Let there be no doubt: if you want a 0.0 recordable incident rate, you can get one. You either manage work to the extent incidents do not cause injuries or illnesses; or you manage your OSHA 300 log the way you would like it to look.

Underreporting is an epidemic. For those of you who have never fudged your log, and maybe even have never considered it, please enjoy the following scenarios being practiced today. For those who have done these things (ashamed to say I wouldn’t be writing about them from inexperience), see if anything sounds familiar.

The voodoo doctor
The voodoo doctor goes by a more common term “company doc.” They are the “preferred” docs who will give you whatever you want… as long as you keep bringing business.

This is not fiction. I have convinced my voodoo docs in the past to back date forms, not document physical therapy being required, consider restricted work as regular duty, and other lessthan- legal or ethical practices, all in the guise of “helping the company out.”

Most seriously I have “heard” about people convincing doctors to write prescriptions to the “case manager” instead of the employee as to prevent the prescription from showing up on the employee’s file. This also makes it handy to avoid workers’ compensation status; just put it on the company credit card.

There are less severe and more reasonable solutions to doctor relationships. There is nothing wrong with building trust, becoming partners (in ideology), or even inviting docs and their staff to tour your facility or workplace so they can more clearly understand the work task.

The wizard
Remember the pure shock when Dorothy, the Tin Man, and company found out the wizard had no powers, and was actually just a feeble little person behind the curtain pretending to be all powerful or all knowing? With recordkeeping some of us just plain stretch the truth to the point we forget what the truth is.

Some of the most common twists of the truth that the wizard uses are:
  • It’s not restricted because…
  • Well the other doc said he didn’t need the prescription…
  • Doc, were these stitches necessary or just cosmetic?
  • Doc, can we give him over-the-counter pain relievers instead?
  • That antibiotic was precautionary, just like a tetanus shot.
  • This guy is out to get us. He wasn’t hurt here and I have 800 witnesses saying that they didn’t see him get hurt here.
  • This is a pre-existing injury, why do we have to pay for it?
  • He already had bad knees and elbows before he fell off the scaffold.
Let’s be clear: since 2001 when the standard was revised into law, 99 percent of the loopholes safety professionals utilized became nonexistent. The standard leaves little to no room for interpretation. It was re-written ten years ago because there was too much interpretation already. No, you can’t use sample medications. No, you can’t interpret a job description after the injury to keep it from being restricted. His/ her job did allow for them to lift items heavier than ten pounds, and you know it.

What am I trying to say about the “wizard”? He’s a liar, both to himself and his management. He creates rules that don’t exist, or twists the ones that do into something they are not.

See no evil, hear no evil, speak no evil
Yeah, just like it sounds. We pretend the injury never happened. In the best scenario, ignoring the case is justified by a mental checklist the “case manager” utilizes in his head:
  • Employee treated properly by physician and provided restricted duty? Check.
  • Management happy on site and off site that we have not had recordables? Check.
  • Everyone gets to keep their safety incentives? Check.
  • Safety manager is successful? Check.
  • The injury was properly recorded on the OSHA 300 log… well not exactly.
  • The incident that caused the injury got a strong corrective action and management attention… no, after all it was only a first aid, or that’s at least what we’re calling it.
  • Did we just fool ourselves into thinking we were better than we are, and did we put ourselves in a position to hurt more people because we ignore our injuries? Unfortunately, Check.
  • Did we reinforce with the employees that safety really isn’t the priority that we’ve been saying it was? Check.
I have personally been to dozens of one-million man hour safety celebrations; most have some employee in the audience using crutches, in a sling or some other injured status that makes the whole event nothing less than a fraud.

Where did we go wrong?
I thought everyone manipulated the OSHA logs, till I grew up. I have sat across from many safety directors, who should be truly proud of their 4.0 recordable incident rate, even their 1.0 rate. I am proud to say that those people helped me change my perception of recordkeeping methods significantly. It also made me concerned for our industry as a whole.

What was intended to be a metric developed by OSHA and the Bureau of Labor Statistics became a standard to evaluate safety performance by management, customers, contractor associations, trade organizations and even insurance carriers.