Category: Injury & Illness Reporting
The current news articles about the concerns raised about metrics manipulation associated with the VA Electronic Wait List reminded me of the similar concerns that have been raised about metrics manipulation related to the reporting of workplace injuries and illnesses.
One of the recurring problems with metrics is attempts to “game the system.”
Interested in finding out more?
Check out the latest issue of my Ethics in Focus newsletter – Metrics Manipulation.
This newsletter is a part of a new web-based course that ENLAR is offering in partnership with AIHA – Ethics for the OH&S Professional. This interactive course meets the CEU training requirements set by ABIH for CIH’s to maintain their certification.
(NOTE – This edition of the newsletter also contains links to the GAO reports on the disincentives for reporting workplace injuries and the OSHA guidance on the use of safety incentive programs. As set out in the OSHA guidance, “Reporting a work-related injury or illness is a core employee right, and retaliating against a worker for reporting an injury or illness is illegal….”)
© ENLAR Compliance Services, Inc. (2014)
Many companies are increasing including some type of “injury and illness data” in their sustainability reports. It is one of the metrics included in the GRI reporting scheme. It is used both internally and externally to determine financial bonuses. It is also used by a number of companies and governmental agencies to select qualified contractors. There is a great deal of pressure to report low numbers.
The question is – “How accurate is this data?”
There are many who believe it isn’t very accurate at all.
As I discussed in a previous blog, there are strong incentives for under-reporting and, very often, little or no independent verification of the numbers. This is even the case for many of the processes and web-based tools used by major companies to select contractors.
Safety professionals may want to re-assess the risks associated with the creation and external reporting of injury and illness data.
Companies may want to re-assess their reliance on data that has no independent verification.
Because, given the results of a recent court case, inaccurate reporting can be considered fraud and those involved can go to jail.
In early November 2012, a jury convicted a safety manager for The Shaw Group of eight counts of major fraud against the United States. They found that he had provided false and misleading information about injuries associated with work at TVA (Tennessee Valley Authority) facilities. This false injury data was used by his company to collect safety bonuses worth over $2.5 million. (Note – According to the DOJ press release, The Shaw Group entered into a civil agreement in 2008 with the United States and paid back twice the amount of the safety bonus they collected.)
What to know more about verifying injury and illness data?
© ENLAR Compliance Services, Inc. (2012)
Dr. John Howard, Director of NIOSH, gave the keynote presentation last Tuesday (June 19, 2012) at the American Industrial Hygiene Conference (AIHce). In his talk, he focused on 7 trends that will define the future of occupational health and safety – demography, employment, discrimination, disability, governance, standards and professionalism. In this blog post, I will focus on one – employment trends.
As Dr. Howard put it, “A job is a dying concept.”
He went on to elaborate – In prior generations, security was what defined employment; today, it is precariousness. Work is increasingly contingent and less secure. There is no promise of continuous employment – or, in a great many work situations, of even being considered an “employee.”
According to Dr. Howard, this employment trend has a significant impact on occupational health and safety. Within the current legal structures governing worker protection, non-employee workers are often unrecognized and unprotected. Both workplace safety regulations and injury compensation schemes are based on one’s status as an employee. Yet, the risk of injury or death in the workplace is not related to a legalistic definition of employment – whether you are an “employee” rather than simply an individual laboring in the workplace.
Later in the week, Mike Wallace, from the Global Reporting Initiative (GRI), gave a presentation on the evolution of sustainability reporting and the need for new metrics for evaluating organizational performance related to occupational health and safety.
He started his presentation with the following statistic – annually 2.3 million workers die across the world. It is clear that workplaces are not safe and worker protection is often missing.
He sent on to note that, in the past, safety professionals have “stayed on the sidelines” in defining OH&S metrics for measuring organizational performance – unlike their environmental counterparts. Creating comparable metrics is often viewed as “too complex” and “too time consuming.”
Is creating OH&S metrics really more difficult than
creating metrics to address global climate change?
GRI is currently soliciting public comment on new OH&S metrics for inclusion in the GRI reporting scheme. Unfortunately, to date, the metrics being used, as well as those being proposed, fail to take into account the employment trends highlighted in Dr. Howard’s presentation. In particular, they continue to link OH&S performance metrics to “employee” protection NOT “worker” protection.
In my view, what is needed is new metrics. Metrics that are specifically developed to promote worker protection – not the perpetuation of metrics based on definitions of employment that has little relevance to today’s economic realities.
© ENLAR Compliance Services, Inc. (2012)
There is a renewed interest in management systems on metrics.
This interest seems to be driven by two organizational concerns – transparency and risk. In particular, it appears to be driven by the risks associated with transparency.
I attended the ISO 9000 Conference earlier this week.
One of the keynote speakers – Bennie Fowler from Ford Motor Company – discussed how Ford has refocused on its core principles in order to achieve a financial turn-around. This includes a re-emphasis on the principle – “Quality is Job #1.” At Ford, quality is now an integral part of executive strategy discussions.
One of the main drivers for this renewed emphasis on quality is transparency.
Due to the “open communication” nature of the intranet, companies can no longer hide their quality problems.
Today, delivering a quality product every time is key to survival. If a company does not, its quality issues are likely to be reported on the intranet for all to see.
Other speakers discussed the on-going shift in focus from product quality to organizational quality. According to surveys, consumers often buy products because of their perception of the company rather than because of any objective evaluation of the quality of a particular product.
This means that organizational risks become marketing risks.
This customer focus on organizational quality is one of the drivers in the increase in corporate sustainability reporting. Customers are interested in whether a company is a good corporate citizen. They want to make sure their brand loyalty is justified.
But are these numbers true?
If the studies that have been conducted on the accuracy of injury reporting are to be believed, maybe not. (Click here to go to a previous blog post about injury and illness reporting issues.)
There is no global standardization, no accountability (as in a third-party review of the data or processes used to develop the data) and definitely no transparency for injury and illness metrics. There is no easy way to check the numbers being reported, nor is the information available to do so. Right now, we simply have to take the company’s word for it that these “metrics” are accurate.
Quality is being driven by the risks of transparency; safety is not.
© ENLAR Compliance Services, Inc. (2012)
OHSAS 18001 requires that organizations establish procedures to encourage worker participation in the OHSMS. In some companies, worker participation is equated to establishing some sort of incentive program such as safety bingo. The premise of many of these programs is as follows –
As long as there aren’t any reported injuries, participants in the safety incentive program have an opportunity to win a case prize. However, if an injury is reported, the game stops and the cash prize is either eliminated or substantially reduced for everyone.
Supposedly, these incentive programs build safety awareness. Critics contend that they simply impact reporting of injuries without any underlying improvement in safety. In other words, they drive safety reporting underground. Interesting, based on the results of a poll conducted in June 2010 by SafetyNewsAlert, this is the view of over 60% of the safety professionals who responded.
In his keynote presentation at the AIHce earlier this month, the head of OSHA, Dr. Michaels, re-iterated OSHA’s strong disapproval of safety incentive programs that discourage injury reporting. He went on to point out that they are also potential violations of Section 11 of the Occupational Safety and Health Act. (Click here for a related article from National Safety Council Safety+Health Magazine)
What does this mean for organizations establishing procedures to meet the participation requirements of section 4.4.3 of OHSAS 18001?
Forget gimmicks. Put processes in place for real worker participation in the OHSMS.
© ENLAR® Compliance Services, Inc. (2011)
I was struck by the contrast between two news stories that came out in the last week reporting on occupational injuries and illnesses — one in the United States and one in India.
The first was a press release from the American Society of Safety Engineers (ASSE) in which the President of ASSE applauded the apparent drop in workplace injuries and illnesses recently reported by the US Bureau of Labor Statistics. According to the preliminary BLS report, the overall rate of both fatal and non-fatal work injuries in the United States dropped in 2006. Acccording to the BLS press release, there were 153 fatalities from expsoure to harmful substances or environments for all US workplaces in 2006.
The second was a news report from the Indian Express entitled “Ticket to Hell” that reported that 227 sanitary workers employed by the Pune Municipal Corporation died in just the last 30 months. This news report goes on to ask: “[I]sn’t it incredible that an occupation as horrifying as cleaning the sewers of the city in the most primitive fashion possible should need a newspaper report to ensure something as basic as protective gear and health insurance for those who risk limb and lung every minute of their working life?”
© ENLAR® Compliance Services, Inc. (2007)