Let’s talk about DE-incentivising businesses to properly manage Occupational Safety and Health (OSH), even at the most basic level. OSHA now requires businesses to report their injury and illness logs, which they will use to identify workplaces needing a compliance inspection. They are doing this due to their lack of adequate resources, and they want the businesses and industries to self-report their bad performance so that OSHA can “target” those businesses/industries. This is not my interpretation; this is precisely what OSHA stated in their need for this injury/illness data collection. If your business is still playing the “compliance games” with safety, then the business should be very concerned!
Is this really where we are in OSH data management in 2024?
Does anyone, for a second, believe that once a business/industry realizes what OSHA is doing with this data and the inspections and citations start piling up, these actions by OSHA will not consciously or subconsciously impact the data being reported to OSHA? We will see this in businesses doing the following, sometimes in genuine ignorance of what they are doing and, in some cases, knowing precisely what they are doing: Incentivizing employees NOT to report injuries and illnesses! (See my article last week story of “good intentions” with disastrous results for how this is done)
This injury/illness data analysis MUST be done at the facility level, which is one of the ONLY advantages to OSHA recordkeeping requirements. OSHA should hold businesses accountable for NOT doing these annual reviews of their injuries/illnesses AND generating action plans to address the trends identified in these annual reviews. Then, OSHA should hold those businesses accountable via citations for not doing these data reviews and taking the proper actions to reduce risks identified in these data reviews.
We need to shift to a proactive Safety Management System (SMS) approach and away from the reactive OSHA inspection/compliance approach. With that said, I have always supported OSHA’s Injury Illness Prevention Plans (I2P2) approach as it moves us toward a very simplified Safety Management System approach to OSH, much like the Process Safety Management standard (SIF model) did for catastrophic risks in the process industries. A 2010 proposal for an I2P2 rule included just six (6) elements of an SMS:
(emphasis by me) – pay particular attention to Element #6…
