UNLOCKING THE POWER OF OSHA RECORDS
Ten ways to enhance workplace safety and lower insurance costs
Leveraging OSHA records is a
powerful strategy for enhancing
workplace safety, prioritizing employee well-being,
and lowering insurance costs.
By Randy Boss, CRM, MWCA, SHRM-SCP
OSHA records provide information that risk advisors can leverage to improve workplace safety, protect employees, and lower insurance costs. It’s an opportunity to show that we care about the people who work for the companies we insure, whereas no amount of insurance can reverse a life-changing disability or breathe life back into someone killed on the job.
Let’s explore some practical steps and strategies agents can use to help employers utilize OSHA records effectively to enhance safety practices, mitigate risks, prioritize employee well-being, and lower insurance costs.
Thoroughly analyzing OSHA records. Doing this is crucial to uncover patterns, trends, and recurring incidents. It’s the “canary in the coal mine” warning of trouble or danger. By carefully reviewing these records, organizations can identify common root causes and areas of concern, providing a foundation for effective safety improvements.
I was working with an employer whose employees experienced several cut fingers from box cutters, the worst being cut tendons that resulted in several thousand dollars in medical costs and lost time. To reduce these types of injuries, we instituted the use of a safety box cutter that protects the employee from an exposed blade and eliminates this hazard. The result was no more cuts, fewer OSHA infractions, and lower experience modification rating (EMR), leading to lower workers comp costs.
Identifying high-risk areas. The insights gained from OSHA records help organizations identify high-risk areas or tasks that require immediate attention. Focusing on addressing these areas through targeted safety measures allows for proactive risk mitigation and accident prevention.
One of these high-risk areas is falls related to working at great heights, particularly in construction. A sprained ankle with a couple of thousand dollars in medical bills and a few days off after falling 10 feet without fall protection indicates that something more serious, like a lifetime in a wheelchair or death, could be next.
Developing preventive measures. Utilizing OSHA records to do this may involve updating safety protocols, providing additional training, improving equipment or processes, and enhancing safety signage or warnings. By addressing potential hazards proactively, organizations can significantly reduce the risk of incidents.
Working with a manufacturer, we noticed several eye injuries resulting from using a grinding wheel. Although employees used safety glasses, metal debris still got in their eyes. A change to better-fitting eye protection eliminated these eye injuries.
Training and education. Reviewing OSHA records can serve as a valuable tool for identifying areas where additional training or education is needed. Develop comprehensive training programs that address these areas, thus ensuring that employees have the necessary knowledge and skills to perform their tasks safely.
While reviewing the OSHA records of an employer, we discovered several back injuries due to improper lifting techniques. We added training on how to lift correctly, which significantly reduced back injuries and improved overall productivity by keeping employees on the job where they are needed. The employer valued this because it’s been challenging to find qualified employees.
Fostering a safety culture. Encourage open communication, promote the reporting of near misses or safety concerns, and actively involve employees in safety initiatives. By creating a shared responsibility for workplace safety, organizations empower employees to actively maintain a safe work environment.
It’s been my experience that getting employees to report near misses and close calls consistently is challenging. H.W. Heinrich developed Heinrich’s Accident Triangle Theory in the early 1930s. He suggested that 88% of all accidents happen due to human decisions to carry out an unsafe act.
Frank E. Bird developed the theory further in 1996 by analyzing 1.7 mil-
lion accident reports from about 300 companies. He came up with an amended triangle, which showed a relationship between one serious injury accident and 10 minor injury accidents. It further showed 30 damage-causing accidents to 600 accidents as near misses.
According to this theory, every OSHA recordable had several near misses. When an employer has recordable injuries but no reported close calls or near misses, risk advisors must inquire why this is and suggest improvements to “near miss” and “close call” reporting.
Regular safety audits. These and inspections are essential in assessing compliance with safety protocols and identifying any gaps or potential hazards. Use the insights gained from OSHA records to guide the audit process and prioritize areas for evaluation. Implement corrective actions based on the findings to improve safety standards continually. According to the National Safety Council, a regular safety audit objectively reviews a company’s policies, practices, and operations regarding regulatory compliance.
While doing a safety audit at a construction site recently, we noticed a cement rebar without safety caps. A simple fall to the same level could lead to impalement on the uncapped rebar.
OSHA standards require “All protruding reinforcing steel, onto and into which employees could fall, shall be guarded to eliminate the hazard of impalement.” The key words are “to eliminate the hazard of impalement.”
When employees work above rebar or other sharp protrusions, exposure to impalement is always a consideration. When I explained to the employer the potential injury to not only their employees but also other subcontractors and anyone else on the jobsite, they immediately put safety caps on the cement rebar.
Establishing Key Performance Indicators (KPIs). These indicators may include near-miss reporting rates, safety training completion rates, or the effectiveness of implemented safety measures. Continuously monitor and evaluate these KPIs to track progress, identify areas for improvement, and maintain a focus on ongoing safety enhancements. Tracking Incident Rate, DART Rate, Severity Rate, and Lost Time Rate year after year and against businesses in the same North American Industry Classification System (NAICS) code indicates how well a safety management program performs.
In 2016, OSHA published the final rule that requires certain employers to electronically submit injury and illness data that they are already required to record on their on-site OSHA Injury and Illness forms. When asked why it was collecting this data, OSHA responded that doing so would improve its ability to identify establishments that experience high rates of occupational injuries and illnesses. OSHA will then use the data to interact with these establishments through outreach and enforcement initiatives to reduce injuries and illnesses. This regulation, according to OSHA, will improve the accuracy of this data by ensuring that workers will not fear retaliation for reporting injuries or illnesses.
Fast forward to today: OSHA has implemented artificial intelligence (AI) technology to assess compliance with its E-Recordkeeping Rule. OSHA can now examine and evaluate recordkeeping practices without initiating a specific employer inspection through the electronic collection of injury and illness data as mandated by the rule.
Leveraging AI, OSHA has commenced utilizing this technology to analyze the substantial volume of collected data. This enables an efficient identification of trends within data of specific employers and industries, thereby enhancing the detection of deficiencies more effectively than can an individual compliance officer during a single inspection.
By creating a shared
responsibility for workplace
safety, organizations empower employees to
actively maintain a safe work environment.
Learning from incidents. OSHA records provide valuable lessons from past incidents. Conduct thorough incident investigations to determine root causes and contributing factors. Utilize this information to implement corrective actions and prevent similar incidents.
Organizations can continuously improve safety protocols and prevent future incidents by learning from past mistakes. OSHA strongly encourages employers to investigate all incidents in which a worker was hurt as well as close calls or near misses in which a worker might have been hurt if the circumstances had been slightly different.
A few years ago, a warehouse employee fell, breaking her shoulder. She was rushed to the hospital, had surgery, and was sent home. A claim was submitted to workers comp, the incident was recorded on the OSHA log stating that she tripped, and that’s all. Unfortunately, she died from a blood clot two days after her surgery. This is why doing a root cause analysis is essential.
Ask questions like:
- What did she trip on? A pallet on the floor.
- Why was it there? It was in the right place, out of the walkway.
- Why was she walking there? It was the only place to walk.
- Why didn’t she see the pallet? Forklift traffic caused her to look up and step aside for it to pass, thus not seeing the pallet and she tripped.
- Why was forklift traffic and walking traffic blended? It has always been that way and never changed as the company grew.
From this root cause analysis, the floor markings were installed, separating forklift and foot traffic, significantly reducing this hazard and the possibility that this accident could happen.
Conduct thorough incident
investigations to determine root
causes and contributing factors. Utilize this
information to implement corrective actions … .
Regularly reviewing and updating safety policies. Keep safety policies and procedures up to date based on the insights gained from OSHA records. Review and refine safety protocols to align with best practices and regulatory requirements. Encourage feedback from employees and stakeholders to ensure that policies remain relevant and effective.
Over the past several years, I’ve had the honor of chairing the safety committee of the Associated Builders and Contractors in West Michigan. I’ve helped several contractors complete the Safety Training Evaluation Process application (STEP), which scores their safety and creates a roadmap to world-class safety processes.
The experience has taught me that things change a lot from one year to the next, like:
- Experienced workers retire and are replaced by young inexperienced workers.
- Safety directors change.
- Companies may not have the luxury of a full-time safety person.
- Companies’ budgets for safety change.
- Management teams change, as does focus on making safety a priority.
Business conditions change so it’s critical to at least annually review and update safety policies.
Providing feedback and recognition. Acknowledge and recognize employees’ contributions to maintaining a safe work environment. Provide feedback on safety performance, highlight exemplary behavior, and encourage a positive safety mindset throughout the organization. By fostering a culture of safety and recognizing employee efforts, organizations reinforce the importance of workplace safety.
If there is a lack of trust, effective communication, and psychological safety, it is unlikely that sharing feedback with your employees will result in significant improvement. More important, with these essential elements, workers may be able to provide you with the feedback necessary to advocate for organizational-level system safety.
Leveraging OSHA records is a powerful strategy for enhancing workplace safety, prioritizing employee well-being, and lowering insurance costs. By thoroughly analyzing these records, identifying high-risk areas, implementing preventive measures, fostering a safety culture, and continuously monitoring performance, organizations can create a work environment that is safe, secure, and conducive to employee well-being. With a proactive approach to safety and an ongoing commitment to improvement, organizations can protect their employees, mitigate risks, and ensure a safety culture for long-term success.
In 2015, my sons, Dustin and Josh, and I started Emerge Apps with our first app OSHAlogs.com. Thousands of employers now use it to automate recordkeeping, analyze their OSHA records and make the electronic submission to OSHA unbelievably simple. Agents can subscribe to emergeapps.com and share OSHAlogs.com with their clients and prospects as a valuable risk management tool.
Randy Boss is a Certified Risk Manager at Ottawa Kent in Jenison, Michigan. He designs, builds and implements risk management and insurance plans for middle-market companies in the areas of safety, work comp, human resources, property/casualty and benefits. He has been at Ottawa Kent for 40 years and is the co-founder of emergeapps.com, web apps for insurance agents to share with employers. Randy can be reached at firstname.lastname@example.org.