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Recordkeeping: more than a numbers game

By Judith Coleman
September 14, 2006


In a study published in the April issue of the Journal of Occupational and Environmental Medicine, the authors cited a gross underestimation of safety performance data. The data was collected from four workers’ compensation, occupational disease statistic and OSHA survey databases in the state of Michigan between the years 1999 and 2001.

Comparing data collected by the U.S. Bureau of Labor Statistics and the four Michigan databases using capture-recapture analysis, the authors determined that 67 percent of injuries and 69 percent of illnesses went unreported in the state over the three-year time period.

They believed that the current national system for collecting industry safety data needs to be redesigned so that it is not dependent upon companies’ potentially subjective interpretation of safety metrics.

While most often the tendency to under-report is not intentional, the potential for missreporting is high when companies don’t understand why safety data is collected. If employees are not made aware that the numbers they report to OSHA will be used to design improved national safety programs and not to punish workers, then there is a greater likelihood that data will be mismanaged.

However, there is a way for companies to satisfy OSHA requirements and meet their organization’s safety goals without sacrificing employee well-being. But first environmental, health and safety (EHS) professionals must understand where their organizations’ safety pitfalls lie.

Three hindrances to reporting

The reasons for under-reporting are as varied as the industries that comply with OSHA requirements. However, there are three potential areas of concern that can affect all industries.

Failure to report. The first of these is failure to report injuries or illnesses. In some cases this failure results from employees seeing their injury or illness as trivial or not worth the time to report. However, in some cases the reason for not reporting an incident is far more complicated and can stem from an organization’s attempt to inspire employees to keep recordable incidents low.

“Incentivising” under-reporting. The desire to keep recordables low leads to the second most common reason for under-reporting. If organizations base their safety performance strictly on counting the number of OSHA recordables that are logged in a given quarter, they are setting their programs up for failure. By encouraging, or worse, incentivising under-reporting, companies are reinforcing negative behaviors that do nothing to improve the safety of their employees.

Lack of consistent data. A third reason for under-reporting stems from a lack of data consistency. While not as deeply rooted in personal psychology as the other two reasons, data integrity plays a significant role in whether a company’s safety program is successful. It is also the easiest of the three stumbling blocks to remove — since the other two are behavioral. By maintaining data integrity companies can begin to see improved safety performance from the moment their changes are implemented.

Data is key

While it may be nearly impossible to eliminate all instances of under-reporting due to an employee’s inability or unwillingness to report an injury or illness, there are steps that can be taken to improve work processes that will greatly improve data quality.

One of the most important steps is to evaluate how your organization is measuring safety performance. If safety is seen as strictly a numbers game, consider rewarding employees when they actively participate in the safety process by reporting unsafe processes or perhaps by participating in safety training courses that can help EHS professionals direct activities to prevent injuries from occurring.

Because data is key to determining the success of any safety program, it is in an EHS pro’s best interest to see how the data that their departments report can be expanded to give as much detail as possible, while making the process easier for those tasked with data collection.

Automation helps reporting

There are automated software programs on the market that offer additional checks and balances to ensure records are filled out correctly and completely. These features can include highlighted fields that guide users through forms to ensure that all necessary information is entered, or user-defined sections that can address non-reportable data types such as near-miss incidents or minor injuries where basic first-aid was needed.

While not necessary for compliance with OSHA, these non-reportable data sources offer EHS pros an opportunity to identify potential hazards in processes that may be causing injury or illness and look for ways to improve departmental responsiveness.

Studies have shown that having fewer restrictions in data management programs regarding what must be entered at the time a record is open actually improves overall reporting and data integrity. For this reason, some software packages have pre-loaded reports that show professionals where they may have gaps in their incident data, so that users are free to populate data fields as data is reported, or time permits, instead of having to manage data entry as a batch process.

Additional benefits of automated reporting software packages include the use of charting and graph capabilities to help safety managers actively trend and analyze data that is entered. Having a visual representation of safety data helps management to identify problem areas and remedy them before they become more serious occurrences.

Training programs surrounding data management and reporting should also stress the importance of entering all employee data regardless of whether records have incidents associated with them or not.

A different view

The problem of under-reporting OSHA recordables doesn’t have to bring safety programs to a halt. EHS professionals can change the way their organizations view OSHA recordkeeping by making the active pursuit of safety the program goal and the elimination of hazardous processes and environments the metric by which employees measure success.

If a company’s leadership and its employees understand that safety data is collected and recorded to improve safety processes and the well-being of workers nationally and not to punish individuals, they will be far more cooperative in reporting incidents and in providing an environment where discussions about safety can take place.

An important step in developing this environment of exchange is to assess the benefits of automating the safety recordkeeping process. In so doing, the depth and breadth of safety information can be expanded to improve decision-making and increase an organization’s ability to respond to potential hazards before they cause incidents of a larger magnitude. Safety recordkeeping should not be handled in a vacuum. It can and should be communicated as an opportunity for improved employee well-being and corporate advancement.

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Judith Coleman is manager of training at ESS. She is an expert in the field of automated MSDS management software. ESS is a leading provider of operational risk management software and services for environmental, health and safety (EHS) and crisis management. For more information, call 480-346-5526 or visit www.ess-home.com.

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