Being a Safety Advisor (OSHA) is not popular. Bosses hate you because you cost them money. Workers hate you because you nag them about earplugs and safety glasses. Everybody hates you because you are forever chasing compliance — chasing company compliance with Acts and Regulations; chasing worker compliance with site rules and practices; chasing, chasing, chasing.
Many workers consider OSH to be an imposition based on pettifogging paperwork. If you want to show them that they are right, one of the great ways to do so is to chase compliance to a senseless rule. Here is an example.
Since the turn of the century most Western Australian mine sites require workboots to be toecap, lace-up, and extend above the ankle. Slip-on, zip-up, and elastic sided boots are not allowed, and compliant boots are to be fully laced. People who have lived in Redwings constantly ask why, and the standard answer (from the company) is that compliant boots provide ankle support thereby reducing the incidence of ankle injuries. A noble aim, but I have to ask, “Where is the evidence?”
I asked the Department of Mines and Petroleum for their data on ankle injuries. Figure 2 shows the incidence of all ankle injuries from 1987 to 2010. These injuries include sprains, strains, fractures, contusions, swelling and other musculoskeletal problems. There is an obvious, and major, reduction. The question is, “What caused that reduction?”
What we do know is that the late 1970s saw the start of mine mechanization. Airleg, shaft mine technology hadn’t changed much since seven short fellas looked after Snow White. Tramping round drives and stopes on blasted rock was to invite ankle injury. Now, most workers sit in a cab (frequently air conditioned) and are most at risk of ankle injury when they climb out. In any case, this rule about boots arrived in the 2000s. It cannot be the cause of the big reduction.
Consider Figure 3. There is still some reduction probably related to ongoing mechanization. The actual figures are 3.43 in 1999-2000 to 1.34 in 2009-2010. There is no point where we can see the effect of boot style restrictions or any other single factor.
Why then was this rule brought in?
Quite simply, it sounded like a great idea to someone in an air conditioned office on Main St. Unfortunately, nobody bothered to check the facts. It must have appeared obvious that the wearing of compliant boots would reduce ankle injuries. As we have seen, compliance played no part in any reduction. Furthermore, site workers know this intuitively. Consequently, site workers constantly rail against the rule.
One serious consequence of this is that they regard with the deepest suspicion any OSHA conscientious enough to insist on compliance with the rule. That suspicion carries over to any other requests for compliance, however well-founded those requests might be. These other requests are simply seen as more pettifogging and to be ignored or, at best, suffered. Your OSHA's reputation is irreparably tarnished.
The point is this: “If you are going to pontificate site rules from head office, write the rules on the basis of facts!” If you don’t, you can make your OSHA’s life more difficult than it already is.