OSHA’s proposal to require the electronic submission of workplace injury and illness data – and to make that data publicly available online – has predictably inspired a range of opinions.
The agency wants to amend its current recordkeeping regulations to add requirements for the electronic submission of injury and illness information employers are already required to keep under existing standards, Part 1904. The first proposed new requirement is for companies with more than 250 employees (and who are already required to keep records) to electronically submit those records on a quarterly basis to OSHA.
Smaller companies -- with 20 or more employees – who are in certain industries with high injury and illness rates, will be required to submit their summary of work-related injuries and illnesses to OSHA once a year, also electronically.
The part of the proposal that has drawn the most attention is that the data collected will be posted online. OSHA chief Dr. David Michaels appealed to the competitive nature of businesses when making the case for revealing the data, noting that it would allow employers to benchmark their performance against others in their industry.
“Employers want to be seen as the top performers in their industry,” he said.
A company's reputation "truly does matter"
Amanda Wood, Director of Labor and Employment Policy for the National Association of Manufacturers (NAM), dismisses that argument.
“Publicly disclosing specific injury and illness data serves little public good, is easily misinterpreted and can lead to unfair conclusions or judgments about a company or particular industry,” said Wood. “A company’s reputation is its currency - and it truly does matter. Numbers on a page do not present an accurate picture and this new regulation will only lead to mischaracterizations. It will not fulfill employer and employee goals of making workplaces safe.”
Wood added that OSHA already has the tools necessary to improve workplace safety, such as inspections, current reporting requirements and the ability to work with employers on a collaborative basis.
Encouraging employers to focus on safety
The Center for Safety and Health Sustainability issued a statement in support of the increased transparency.
“Appropriately expanding access to meaningful data on injuries, illnesses and fatalities can encourage employers to put additional focus on worker safety and health,” according to a statement by the Center.
A scarlet letter
James E. Leemann, Ph.D., clinical assistant professor in Tulane University’s Center for Applied Environmental Public Health, said making data public would not motivate companies to improve their safety records.
“Do we honestly believe that identifying companies with a scarlet ‘S’ is going to provoke some modification in behavior?” asked Leeman. “Companies know injuries cost them money, which is the greatest incentive to adjust behavior.”
He said underreporting of injuries and illnesses would continue, regardless of the recent proposal.
Doing the right thing
American Industrial Hygiene Association® (AIHA) President Barbara J. Dawson, CIH, CSP, said the proposal will increase the focus of senior managers on injury and illness data “and encourage employers to do the right thing for their workers.”
Dan Glucksman, Government Affairs Director for the International Safety Equipment Association (ISEA) Government Affairs Director, said he thought the data would be useful for anyone in the workplace health and safety industry.
“For some, it will motivate them to improve, and others will be motivated to show as few injuries and illnesses as possible,” said Glucksman.