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Copyright © 2008, ORC Worldwide. All rights reserved. (Another…ugh) OSHA Recordkeeping Discussion…. "This is like déjà vu all over again.“ Yogi Berra
Copyright © 2008, ORC Worldwide. All rights reserved. “I don’t tell jokes, I just watch the government and report the facts.” Will Rogers
Copyright © 2008, ORC Worldwide. All rights reserved. Perceived Problems The OSHA data are not accurate Difficult to understand the complex criteria Some employers intentionally under report Some employees milk the system by over reporting OSHA definitions are overly inclusive and don’t make sense Include things that can’t be managed Include stupid stuff THE OSHA RK system is inefficient Too much time spent on contentious debates over whether or not something is “recordable” Push back by plant managers and others to keep information off the OSHA log The OSHA system does not meet critical needs for surveillance and for managing worker safety and health
Copyright © 2008, ORC Worldwide. All rights reserved. Importance for Business Industry uses OSHA records as the basis for “trailing indicators” Primary metric used to assess safety and health performance Used to benchmark internally and externally Used to benchmark domestically and internationally Data can be useful for some hazard analysis and risk identification Linked to Sarbanes Oxley Closer connection evolving to Sustainability and Corporate Social Responsibility
Copyright © 2008, ORC Worldwide. All rights reserved. Importance for Government BLS uses the data to: Produce national and state statistics (rates and numbers) of injuries and (acute) illness Help develop CFOI OSHA uses data to: Target individual establishments for safety inspections Support local emphasis programs & broader inspection targeting Qualify sites for voluntary programs Develop regulations and conduct regulatory impact analysis OSHA also uses data for performance measurement -- Government Performance Results Act (GPRA) NOSH uses the data to support S&H research OMB requires that Recordkeeping Audits be conducted as a prerequisite to OMB approval.
Copyright © 2008, ORC Worldwide. All rights reserved. Copyright © 2007, ORC Worldwide Scrutiny Increasing Several independent studies release dramatic findings 2006: The BLS survey missed up to 68% of injuries and illnesses in Michigan between 1999 and 2001. 2007: Rate of injuries in Illinois from 1995 – 2003 was really constant; not the 37.4 percent decline reported by BLS 2007: 83 percent of reported decline in injuries and illnesses from 1993 to 2002 can be attributed to changes in OSHA recordkeeping criteria. 2008: In six states BLS survey only captures 76 percent of all injuries
Copyright © 2008, ORC Worldwide. All rights reserved. Increasing Scrutiny cont. June 2008 Congressional Hearings: Hidden Tragedy: Underreporting of Workplace Injuries and Illnesses July 2008: Bill Moyers Special on PBS: 20,000 Cuts Accuracy of recordkeeping clearly a priority for the incoming administration OSHA detailed records checks likely to increase We may be on the verge of another “ perfect storm ”
Copyright © 2008, ORC Worldwide. All rights reserved. How Did We Get Here: Brief History Congress passed OSH Act in 1970 that mandated a new recordkeeping/statistical system Purpose of system was to produce aggregate national and state statistics – not reflect health and safety at company or facility level Broad coverage – all industries/all sized establishments Need for simplicity and ability to identify emerging conditions resulted in very inclusive requirements and definitions In a nutshell, the OSHA system was designed for surveillance; not to measure performance at individual sites
Copyright © 2008, ORC Worldwide. All rights reserved. As a Result… OSHA requirements = broad Work relationship = “geographic” OSHA rules include a finite list of first aid treatments – ALL OTHER treatments are considered medical treatment beyond first aid, and are recordable OSHA exceptions = narrow Mentality = “When in doubt, record.” For surveillance this makes sense…
Copyright © 2008, ORC Worldwide. All rights reserved. Evolution of Recordkeeping Definitions Initially developed by joint business, labor, government roundtable Definitions limited to back of OSHA forms Questions submitted by employers – eventually compiled by BLS into guidelines BLS “Bluebook” written in 1986 Revised rule issued in 2001
Copyright © 2008, ORC Worldwide. All rights reserved. What Happened To Shift Use from Surveillance ? Under Thorne Auchter OSHA began targeting entire industries based on the industry lost workday injury rates Business responded by pushing back on what was deemed recordable Union Carbide, Institute West Virginia was the first large RK citation 100 egregious willful recordkeeping citations in late ’80s Over time OSHA rates became the primary S&H metric
Copyright © 2008, ORC Worldwide. All rights reserved. Our Current Dilemma… OSHA system being asked to do too much Definitions that work for general surveillance do not work well for accountability and performance measurement purposes Domestic criteria hard to apply in a global business environment OSHA unable to fix the root cause of the problem – the misuse of the data as the sole metric for safety and health
Copyright © 2008, ORC Worldwide. All rights reserved. Solutions: One Perspective… 1.Improve the way the system functions 2.Address the root cause -- improve the use of the data 3.Recognize what the system does well and where it needs to be supplemented
Copyright © 2008, ORC Worldwide. All rights reserved. 1. Improving the Way the System Functions Clarify critical grey areas and eliminate the “stupid stuff” Develop an expert system OSHA should implement a cooperative compliance program to encourage use Employer signs statement they are using the OSHA software OSHA forgoes detailed records check and verifies they are in fact using it
Copyright © 2008, ORC Worldwide. All rights reserved. 2. Improving the Use of the Data System OK for injury and acute illness surveillance Not OK for performance measurement Leading indicators needed to drive and assess performance; agreed upon leading indicators needed for benchmarking An agreed upon subset of the OSHA data should be developed as an appropriate trailing indicator
Copyright © 2008, ORC Worldwide. All rights reserved. 3. Recognizing System Limitations OSHA system doesn’t work well for chronic and long term latent illnesses Why? Difficulty in recognition Influence of confounding factors on work relationship determinations Calendar year reporting of occurrence Alternatives: Capture occurrence at point of service Conduct household surveys Assess prevalence by occupation
Copyright © 2008, ORC Worldwide. All rights reserved. That’s all, folks!!
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