A recent survey by the Occupational Safety and Health Administration (OSHA) reveals that 60 percent more companies conduct voluntary self-audits of safety and health conditions than in 1981.
As a result, more than 85 percent of employers conduct these audits. About 53 percent of companies did audits 18 years ago, according to a National Institute for Occupational Safety and Health survey.
The survey indicates a trend that environmental, health and safety professionals have known for years, said Zack Mansdorf, Ph.D., CIH, CSP, QEP.
"It's good that [OSHA] recognizes the trend," said Mansdorf, a safety and health consultant. "It's funny that it took two decades to determine. If you ask anybody on the street in this business, they"ll tell you that auditing is a routine matter."
The bigger issue is not whether companies are doing audits, but whether they are finding and correcting problems, Mansdorf said. As a result, he added, OSHA should have compliance as its ultimate goal.
The OSHA survey, which involved telephone interviews with 492 large and small employers in general industry and construction, showed that companies conduct self-audits:
- To reduce injury and illness rates (83 percent);
- To do the "right thing" (79 percent); and
- To be in compliance with OSHA regulations (79 percent).
"These high percentages are evidence that our policies to encourage self-inspections are working," OSHA Administrator Charles N. Jeffress said.
Mansdorf sees it another way and suggests OSHA has been unprogressive and bureaucratic in its response to self-audits. He said OSHA could have followed the lead of the Environmental Protection Agency (EPA) in 1995 when it adopted a new policy on environmental self-auditing and self-disclosure. EPA's policy offers greatly reduced penalties and safe harbor from criminal referrals to facilities that voluntarily disclose and fix violations identified through environmental audits.
Instead of joining EPA in the self-audit crusade, OSHA waited until this year to fully tackle the topic. "It seems like they are now trying to change their thinking," Mansdorf said.
On Oct. 6, OSHA announced that, during an inspection, employers will no longer routinely have to provide the agency with voluntary self-audits of safety and health conditions. The agency indicated it will not use such reports as a means of identifying hazards to focus inspection activity.
Also, if an audit identifies a hazardous condition in the workplace and the employer promptly takes corrective action, OSHA will not use the audit report as evidence of a willful violation.
When employers not now conducting self-audits were asked, in the survey, what would encourage them to begin, they said the strongest influences would be lower insurance costs, an increased probability that injury and illness rates would decrease, and a penalty reduction if OSHA inspected and found a violation.
Some insurance companies develop partnerships with the agency and offer reduced premiums to employers who participate in programs to assist them in conducting self-audits. To help injury rates decrease, OSHA is distributing guidance via "online advisors." Go to www.osha.gov and click on "OSHA Advisors/Software."
Regarding penalty reductions, OSHA seeks comments through Dec. 6 on allowing employers' self-audits to be considered as evidence of good faith. This would qualify the employer for a substantial civil penalty reduction if OSHA proposes a penalty.
The most common reason given for not doing self-audits was that the survey responders found no hazards. Another reason was there were no qualified staff to conduct the inspections.
The survey, which did not include state-plan states, revealed that most employers not doing self-audits are smaller companies. Another trend, pointed out by Mansdorf, is that auditing cycles have become further apart because employers are not finding as many problems as in years past. Many companies, he said, are going from yearly to a three-year cycle of self-audits.