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The Risks of Using Injury and Illness Reporting as Measurements of Success

Dec. 19, 2018
Measuring operational success is an ongoing challenge for businesses of all sizes and across all industries.

What does success look like? For some businesses, it’s all about revenues and growth. For others, it’s about employee satisfaction and turnover rates.

Many businesses in the manufacturing sector look at even more indicators, such as the number and types of injuries and illnesses reported, to gauge the success of their workplace safety programs. There is no doubt that this is an important indicator, especially when oversight from the Occupational Safety and Health Administration (OSHA) is involved.

The Do’s and Don’ts of Incentivizing Workplace Safety

OSHA is primarily concerned with making sure work sites are operating safely. One way they do this is by tracking incidents of illness and/or injury through reports submitted by employers. The trouble with using reported injuries and illnesses as a barometer of workplace safety isn’t so much in what is reported as it is in what is not reported. In some instances, employers may have created a culture that incentivizes not reporting injuries and illnesses or withholds “rewards” for those employees that come forward and report and injury or illness.

Although the business may have the best of intentions at heart and really only wants to recognize their employees’ dedication to workplace safety, OSHA may not see it quite the same way.

Under OSHA’s update to its 2016 rule on recording and reporting workplace injuries and illnesses, such programs would be in violation of the law. Whether this incentivized culture was purposeful or inadvertent doesn’t matter. What matters is that any practice that incentivizes employees for not reporting an injury or illness or denies employees incentives if they report an illness or injury, can now be cited by OSHA.

That means organizations must now be more vigilant about how they handle and reward workplace safety. However, there are ways organizations can mitigate their risk, including the promotion of an overall culture of safety within the workplace.

Injury and Illness Reports Can Mask Issues Of Concern 

Injury and illness reports serve an important purpose by providing the employer and OSHA with deeper insight into an organization’s approach to workplace safety. However, by relying on such reports as indicators of success, leaders may be exposing the business to potential OSHA violations.

If employees believe that they will be penalized for reporting injuries and illnesses and/or actively take steps to avoid filing such reports to receive a reward or incentive, reporting data will be skewed and inaccurate. In this scenario, neither the organization nor OSHA will have a complete understanding of how well the workplace safety programs are working, and worker safety may be genuinely at risk.

Organizations that take the right steps to ensure that illness and injury data is more accurate, will then allow leadership to make better-informed decisions regarding workplace safety programs and practices. Plus, it removes the possibility of violating OSHA’s new regulations regarding incentives.

Tips for Compliance

OSHA is interested in documenting all injuries, from the obvious, serious injuries to the smaller, less noticeable ones. Given the new provisions, employers should:

  • Let employees know that they have a right to report work-related illnesses and/or injuries.
  • Ensure employees are not discouraged or dissuaded from reporting such injuries.
  • Strictly prohibit any retaliatory actions against employees who report injuries or illnesses.
  • Re-examine workplace safety incentive programs to ensure they do not incentivize non-reporting.
  • Examine existing safety practices, policies, training, and procedures for compliance.
  • Communicate any workforce safety changes to the entire organization.
  • Provide training for leaders and managers to ensure compliance with the new procedures. 

Examination and Monitoring Can Support Organizational Compliance

The challenges of keeping up with ever-changing OSHA rules and regulations are enormous. Complicating matters is the fact that the rules and requirements may differ depending on the size of the organization and the fact that states may interpret and enforce OSHA updates differently.

Worker safety is not something that can be left to chance. Organizations that don’t have the internal staff or knowledge to review policies, practices, and procedures for current compliance should have an external expert conduct a workplace safety audit to ensure compliance.

As OSHA updates continue to emerge and evolve, leaders must keep up with the latest news. This can be accomplished by using technology to create custom alerts based on industry, state, or other key factors, or through curated news feeds which can provide relevant information without data overload.

Workplace safety programs exist to provide a safe working environment for employees as well as to support a culture of safety and health. Consistent monitoring of OSHA rules and regulations and strict adherence to those requirements is the best way to ensure worker safety and to remain in compliance with current law.

Mark Kozeal is the director of product management for Bloomberg Environment, a leading source of legal, regulatory, and business information for professionals. Contact: [email protected]

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