them to take risks while driving, like speeding or running stop signs. 

The reality is that modern workers face enormous challenges in today’s workplace.  Factors like time pressure, peer pressure, fatigue, workload, task complexity, suitability of tools and equipment, and organizational influences play a role in shaping worker behaviors.  It’s shortsighted to discipline workers for safety infractions without first considering how their decisions and actions made sense to them, given the circumstances that surrounded them. 

For example, let’s say we have an hourly worker who has been instructed to change a high-bay light bulb over a production line.  The production line is going to start up in 30 minutes and the light bulb is critical for conducting quality inspections.   In this case, the proper procedure calls for the use of a man-lift to reach the light bulb.  But unfortunately, the man-lift is broken (and won’t be fixed anytime soon due to budgetary concerns).  To avoid delaying the production process, the worker decides to use a forklift and a makeshift platform.   This is an example of a situational violation, where the worker took actions deemed necessary to get the job done.  It wasn’t done for personal gain.   The lack of personal gain is a key difference between safety violations and other types of violations.

Issue #4: Discipline creates disengagement and mistrust

Using cookbook disciplinary responses to unsafe acts and outcomes without adequately diagnosing the behavior and accounting for system influences will undermine efforts to produce workers who are engaged and committed to the goals of the organization.   From the results of thousands of employee surveys and personals interviews, we’ve also found that that using discipline in this fashion fosters mistrust.  When discipline is used as punishment for safety errors this can lead to a “cycle of blame” which is characterized by reduced trust, less communication, and less managerial awareness of jobsite conditions.  As a result, latent organizational weaknesses persist which perpetuate more errors.

Using discipline as punishment for safety violations or accidents isn’t much different.  When a serious accident occurs it is almost always attributed to an unsafe act or condition that immediately precedes the failure. However, these events are generally not the result of a single cause or individual action.  The cause is usually rooted in underlying latent conditions or organizational weaknesses that allow the failure to occur.  Latent conditions are often not identified in traditional accident investigations. As a result, actions are taken against a culprit or “safety violator” while allowing latent conditions to continue to exist.   Punishing people for system induced violations is both unjust and retributive.

The mere fact that an accident can be behaviorally prevented is not sufficient grounds to conclude that behavior is the root cause of the accident.

Issue # 5: Discipline may be considered discriminatory

According to OSHA, reporting a work-related injury or illness is a core worker right, and retaliating against a worker for reporting an injury or illness is considered illegal discrimination.  OSHA has reiterated their position that incentive programs and disciplinary programs may discourage workers from reporting injuries and that this can constitute unlawful retaliation under Section 11(c) of the OSH Act.   Below are some of the practices that OSHA lists as potentially discriminatory:

  • Disciplinary actions against workers who are injured on the job, regardless of the circumstances surrounding the injury.
  • Disciplinary actions for violations of a safety rule, if it is used as a pretext for discrimination against a worker for reporting an injury or illness. Compliance Officers and Whistleblower Investigators are directed to focus on whether the employer consistently monitors compliance with the safety rule in the absence of an injury and whether it uniformly disciplines for violation of the safety rule in the absence of injury. If discipline is issued only when a worker is injured, such disciplinary decisions will be considered suspect.
  • Programs that intentionally or unintentionally provide workers with an incentive not to report injuries or illnesses such as rewarding workers with prizes or bonuses if the workers have not been injured over a given period of time (e.g. safety bingo). OSHA's position is that if the effect of an incentive program is great enough to dissuade a reasonable worker from reporting a work-related injury, the employer may be found to have unlawfully discriminated against a worker.  Instead, OSHA encourages employers to develop incentives that promote worker participation in safety-related activities, such as identifying hazards, participating in the investigation of accidents, or serving on a safety committee.

Issue # 6: Terminating experienced workers can decrease safety

The most extreme form of discipline is termination.  This can have a toxic effect on an organization, especially when severing experienced workers.  Studies show that injury rates decline with job tenure and that newly hired workers are more likely to be injured than those who have been on the job for longer periods of time.   In a major study involving 58,000 workers over a period of six years, this was shown to be true in all age groups and for all job tenures.  So when an experienced worker is fired and has to be replaced with a new worker, chances are that new worker will be more likely to be injured.  Especially during the first six months.

Several years ago, one of our clients in the transportation industry terminated a driver who had experienced a minor collision due to a mental lapse.  The collision could have been disastrous, but fortunately only minor property damage resulted.  The driver, an experienced veteran, had an excellent safety record with only the one blemish.  But he was determined to have “violated a safety rule” and the management team upheld his termination.  He was then replaced with a new, less-experienced driver, a driver that – according to the organization’s own data – was four times more likely to be in an accident than his predecessor. 

 

Using Discipline in a Positive Fashion

By reflecting the social and cultural underpinnings of an organization, discipline defines the relationship between workers and management.   If this relationship is not built on trust, mutual respect and fairness, then the safety system will be adversely affected.  

1.  Become a learning organization.  Before administering discipline for unsafe acts and/or accidents, seek first to understand.  Take the time to diagnose what happened before reacting. This may require a shift in thinking in order to overcome our natural tendencies to attribute personal factors as the reason for unsafe acts which often leads to blame.  Learn from mistakes; don’t try to punish them out of the system by blaming your workers.  As Sydney Dekker says, you can learn or you can blame. You can’t do both!

2. Use a methodical process to determine culpability.   A good starting point is to use James Reason’s “substitution test” which asks the question “would other workers with similar experience and in a similar situation and environment have behaved in the same manner as the worker being evaluated?”  If the answer is most likely “yes”, then punishment is not the appropriate response.   Another way to administer the substitution test is to ask the worker’s peers “given the circumstances that prevailed at the time, can you be sure that you would not have committed the same or similar type of unsafe act”. If the answer is most likely “no”, then punishment is inappropriate.   Other questions you can ask to determine culpability are as follows:

  • Have work rules been effectively communicated?
  • Were the rules and procedures workable and correct?
  • Was the worker adequately trained and coached?
  • Did the worker knowingly violate rules or procedures?   
  • Was the worker’s action for personal gain or organizational gain?
  • Was the associate experienced in this work?

3. Make your disciplinary program “Pro-Worker”.   If you’ve determined discipline is the appropriate response, consider a “pro-worker”, non-punitive approach.  Organizations such as Frito Lay, GTE/Verizon, and Tampa Electric have utilized these non-punitive approaches with positive outcomes.   Namely, problems get resolved favorably without all of the headaches often associated with traditional discipline like stress, reduced trust, reduced communication, absenteeism and turnover. The premise behind this approach usually begins by helping the worker identify a performance gap and coach and counsel them in a positive, constructive fashion.  If that fails, the worker is suspended, with pay, for one day to give him/her an opportunity to reflect on their behavior and respond accordingly.  At that point, either they make the necessary changes to improve their performance or leave the company.

 

Mike McCarroll, CSP

President & CEO

PROSAFE Solutions, Inc.

Villa Rica, GA

 

Michael Belcher, CSP

VP Risk and Safety

DS Services of America, Inc.

Atlanta, GA

 

Reference List

Bena, A & Giraudo, M & Leombruni, R & Costa, G.  Job tenure and work injuries: a multivariate analysis of the relation with previous experience and differences by age.

Berg, Eric N. (1989) Fight on Quick Pizza Delivery Grows  Retrieved from http://www.nytimes.com/1989/08/29/business/fight-on-quick-pizza-delivery-grows.html?pagewanted=all

Goldberg, Allan T. (2012) Is Firing an Effective Safety Tool?  Professional Safety

Grote, Dick (2006) Discipline Without Punishment

Holden, Richard J. (2009) People or systems? To blame is human. The fix is to engineer.  Professional Safety

McDonald, Chris (2011). Death by Pizza Delivery: Domino’s Korea.  Retrieved from https://businessethicsblog.com/2011/02/10/death-by-pizza-delivery-dominos-korea/

McCarroll, Mike (2016) Catch the Drift - How Organizational Drift Leads to Accidents. 

Holden, Richard J. (2009) People or systems? To blame is human. The fix is to engineer.  Professional Safety

Reason, James (1990) Human Error

Reason, James (1997) Managing the Risks of Organizational Accidents

Society for Human Resources Management (2014) Progressive Discipline Policy

The Power of Positive Reinforcement

During a recent safety leadership training session for a beverage company in New York, one of the managers shared an insightful story. He was a new manager that had just taken over a branch in the Bronx. He stated that in his first week he noticed that out of several drivers, only one was doing his pre-trip vehicle inspection. Despite the fact that a pre-trip inspection is required, the other drivers were simply loading their trucks and hitting the road to make deliveries.

The new manager said that in his first safety huddle, he said nothing to the drivers who were not conducting inspections but highly praised the one who did a thorough job. He said the initial reaction from the other drivers was to make “kissing sounds” at the guy being praised to make fun of the fact that he was kissing up to the boss.

Then, a strange thing happened. He said the next day, he noticed that several other drivers were inspecting their trucks. At the next huddle, he highly praised those drivers while saying nothing to the others. He stated that within a month of the initial safety huddle, all of the drivers were inspecting their trucks.

This story perfectly illustrates the power of leading people through positive reinforcement. Leadership has been defined as “the ability to enlist the willing cooperation of people towards a desired goal”. This manager was able to change the behaviors of his drivers not through force, but by reinforcing the desired behaviors.

Mike McCarroll, CSP

President & CEO

Hot Weather Safety

Heat is the number one weather-related killer in the United States, resulting in hundreds of fatalities each year. In August 2003, a record heat wave in Europe claimed an estimated 50,000 lives.

Workers exposed to hot and humid conditions are at risk of heat illness, especially those doing heavy work tasks or wearing protective clothing and equipment. Some workers might be at greater risk than others if they have not built up a tolerance to hot conditions. Severity of heat disorders also tends to increase with age.

NOAA issues Excessive Heat Warnings/Advisories when an excessive heat event is expected in the next 36 hours. Warnings are based upon the Heat Index below:

 

The Heat Index does not account for impermeable clothing. Workers wearing impermeable clothing will be at risk at lower temperatures.

When the body heats too quickly to cool itself safely, or when you lose too much fluid or salt through dehydration or sweating, your body temperature rises and heat-related illness may develop.

Heat illnesses range from heat rash and heat cramps to heat exhaustion and heat stroke. Heat stroke can result in death and requires immediate medical attention.

Prevention Best Practices

Planning/Training

  • Plan for covered shade areas for rest and lunch breaks
  • Train employees in recognizing heat stress & dehydration and stress early self reporting of symptoms

Water

  • How much water someone needs is highly variable but one rule of thumb is to drink about a cup of water every 20 minutes.
  • A good rule of thumb is to drink as many ounces of water as you weigh in pounds every day. (A 150 pound person should drink 150 ounces of water per day)
  • Instruct employees to avoid alcohol or liquids containing large amounts of sugar

Rest/Shade

  • Allow employees to spend time in air conditioned offices or in shade during breaks and lunch
  • Workers who are new to working outdoors in the heat or have been away from work for a week or more may need to gradually increase workloads and take more frequent breaks. Some companies use a 6, 8, 10 hour policy for new hires where they work 6 hours the first week, 8 the next and so forth.
  • Researchers have concluded that a fan may not always be helpful, especially in temperatures over 95º. A fan may be helpful when not directly aimed at a person in temperatures lower than 95º.

OSHA Potential Use of General Duty Clause

According to a memo issued in July, 2012, OSHA may consider it a General Duty Violation where the employer is aware of heat related dangers but has not taken protective actions to provide workers with, at a minimum, water, rest and shade.

Use of General Duty Clause may be considered when:

  • Workers exposed to Heat Index at or above danger zone
  • Workers outside most of the day or during heat of the day when NOAA has issued a heat advisory
  • Workers have complained about heat or are showing signs and symptoms of exposure
  • Employer indicated they are aware of the hazard by providing water but not rest or shade

Resources:

http://www.noaawatch.gov/themes/heat.php

http://www.epa.gov/heatisland/about/heatguidebook.html

http://www.osha.gov/SLTC/heatillness/index.html

 

Get REAL About Risk Taking

 

On any given job it is typical to hear safety people and supervisors bemoan the “stupid, careless” employees that keep getting hurt in the workplace. The solution often is to “weed out” the more “accident prone” employees.

The problem with this method is that the new employees often seem to be no different and the cycle goes on.

People take risks, not because they lack intelligence are careless or want to get hurt. They take risks because they truly believe that nothing bad will happen to them by doing so.

 

Here are some simple truths to ponder:

 

1. All humans have some degree of risk taking potential.

Can you honestly tell me you never exceeded the speed limit or coasted through a stop sign?

 

2. The more times you take a risk, the less you believe you will be hurt.

Were you scared the first time you climbed on a roof or a really tall extension ladder? How about the 50th time? The only thing that changed was your perception. The risk stayed the same.

 

3. If a task is done frequently, it is normal human behavior to look for a way to take shortcuts to do the task.

If we allow the shortcut to continue it becomes the new procedure over time and will be eventually taught as the way to do the job. We actually reward the risk taking sometimes by praising the employee for their increased productivity.

 

4. Discipline/punishment will only stop the behavior while you are watching; it won’t change the way they do the job.

To change behavior long term it must modeled by management and praised/rewarded. We (management) must set the example and lead by our behavior.

 

5. Employees will do what they think their immediate supervisor wants.

If the boss does not wear PPE, the employee won’t either. If they think the boss wants them to take shortcuts to “get er done”, they will.

 

6. How much risk taking is considered acceptable in your workplace is influenced by the frequency of the production/safety messages received.

Managers are often shocked to find out their employees truly believe that management wants them to do “whatever it takes” to get the job done. After all, the manager attended last months safety meeting and told them that safety is number one!

 

7. Our cultural background can make us more likely to take risks.

Examples of this can be the macho construction culture, specific trades, i.e. ironworkers or new immigrants who come from a non-safety culture.

 

 

O, K. so now I know that my employees are all likely to take more risk than I want them to in the workplace. What can I do to change that? Well, first you must convince the employee what is expected of him/her in this workplace. Here are some ways to do that:

1. Provide an effective, “hands on”, interactive new hire orientation that clearly communicates the expectations. Sticking a videotape in the TV or handing them a list of rules will not do the job. A management representative must verbalize and impress on the employee what behavior the company truly wants. By management, I mean someone other than safety. Safety people are expected to talk about safety. What matters is what do the managers want.

2. Reward what you want repeated. Focus on observing for safe behavior rather than unsafe behavior. This is more difficult than it sounds and you will need to train employees and supervisors in this technique.

3. Train supervisors in leadership for safety. This should include how to provide effective feedback and reinforcement. If leaders are not modeling the behavior you want, employees will not do it either.

4. Dramatically increase safety communications. Here is a test you might want to use to determine what messages are being received in your workplace: Plan to spend at least a half-day in the work environment. Bring a clipboard. Announce to everyone you are there just to observe and learn more about the way the work is done or count the number of concrete trucks arriving, etc. Plan to observe only, no corrections or discipline. (If something needs immediate attention have someone else tend to it.) On your clipboard, draw a line dividing a piece of paper in half. Every time you hear a message that relates to safety put a checkmark on one side of the line. Every time you hear a message that relates to production put a checkmark on the other side of the line.

Some companies require that no meeting of three or more employees take place without starting the meeting with safety topics. In the beginning, it is necessary to force the communication to the point that it seems overdone. It won’t be. The messages only count if they come from production, not safety staff.

5. Develop an effective root cause process. In order to have a strong safety culture, you must determine the root cause of unsafe behavior and fix the system that is allowing or even encouraging unacceptable risk taking. Very few investigations truly determine the root cause. This will be the subject of another article.

6. Work to gain employee involvement in safety. If all information only flows downhill, we lose the most valuable nuggets of knowledge available. If you want to know what is wrong with your system, you have to ask employees and be willing to listen to what they have to say.

7. Teach supervisors how to manage employees of diverse cultural backgrounds. Have your supervisors been trained to understand the nature of cultural differences and it’s impact on behavior? Have they been taught how to effectively manage this workforce? Most often, we find someone became a supervisor without ever receiving any training or education in how to manage.

Remember that no one wants to come to work to get hurt or believes that they will be the one to get hurt. The perception of whether or not something is risky behavior is often not grounded in reality, but rather the result of REAL people, reacting to the REAL world around them.

Use of Incident Rates in Measuring Safety Performance

 

History of Incident Rates

Following the passage of the Occupational Safety and Health (OSH) Act of 1970, the Occupational Safety and Health Administration (OSHA) was formed to promulgate and enforce safety and health regulations and standards. In 1971, OSHA published the occupational injury and illness recording and reporting regulation, 29 CFR Part 1904. During that same year, the Secretary of Labor delegated responsibility for the occupational injury and illness statistical program to the Bureau of Labor Statistics (BLS).

In 1981 OSHA changed its use of injury and illness records in its inspection activity. At the beginning of a planned programmed inspection, the compliance safety and health officer used to do a "records-only check" to determine the lost workday injury incidence rate for the establishment. If the establishment had a rate below the national average, the compliance officer would end the inspection.

Beginning in 1986, OSHA discovered numerous instances of significant underreporting of injuries and illnesses. The Agency began issuing large penalties for recordkeeping violations.

In 1989, OSHA discontinued its "records-only check" policy of terminating inspections because of concerns that this policy might have been an incentive to under record injuries and illnesses.

 

Purpose

Injury and illness records serve as a "management tool" to direct company safety and health programs and efforts. They have also been used by OSHA to direct compliance officers better focus their inspection efforts.

These records also serve to produce statistical data on the incidence of workplace injuries and illnesses, thereby measuring the magnitude of the injury and illness across the company.

Employers have used this data to measure whether they are performing better or worse than their competitors.

 

Forces Driving Underreporting

Unfortunately, many large clients/companies now use this data in order to prequalify contractors and to measure their onsite performance. This has seriously increased the scrutiny that injury/illness rates receive by upper management and has lead to significant underreporting and inaccurate statistical data.

Construction companies looking for ways to measure the performance of their supervisors, divisions and jobsites have incorporated injury/illness rates into their accountability process. That has lead to additional pressure to underreport.

 

General Accounting Office

An August 1990 report by the United States General Accounting Office found "possibly significant injury and illness under recording and subsequent underreporting" This lead to the revisions of the recordkeeping rule.

In spite of the revised recordkeeping rule, underreporting continues to be perceived as a serious problem.

Sen. Patty Murray, D-Wash., and Sen. Edward Kennedy, D-Mass., asked the Government Accountability Office (GAO) to investigate whether OSHA effectively ensures that employers are providing accurate workplace injury and illness reports.

Specifically, the senators asked GAO to evaluate OSHA's efforts to ensure that employers are properly recording injuries and illnesses and assess the trends in the number and types of OSHA recordkeeping audits, among other recommendations. They expressed concern that underreporting injury and illness rates has become more prevalent in recent years, and that OSHA's effort to monitor the accuracy of these reports significantly has diminished.

 

OSHA National Emphasis Program

A recordkeeping National Emphasis Program (NEP), launched Oct. 1, is looking at injury and illness underreporting. That initiative includes evaluation of incentive programs that encourage a non-reporting workplace culture.

The NEP on underreporting comes in conjunction with the release of a report by the Government Accountability Office which found that many employers did not report workplace injuries and illnesses for fear of hurting their chances of winning contracts.

The report also said that workers did not report job-related injuries because they feared being fired or disciplined, and worried that their co-workers might lose rewards as part of safety-based incentive programs.

In response, additional OSHA inspections for the purpose of monitoring recordkeeping have been funded through recovery act.

In addition, Stone & Webster Construction Inc. recently made headlines and must pay $6.2 million to the federal government to settle a multi-year investigation into alleged improper recordkeeping of injuries and site safety under a $10-billion long-term contract with the Tennessee Valley Authority for modifications and maintenance work at nuclear plant sites in Tennessee and Alabama.

OSHA was made aware of the problem by TVA, which noticed discrepancies on the OSHA 300 Log used to record work-related injuries and illnesses. OSHA regulations require employers to maintain records of fatalities, injuries and illnesses and post a summary of these incidents each year at job sites.

 

Statistically Inaccurate Measurement

Most companies are aware that the use of incident rates becomes less meaningful with small sampling sizes. For example, the overall company incident rate might be a useful statistic, although a lagging indicator. However when the company attempts to use this measurement to compare work groups, crews or locations with small populations, one incident will skew the incident rate so that the crew can never recover due to low man-hours.

The OSHA incident rate was originally developed to compare large corporations against other large corporations, not to compare small locations/crews.

 

Better Measurements

Organizations are still going to measure OSHA recordable incidents. Forward thinking companies have added additional measurement systems with an emphasis on leading, rather than lagging indicators. This provides the organization with a “dashboard’ of measurements allowing a more fine-tuned means of monitoring the health of the safety system.

Some of the leading indicators that are used include:

*Audit scores
*Perception survey scores
*Frequency of daily personal safety contacts with employees 
*Frequency of behavior / coaching observations
*Frequency of inspections, self assessments to goal
*Number of JSAs completed per task / day / crew / etc.
*Number of recognitions given to employees
*Number of employee suggestions to goal
*Number of hazards reported by employees
*Quality of tool box safety meetings, inspections, investigations, etc.  

 

Conclusion

Additional scrutiny of your company recordkeeping is prudent given the current regulatory emphasis. In addition, consider adding leading indicators to your dashboard.

Pamela Fisher, CHST, CSHM
Mike McCarroll, CSP

 

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