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The Case Against OSHA Recordable Frequency Rates:
Defining the Fallacy - - Repairing the Damage

Determining accurate methods of measuring safety performance is a formidable challenge. Unfortunately, the only widely accepted metric is frequency rates of OSHA recordable injuries and illnesses. This inaccurate, arbitrary, and downstream measure has been the impetus for much chaos in the field of safety. Using OSHA recordable rates distorts the true picture, measures failure, is reactive, and leads organizations to make bad decisions.

Incentives to not report – and disincentives to report – are widespread and extremely influential, hence injuries and illnesses are not reported and valuable information is driven underground. Organizations waste an inordinate amount of time and resources attempting to manage this inveterate system instead of proactively focusing on meaningful data that more accurately assesses safety systems and critical upstream indicators.

Simply put, the numbers are easily manipulated, and there is often extreme pressure to do so. Great efforts are routinely expended to keep an incident from becoming an OSHA Recordable case, and can often range from extreme to ridiculous. As the misuse of frequency rates falsely drives rates lower and lower, the damage becomes increasingly detrimental. The lower the rate, the greater the impact one OSHA recordable has on the rate. The greater the impact, the more consternation and chaos ensue.

Consequently, excessive attention is paid when over-reacting to an OSHA recordable injury without regard to incident severity or hazard potential. With the emphasis on OSHA rates, efforts to correct hazards with much greater injury potential, such as fall hazards, lockout violations, or explosion potential, are neglected.

There is no doubt that this system is seriously defective. In August of 2009, federal OSHA began a year-long, $1 million National Emphasis Program (NEP) on Recordkeeping following a derisive report by the General Accounting Office and academic studies that clearly concluded gross inaccuracy in the current system. More recently, in 2010 OSHA announced the extension and expansion of the NEP through 2012.

These governmental activities unequivocally confirm that the problem is significant and widespread. What it does not feature is that OSHA itself is at the root of the problem. It is OSHA that mandates this system, and bases much of its decision-making on this system that it now admits is flawed. However, business and industry has intensified the problem by using Recordable Frequency Rates in ways not required, or intended, by law. The GAO report points out that many organizations compound the problems by developing safety programs that incentivize the under-reporting of injuries and illnesses.

The solution to this massive conundrum will require a total paradigm shift where the current OSHA Frequency Rates are viewed as a defective measurement system that must be remedied in a holistic fashion. If OSHA attempts to remedy the problem only through tougher enforcement without addressing the root cause, a grossly inefficient and costly battle will ensue between the regulators and those being regulated. Tougher enforcement only will be focused on symptoms of the problem that are manifested in business and industry – poor recordkeeping. A more balanced approach should include an inward look by OSHA to evaluate its misuse of injury and illness data, and the various ways that they have perpetuated the unintended effects of placing too much emphasis on rates.

A balanced approach should also include intense and immediate efforts by business and industry to properly record workplace injuries and illnesses by eliminating all incentives and pressures to not reporting, and removing all other barriers to reporting. OSHA can provide guidance here, too, by clearly specifying that injury and illness rates are not to be used in ways that will encourage underreporting. For example, OSHA should require that frequency rates not be used as a key criterion in contract bidding where competing firms are strongly encouraged to underreport if they are to remain in contention.

The movement to significantly alter and correct the use of OSHA Recordable Frequency Rates is emerging on many fronts. This correction is strongly desired, eagerly anticipated, and openly welcomed by all stakeholders – OSHA, organizations regulated by OSHA seeking better safety measurement systems, individuals responsible for ensuring accurate data, grass root employees who detest the current system, and safety professionals desiring to legitimize their efforts. These stakeholders, working in concert toward this common goal, will be the impetus driving this significant and much needed change.

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