SAFETY
entries on the OSHA Form
300 and that entered on the
OSHA form 301, (basically
individual accident reports).
The summary page, (the
300A) would still be submitted
annually.
Establishments with 20 or
more employees in certain
designated industries would
have to upload the OSHA
300A summary information
on an annual basis, but not the
300 log information or the 301
forms.
Some establishments of
OSHA’s choosing will receive
notifications to upload
information “for the time
period and at the intervals
specified by the notification.”
In the summary section
of the proposed rule, it
states: “The purpose of this
rulemaking is to improve
workplace safety and health
through the collection
of useful, accessible,
establishment-specific data to
which OSHA does not have
direct, timely and systematic
access.”
This stated purpose prompts
a thought process in my
mind: It currently seems
requests for lagging safety
indicators and the seemingly
endless input required in the
safety networks continues to
increase. I am amazed that as
safety-related requirements
become increasingly difficult
across the country, (several
plants now require TRIR’s at
roughly 75 percent below the
national average), the majority
of service providers are still
able to comply. Somehow,
thousands of contractors
are able to achieve safety
performance and metrics that
19
FEBRUARY 2014
ACT
inspection.
OSHA is able
to inspect only a very small
portion of contractors. In
2010, inspections took
place in one percent of all
establishments under their
jurisdiction, (98,000 out of a
possible
7.5 million).
■
Through survey data
collected.
The OSHA Data
Initiative, sends out roughly
80,000 safety metrics
surveys each year. Due to
the the time required to
calculate the data it is usually
two to three years old by the
time OSHA analyzes it.
■
Through received
reports of fatalities
and multiple
hospitalization
incidents.
Each year
OSHA receives less than
2,000 establishment specific
reports of fatalities and less
than 20 reports of multiple
hospitalization incidents.
Although we at times feel
differently, particularly during
an inspection, these statistics
show us that “the long arm
of the law,” at least when it
comes to OSHA, is actually
quite short. A new proposal
is aimed at increasing this
oversight. The proposed rule
titled, “Improve Tracking
of Workplace Injuries and
Illnesses” is available for
review at OSHA.gov. I have
listed a very brief summary
below:
Establishments currently
required to keep illness/
injury records with over 250
employees will be required
to electronically submit
these statistics to OSHA
on a quarterly basis. The
information would include the
‘‘
Although
we at times
feel differently,
particularly during
an inspection, these
statistics show us
that ‘the long arm
of the law,’ at least
when it comes to
OSHA, is actually
quite short.
THE AUTHOR
Daniel Erwin
is director of
safety for TNT
Crane & Rigging
in Houston.
An OSHA proposal
could increase
the oversight of
workplace injuries
and illnesses.
meet the increasingly higher
standards of clients. [This level
of safety performance doesn’t
appear to reconcile with what
the industry statistics tell us is
actually happening.]
In closing, after my review of
this proposal a few things are
certain:
■
OSHA would have much
more information to
analyze, review and
quantify for their purposes.
■
Companies would be
reporting data on a much
more frequent interval to a
regulatory agency.
What is not as certain is:
■
Does more reporting truly
increase workplace safety?
■
What will an increased
reporting requirement
to the group in charge
of compliance do to the
accuracy of our
reporting?
■
No place
to hide
O
ne of my small
children is a picky
eater. He knows
that if he eats he is rewarded,
and if he does not he is
punished. I recently watched
from a distance as he sat at
the table alone. He looked
around, made sure no one was
watching, and placed what was
left of his food in his napkin,
which he discreetly put in the
trash, for which he also was
punished. He decided the risk
of getting caught was worth
the potential reward of not
having to continue to eat.
How does this experience
compare to the process of
reporting workplace illness
and injuries? Companies are
required to report certain
workplace injuries and
illnesses. This reporting in
turn can result in the threat of
decreased business, increased
insurance premiums,
declining safety performance
metrics and the potential of
government intervention
and a lack thereof can result
in the inverse. Like my son
who thought he was alone,
the process of recording
these events is done largely
in private with little risk of
oversight.
Under our current system,
OSHA can only review a
company’s safety metrics in
one of three ways:
■
Through an OSHA
