Thought Leadership


OSHA’s electronic injury/illness recordkeeping data regulation,

or OSHA adopts Saul Alinsky’s “Twelve Rules for Radicals”

November 21, 2013

The current administration looks to Saul Alinsky’s “Twelve Rules for Radicals” for their guidance. OSHA has now stepped in this direction and away from safety principles.

Their first foray was the Shaming Press Releases. With the exception that some targeted work sites were held up for ridicule wrongly after further review of their citations, this foray has largely been a big yawner.

Not to worry. There are other opportunities and OSHA took another big step in the Rules For Radicals direction last week.

The shaming press release initiative targeted significant violations or number of violations of standards. This new initiative will target injury/illness performance.

OSHA has issued a proposed regulation to require certain larger site employers to submit their injury/illness recordkeeping data electronically. OSHA will then make that data public in hopes of generating public criticism of these companies. It doesn’t matter if they are generally in compliance. It is now all about the publicizing the number of injuries and illnesses they experience and the public criticism that may engender.

You should note that the proposed regulation appears to include only sites that have higher rates. But watch carefully for the term: “initially.” It is a word that is supposed to communicate that the regulation is really intended for the “bad actors”. But watch out. If we empower the government here with this regulation, more sites’ injuries and illnesses will eventually be publicized. If the initially publicized high injury/illness rate data for large sites does not generate sufficient public outcry, ”Let’s add more large sites”—will be their approach.

So, despite what OSHA says about improving safety, this proposed regulation is nothing more than a raw political agenda play. Here are some of the problems:

First, large companies are most likely to employ safety professionals and, thus, have organized, structured safety and health management systems, including management systems for compliance with OSHA and other agency regulations. These have been termed “the best” by OSHA’s Dr. Michaels. So why would he now attack these companies by unleashing his political radical colleagues on them?

The impact of this attack will be greatest on the safety professionals who will have their management systems criticized in the press, by their employers and harassed by OSHA. And for what purpose:  The OSHA leadership’s political agenda.

Second, we have seen that this government cannot be trusted to hold and use electronic data responsibly.  They will likely misuse it in ways that we cannot imagine. The government has to get this data out there to mobilize the radicals to attack.

Third, this proposed regulation only benefits the government in allowing it to “Alinskyize” the data. It has no benefit to the regulated community or to safety as concept and practice. The current paper injury/illness recordkeeping process works fine for the regulated community and for the established record keeping interests of the government.

Finally, safety professionals and ASSE have, for many years, worked on better ways to measure safety and health results. The terms are leading and lagging indicators. The emphasis has been that leading indicators are better measures and should be the outcomes measurement of choice. However, if OSHA enacts this regulation, all of that effort will have been for naught. Injury/illness are the primary lagging indicators. Lagging indicators will become the absolute focus. No one will be interested in leading indicators anymore. OSHA will be focused solely on lagging indicators and that will become everyone’s focus.

That lagging indicator focus will, in turn, revive the injury illness recordkeeping police function. The current OSHA leadership has long asserted that firms were under reporting. They set out prove that by conducting special recordkeeping inspections. They were not able to find much. So with the new focus on injuries and illnesses as lagging indicators, OSHA will be back in the recordkeeping police business.

In short, this is a really inappropriate proposed regulation. There are no safety issues. There are just Saul Alinsky’s Rules for Radicals issues—political agenda all the way.

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