Here is an example:
Since the turn of the century most Western Australian mine sites require workboots to be toecap, lace-up, and extend above the ankle. Slip-on, zip-up, and elastic sided boots are not allowed. People who have lived in Redwings constantly ask why, and the standard answer (from the company) is that compliant boots provide ankle support thereby reducing the incidence of ankle injuries. A noble aim, but I have to ask, “Who said these boots would reduce injuries, and where is the evidence?”
I asked the Department of Mines and Petroleum for their data on ankle injuries from 1987 to 2010. These injuries include sprains, strains, fractures, contusions, swelling and other musculoskeletal problems. There is an obvious, and major, reduction. The unanswered question is, “What caused that reduction?”
My answer is that the late 1980s saw the start of mine mechanization. Airleg, shaft mine technology hadn’t changed much since seven short fellas looked after Snow White. Tramping round drives and stopes on blasted rock was to invite ankle injury. Now, most workers sit in a cab (frequently air conditioned) and are most at risk of ankle injury when they climb out. In any case, this rule about boots arrived in the 2000s. It cannot be the cause of the big reduction.
There is no point where we can see the effect of boot style restrictions or any other single factor. The actual figures are 3.43 per 100,000 working hours in 1999-2000 to 1.34 per 100,000 working hours in 2009-2010. There is still some slight reduction but I relate that to ongoing mechanization.
Why then was this rule brought in? Quite simply, it sounded like a great idea to someone in the air conditioned office, but nobody bothered to check the facts. Why would they? Isn’t it obvious that the rule would reduce injuries? Garn! Consequently, pushing the company line only annoys people.
What is obvious, to anyone on the site, is what the OSHA is full of when chasing compliance with this rule. From now on, when OSHAs want something that really is important, it’s a case of pushing something uphill because everybody already knows what they are full of! Gimme a break!
The point is this: “If you are going to pontificate site rules from head office, get the rule right!” If you don’t, you can make your OSHA’s life hell.