On May 12, 2016, OSHA revised its Recording and Reporting Occupational Injuries and Illnesses regulation; the changes will come into effect January 2017. This revision requires employers in certain industries to submit illness and injury data via the OSHA 300 log electronically and then OSHA will share this information publicly. These changes don’t address the many underlying issues preventing the health and safety industry from improving. 

There is a strong need for increased transparency, but in my experience, transparency is only truly achieved when the right information is being measured and the best practices are put in place first. There are two problems here: the metrics OSHA has chosen to make public are inadequate to inform safety policy. And while OSHA will require all forms to be submitted electronically, the status quo for managing safety in at-risk industries is still paper processes. I believe the OSHA’s final rule has fundamental flaws and will likely result in poor decisions by prospective employees, investors and their own enforcement teams.

Lagging behind

With the final rule, OSHA is going to make a number of companies’ injury and illness data public. These data sets are referred to as lagging indicators. Lagging indicators are limited by the fact that they only provide insight into past safety performance and give no indication of how a safety program is currently performing. If you are keen to invest in a company, for example, it’s not enough to know how much profit a company made last year, you want to project how much profit is going to be made in the current year and years to come.  Lagging indicators lack the foresight necessary to truly assess an organization’s risk level. Companies with zero incidents are not necessarily the companies with the best and most effective safety practices. By promoting only lagging indicators, OSHA could mistakenly recognize high-risk companies for having low incident rates which will mislead potential workers, investors and the general public. 

Instead, OSHA should request the submission of a variety of metrics including both lagging and leading indicators. Leading indicators are key performance indicators (KPIs) meant to identity potential hazards or risks before they result in an incident. OSHA needs to influence practices that paint a complete picture of a company’s safety program, and what they are doing to remain safe or improve safety.

Where’s the software?

A recent EHS Daily Advisor report found that 79 percent of companies are reporting and managing their internal programs without safety software. That same report also noted that 60 percent of respondents believed that transparency of safety performance is an important element of an effective safety program. In other words, a majority of safety professionals do want improved transparency, but with only 21 percent of companies currently using electronic safety management systems, we’re still far from achieving our goals. The need and desire is there, but without the proper infrastructure to support it, how does OSHA plan on addressing this alarming gap?

You wouldn’t build a house on an unstable, out-dated and damaged foundation, and then put it on public display. You know that would be dangerous, costly and would eventually crumble to pieces. Why would you build your safety program on an equally faulty foundation? OSHA is forcing people to build a fancy new house without supporting them to first build a foundation. Before OSHA mandates how companies should submit their safety data, it should first introduce policies that encourage organizations to more effectively collect and manage their safety data. By doing so, companies collect far more valuable data and OSHA gets more time to build an interface that connects to participating companies, facilitating easy data sharing.  Instead of punishing poor performers, OSHA would be encouraging strong performers, which is far more effective in influencing employees, customers and investors to act. The only way to do this is to nudge at-risk companies into the 21st century – to move away from basic paper management systems and embrace technology.

Electronic safety management systems reduce bureaucracy instead of creating it. They improve data accuracy and revolutionize the speed at which data can be shared with stakeholders.

Barrier to worker engagement

The EHS Daily Advisor report also showed that 9 out of 10 safety professionals believe that increased worker participation has the most dramatic impact on safety. One of the biggest barriers to participation is management’s refusal to adopt modern technology. A clear gap exists and it’s OSHA’s mandate to plug it. OSHA should be investing in the adoption of software that improves employee participation, increases communication between field workers and office workers, and collects and organizes relevant leading indicator data. Anything else is ignoring the elephant in the room. 

Accurate data submission and transparency are admirable goals, but are only as valuable as the metrics being submitted. Enforcing mandated electronic data submission of OSHA 300 forms will not achieve the outcomes OSHA is looking for, and is likely to create more problems than solutions. OSHA should encourage and support companies to embrace new internal technology before they seek to mandate policy. This starts with a deeper understanding of what tools are necessary to proactively address safety hazards. By only sharing lagging injury and illness data, OSHA’s final rule may unintentionally misinform the public about the risk levels of an organization and miss out on a real opportunity to use its resources to actually improve health and safety.