This week I had an enlighting discussion with another senior management group that was just way off base in their understanding of OSHA’s use of injury and illness rates. This company is in an industry that is certainly on OSHA’s radar, and their desire to improve safety is simply to reduce their injury and illness rates so they are less likely to receive an OSHA inspection than their competitors. If there is ever a sign from above that a group of executives has lost their way in their safety journey, this is it! So this injury rate discussion led to a discussion about their “safety metrics,” which, of course, were ONLY their Recordable Rate and DART rate. Their rationalization for these rates was simply these are the rates that OSHA uses to establish enforcement priorities, so if they are being used by OSHA for this purpose, why would we not use them? The answer is quite simple, but I believe it can be quite difficult for many management groups…
The “OSHA rates” devised by OSHA over 50 years ago were intended to look at VERY LARGE groups of workers, much like an entire industry sector. In this huge group of workers, there are enough data points to increase the accuracy of the injury rate. This use is exactly what OSHA had in mind when they created these rates – to examine industry sectors, NOT individual employers, and certainly NOT individual facilities within a company.
But somewhere along this journey, we got way off course and somehow decided that if OSHA can use these rates to direct their inspection and enforcement efforts, maybe we should use them to direct our efforts. And this is where we fundamentally lost control of OSH – we began chasing a lagging indicator and even began rewarding employees based on this lagging indicator.
These metrics were created and have a viable use by OSHA – they have very little use for employers. They can be used to validate our leading indicators in a very mature Safety Process/SMS. Still, even then, if there is a hint of these rates influencing management, the rate(s) may be manipulated. I can live with Safety Goals being set based on these rates as long as the management group can realize the immaturity of this approach and understand that world-class safety does not use rates as goals. But in the early days, the BOD/Execs can establish safety goals using the Injury Rate and DART rate; then, it is our job to establish a “plan” (e.g., our process/SMS) to achieve those goals. We MEASURE the process/SMS to ensure the right amount of activity, the activities are the right ones, and they are of high quality.
