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.
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.
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:
*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.
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