Safety Leadership: How to drive OSHA’s efforts to reduce workplace serious injuries and fatalities
Editor’s Note: Achieving and sustaining an injury-free workplace demands strong leadership. In this monthly column, experts from global consulting firm DEKRA Organizational Safety and Reliability share their point of view on what leaders need to know to guide their organizations to safety excellence.
In January 2015, OSHA issued new rules that require employers to report to the agency most work-related serious injuries and fatalities, or SIFs. Now, four years later, if you’re wondering how goes the battle, the answer seems to be: There’s lots of room for improvement.
Between January 2015 and April 2017, employers reported to the agency 4,185 fatalities and 23,282 severe injuries. OSHA’s former assistant secretary, however, estimated that at least half of all severe injuries went unreported during that period. That’s a pretty astounding estimate. Think about it: There may be at least twice as many SIFs as the agency charged with protecting workplace safety knows about.
This information comes from an audit recently published by the Department of Labor Office of Inspector General that sought to determine whether OSHA is effectively implementing the revised SIF reporting program, as well as whether employers who report SIFs are investigating the incidents and taking action to prevent recurrences.
What would cause employers to not report serious incidents to OSHA? In some cases, they may worry that if they do, OSHA could cause them further trouble. If a company reports truthfully, management may fear that OSHA’s onsite presence would lead to the discovery of other safety problems. However, penalties for a violation aren’t really severe – the $5,000 fine can easily be seen as an inconsequential deterrent.
Some leaders may not be aware of the change in SIF reporting requirements, or may have misinterpreted the standard. In some cases, it’s conceivable that executives assume the job is being handled down the line and they don’t need to verify compliance with the standard.
To its credit, OIG has recognized a significant shortcoming in the OSHA SIF reporting system. This shortcoming has two far-reaching consequences for the U.S. workforce:
- OSHA is left with highly incomplete data for targeting high-risk occupations.
- Employers can easily develop a false sense of security regarding actual safety performance.
High-performing employers, including many of our clients, have long recognized that a best-in-class handling system should include these six elements:
- Leadership commitment to establishing a climate that encourages and supports reporting of incidents.
- An investigative process dedicated to finding all root causes and contributing factors – including management systems, culture and leadership factors – that might play a role in SIF incidents.
- A Hierarchy of Controls analysis to drive corrective and preventive actions, whereby solutions rely less on changes in employee behavior and more on engineering solutions that improve the safety reliability of the operations.
- A system of tracking corrective and preventive actions to completion.
- Field verification or confirmation with workers that the corrective and preventive actions actually mitigated the exposure that led to the SIFs.
- A system of metrics to monitor performance in all of the aforementioned areas and drive accountability.
Such a system, if enforced by OSHA, would result in more accurate reporting of SIFs, higher quality investigations and actions taken that actually solve the problem of workplace SIFs.
Leaders could also alleviate their concerns about complying with the SIF reporting standard because they would have few, if any, SIFs to report.
OSHA is in the best position of any government agency to reverse this trend. The agency’s SIF reporting requirements are a good first step. But, as the OIG audit makes clear, it will take a more dedicated investigative and enforcement effort at OSHA than we currently are seeing to make it happen.
This article represents the views of the author and should not be construed as a National Safety Council endorsement.
Don Martin, senior vice president and executive consultant at DEKRA OSR, is a safety industry veteran with more than three decades of experience in the design and implementation of environmental health and safety management systems; risk management programs; and organizational culture change initiatives for companies worldwide.
Direct to your inbox: Sign up to be notified in email about new "Safety Leadership" columns.