But many audit experts say that number, less than 10 percent of Weyerhaeuser's 264 plants, is far too low for a company with a history of recordkeeping problems, especially since Weyerhaeuser continues to offer financial incentives for low OSHA recordable rates.
Experts Recommend Frequent Audits
"It's ludicrous to audit once every 10 years," commented Halley Moriyama, vice president with ENSR International, an environmental, health and safety consulting firm. "I'd be auditing every plant at least annually."
OSHA fined Weyerhaeuser $77,000 last year when the agency found 38 unrecorded injuries and illnesses at the company's Buckhannon facility.
Moriyama added that even companies without a history of OSHA violations and without financial incentives for low rates audit their environmental, health and safety (EHS) programs, including OSHA logs, every 3 to 5 years.
Several members of the Auditing Roundtable, a professional organization dedicated to the practice of EHS auditing, agreed with Moriyama's assessment that companies without major problems should audit their programs at least every 3 to 5 years.
As part of Weyerhaeuser's settlement of OSHA's Buckhannon enforcement action, the company agreed to an independent audit of the OSHA logs at 16 Trus Joist facilities. The audit, completed earlier this year by Shaw Environmental & Infrastructure Inc., uncovered an additional 60 injuries and illnesses over a 2-year period that should have been recorded, but were not.
"As part of the 'learnings' from that," explained Weyerhaeuser spokesman Frank Mendizabal, "we are beginning a pilot program to complete a safety audit at other facilities. At this point we plan to perform the audits at 24 facilities, review with senior managers, then see where we stand." Shaw will continue to be involved in the audit program, he said.
Mendizabal also confirmed that low OSHA recordable rates continue to be one measure of a manager's performance at Weyerhaeuser. Just before OSHA's 2004 investigation of the records at Buckhannon, Weyerhaeuser promoted the facility's manager, Len Komori.
The company's promotion announcement cited Komori for his plant's "business-leading safety performance." Seven months later, OSHA cited the plant for not recording injuries and illnesses. Weyerhaeuser discharged Komori in late 2004.
Using Outside Auditors
Experts in EHS auditing praised Weyerhaeuser's decision to use an outside auditor to examine the accuracy of its OSHA logs, especially because of the company's continued use of financial incentives for low OSHA recordable rates.
"No one should have incentives for low injuries and illnesses, but we don't have the strength to educate our management about leading indicators," commented Edwin "Brownie" Petersen, a safety engineer at ATK Thiokol Inc., who has had auditing responsibility at the company for many years.
Brownie explained that examples of leading indicators include job hazard analyses, corrective actions and other elements in a complete safety management system.
Brownie said he prefers to use personnel from inside the company for general EHS auditing because they often have a better knowledge of the company's program.
"But this argument isn't as strong if we're talking only about records I agree that an independent consultant would be a good backup way of identifying issues," Brownie said. "Statistics indicate that where the wrong things are measured mishaps are not properly reported."