Workplace Injury Recordkeeping: New Rules

The long-debated rule requiring employers to annually submit their injury data to OSHA has become a reality. In the past, injury data was kept internal to a company unless OSHA or DOL requested that information. But no more!

The 2016 injury data for nearly every employer in the U.S. must be sent electronically to OSHA by July 1, 2017. For 2016, the only form employers must send OSHA is the 300A Summary. But starting with calendar year 2017, ALL injury data forms must be sent to OSHA. This includes the OSHA 300 Log (which contains the names of injured employees), the 300A Summary, and the 301 Incident Investigation form (which includes details of the incident, medical treatment received, the injury cause, and what the employer is doing to prevent similar incidents in the future).

As if this is not enough, OSHA will make much of this data available to the public. Beginning next year, your “dirty laundry” about injuries in your workplace (employee names will NOT be made public) will be posted for anyone and everyone to see on the OSHA website.

The rule also prohibits employers from discouraging workers from reporting an injury or illness:

  • Requires employers to inform employees of their right to report work-related injuries and illnesses free from retaliation.
  • Employer’s procedure for reporting work-related injuries and illnesses must be reasonable and not deter or discourage employees from reporting.
  • Prohibits retaliating against employees for reporting work-related injuries or illnesses.

It’s a new day, folks. If you have not been able to think of a good enough reason to reduce the number of injuries in your workplace, perhaps this new rule will light a fire.

Want to learn more about the new rule on electronic reporting of injury data to OSHA, as well as other information about OSHA injury reporting requrements? Sign up for this audio conference!…


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The Zero-Injury Witch Hunt

The Zero-Injury Witch Hunt.

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Right Tool For The Job: Is It Really A Tired Argument?

Once again, some of the more prolific safety bloggers on sites like LinkedIn are proclaiming that they have “the truth” about what works and what doesn’t when it comes to safety management and injury prevention. A current claim is that some safety management tools just don’t belong in the toolbox of any enlightened safety professional. The position is that slogans or BBS are such old technology that it’s akin to bloodletting; any use of tools like slogans or BBS are only for those that refuse to see the “truth” that these tools are not only outdated but dangerous. Some bloggers go so far as to refer to safety professionals that insist on using any part of “outdated” concepts like BBS as “knuckle-draggers”.

The argument is made that BBS is about blaming the majority of workplace injuries on deliberate and conscious employee behavior and that the intent of BBS is to modify and control the behavior of a population. Perhaps there are some BBS practitioners that believe this, but I don’t think this is so of the more reputable organizations that utilize BBS as one of their tools in injury reduction. In fact, I have never spoken with a BBS proponent or practitioner that did believe this to be true. Those that I have discussed this with understand that the human mind is complex. They understand that we make conscious and deliberate decisions and that we also make unconscious decisions. To throw out all of the concepts of BBS as “snake oil” and to state that there is no place for behavior modification is to say that we have mastered the workings of the human mind and have determined that understanding human behavior is of no value in safety management.

Behavior modification has been used for many years in dealing with changing our lives for the better. It’s used in therapy to help people with addictions; people that are not necessarily making a conscious and deliberate decision to be mired in substance abuse. My understanding is that there are often underlying issues that lead a person to abuse certain substances even though consciously they don’t want to do so. It is also my understanding that behavior modification can help a person better understand WHY they do what they don’t want to do. Am I saying that all safety professionals are equipped to embark on a journey of understanding human behavior and making attempts at behavior modification? No. But there are those that have been educated and trained in this field sufficiently that they can help in leading an organization to use certain concepts of BBS, including observation and feedback, in reducing injuries.

What about safety slogans? Are these entirely useless? Perhaps. I think it depends on the organization’s culture. If there is a culture of trust and respect, I believe that slogans and campaigns can help a team to focus. But in an organization where there is mistrust and fear, slogans could be not only of no value, they could do even more to increase the gap between management and front-line worker.

Only you and your organization can determine which tools are of value to you. A tool like BBS could be beneficial in an organization with a mature, trusting culture, but that same tool in another less-developed culture could be dangerous and damaging. I believe the same holds true for any of the many tools available to the safety professional. Just because another person believes these tools are outdated and don’t belong in ANY safety professional’s toolbox does not mean it is so. Just because those tools are of no value or are dangerous to THAT person does not mean they can’t have value for you and your organization. That decision about what is right for your organization is up to you; not me or any other blogger.

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Right Tool for the Job

I see lots of articles on LinkedIn and various blogs about how some methods used in workplace safety management are of no value, or worse, these tools are straight from Hell itself. I’ve read that things such as BBS (Behavior Based Safety), measuring safety performance, or computer based training (CBT/WBT) are not to be used by the right-thinking safety professional. Some safety professionals are saying that these methods are “snake oil” and those that promote the use of these methods are con artists. But I think we may be looking at these methods incorrectly.

My father was a carpenter and he had this massive tool box that went with him on most jobs. It was like the rolling, multi-drawer metal toolboxes you might see today at an auto repair shop, except his was made of wood and he built it himself. He had literally hundreds of tools in the drawers of that toolbox, and each had specific functions. I can’t imagine one of his co-workers saying to him “I don’t know why you keep that #3 Phillips screwdriver in your toolbox; it doesn’t work on a #2 Phillips screw”, or “Why do you have that cross-cut saw? It can’t be used in cutting out a pattern”. It’s really no different when we talk about the various methods, or tools, used in workplace safety management. BBS, CBT, measuring safety performance…these are all just tools that are available. And they don’t work when used for the wrong job.

For example, trying to implement BBS in a place where the organizational culture is one of fear and mistrust would not be effective: in fact, it could be quite harmful to the organization. Additionally, thinking that BBS is the ONLY method to use for safety performance improvement could also be harmful to the organization. BBS is a tool, but it does not focus on identifying and correcting hazards, whereas another tool such as Safety Management Systems do focus on hazards. BBS could be used as a tool in providing an opportunity to perform tasks safely, and then coach individuals on what was observed and discuss decision making in job performance. But if BBS is used to “catch” people or to place blame, individuals involved might be perceived as “safety cops”, not something that is seen in a positive light in most organizations. BBS is just a tool that has correct and incorrect uses.

Another error we might make is measuring safety performance by just looking at injury numbers; this does not tell you what is and is not working in your safety system. Proper use of safety metrics can drive performance toward more efficient use of resources, improved compliance and profitability, and improved general health and well-being of an organization and its workers. But metrics in themselves will not achieve excellence. They do, however, provide a “window” through which management can see the effectiveness of their systems. Injury rates, a lagging indicator, are a measure of our failure, but we can use leading indicators to focus on future safety performance, not the past. Some examples of leading indicators include:
• Perception surveys
• Findings from Safety Audits/Inspections
• Behavior Observation Data
• Number of Job Hazard Analysis (JHAs) performed
• Percent of corrective actions completed
• Number of Lock-out/Tag-out procedures reviewed each year
• Percentage of purchasing contracts that include safety requirements.
• Average time to act on safety suggestions.
• Percentage of funds allocated for safety suggestions

Safety performance measurement is just a tool that has correct and incorrect uses.

Some authors and safety professionals would have you believe that using CBT for safety training will damage your organization’s safety culture. When it comes to training our employees, we need to realize that using CBT as the ONLY delivery method for all of our training will not result in an effective transfer of knowledge and skills. But to use a blanket statement like “CBT is Bad For Your Safety Culture” does a great disservice to a tremendous learning tool and may steer employers away from something that can improve their safety culture, not destroy it. CBT was never meant to replace all classroom training. Some subjects require a significant amount of hands-on training and need to be delivered via classroom, lab, or on-the-job training. But this does not mean that CBT can’t be effectively used to cover some of the details that would normally be covered in classroom lecture format. CBT is just a tool that has correct and incorrect uses.

This was a discussion of just a few of the many safety improvement tools, each that can be used correctly or incorrectly. As safety professionals, we have a variety of tools available to us today to help ensure the safest workplace possible. Why limit ourselves by refusing to keep our toolbox full of these tools? It all boils down to using what works. No one system, process, or theory has all of the answers. The key is in selecting the right tool for the job.

If you would like to learn more about some of the many tools we have to choose from, please check out some of my live and recorded audio conferences:

Behavior Based Safety: What Works, What Doesn’t, and How It Can Help Your Organization:

How to Use and Understand Safety Metrics:

How to Develop and Conduct Safety Training:

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Safety Metrics: Measuring What Matters Most

You’ve worked hard at developing a safety system for your organization. How do you know if it is delivering the best results possible? Is your safety system meeting the goals you established? They way to know for sure is through Safety Metrics, also called Safety Performance Measurement.

Simply put, Performance Measurement is a means to show how well we are doing in achieving an objective or goal. It indicates what a program is accomplishing and whether results are being achieved, and it provides information on how resources and efforts should be allocated to ensure effectiveness.

Benefits of Performance Measurement
Performance Measurement is a continuous improvement tool that provides many benefits. Performance Measures are effective tools because they:

  • Help us make informed resource decisions; decisions are based on fact, as opposed to emotion.
  • Drive a process by focusing on Things that are Important.
  • Help us better understand our processes.
  • Identify if we are meeting customer (internal & external) requirements.
  • Identify where improvements need to be made.
  • Verify the effectiveness of corrective actions.
  • Serve as an early warning of problems or conditions that could lead to serious error.
  • Demonstrate accountability to all concerned.
  • Allow us to benchmark our performance with other organizations.

Many organizations use only Lagging Indicators in their measurement system. While these are important, and in fact are required to be kept as directed by OSHA regulations, adding Leading Indicators can help us to see where we need to improve. In fact, Leading Indicators can actually serve to prevent injuries rather than simply report on injuries that have already occurred. Here are some examples:

Lagging or Trailing Indicators

  • Lost work time,
  • Injury rate,
  • Work restrictions, etc., and

Leading Indicators or Positive Performance Measures 

  • Proactive measures to control or prevent injuries.
  • Number of scheduled inspections completed.
  • Percentage of Lockout/Tagout procedures reviewed annually.

“Measuring the effectiveness of safety programs usually becomes an assessment of accident statistics. This is basically an exercise in measuring luck” Dan Petersen

But a solid performance measurement system does not just happen; research and planning are essential. The 4 key steps in developing a Performance Measurement System are:

  1. Strategic objectives are converted into Key Goals,
  2. Metrics are established to compare the desired performance with the actual achieved standards,
  3. Gaps are identified to allow us to understand performance, and
  4. Improvement actions are initiated.

There are a variety of tools that can be used in measuring safety. Some of these tools are found in the improvement methodology known as “Lean”. In Lean terminology, poor safety is a form of waste. Using Lean methodologies, we can incorporate safety into process and production plans and thereby achieve goals in improved worker health, reduced costs, and increased value.

There is much more to using Safety Metrics and bringing LEAN methodologies into the picture. View my recorded Audio Conference titled “How to Use and Understand Safety Metrics”  to learn more about how metrics can help improve your safety management system and your safety culture as well. For more information or to register, visit:


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Safety PR and Crisis Communication: Are You Ready?

A terrible accident has happened in your work place. An employee falls from a ladder, lands on his head, and dies at the scene. This is one of the most terrible events that can ever occur within any organization. Immediately after the employee’s death, there is confusion, guilt, sadness, anger, and a myriad of other emotions. What is the first thing you should do? What do you say? How do you say it? To whom do you say it? The decisions made and actions taken after any type of crisis situation can spell disaster for your organization.

Don’t think “It’ll Never Happen Here!” A crisis may happen anywhere – anytime, and high profile organizations are more susceptible to some crisis. It is a fact that bad things CAN and DO happen to good organizations. It’s essential to understand that new threats develop regularly, that we need to be aware and be ready.

Let me say first that I am not an attorney and nothing in this article should be construed as legal advice. The information and suggestions here are from my own experiences and understanding of dealing with crisis situations in the workplace. I strongly encourage anyone that is dealing with a crisis to seek out qualified and experienced legal advice.

In a catastrophic event, your every word, every eye movement, every emotion that shows, will resonate with those around you. In a crisis event, communication is different. Uncertainty is one of the greatest concerns for most, so it’s important to reduce anxiety and demonstrate that things are under control. But instead of making promises about outcomes, express the uncertainty of the situation and a confident belief in the process you are using to fix the problem and to address public safety concerns.

The consequences of a crisis can be far and wide and can lead to devastating results. What happens or is done on one front will impact what happens on another. This includes issues like litigation, law enforcement, regulatory agencies, the community, clients/customers, the press, business partners, employees, etc.

Two key issues to consider in crisis communication include the need to instill confidence and to provide information to all concerned (employees, family, police, government investigators, local news media, and public). The bottom line is that we want to have the public respond, en mass, in a logical, predictable manner designed to ensure the greatest good to the greatest number.

One thing for sure is that we must act quickly as bad news travels fast, especially in today’s world of social media which tends to thrive on bad news. By acting quickly, we can preserve the organization’s reputation and control the information that the public, employees, etc. receive. It does take work, but it’s much simpler than rebuilding a damaged reputation.

The KEY to success or failure is effective, caring, and honest communication. Before with employees (training) and media. During with employees, media, outside responders, regulatory agencies. And After with employees, media, regulatory agencies, contractors.

No doubt, there will be lots of questions from every direction. While you can’t always prevent the crisis, you can be prepared by understanding what sort of information people will want to know, such as:
• What caused the accident?
• What is the organization’s procedure to handle such an incident?
• Will there be an investigation?
• What is being done to mitigate the risk?
• Has this happened before? If so, when?

Of course, there will also be lots of rumors going around. Immediately dismissing a rumor is a dangerous move. Take everything you hear seriously, but with a grain of salt and investigate rumors before you comment. Correct wrong information quickly and thoroughly. Try to persuade those with unconfirmed incident information not to publicize it until official confirmation is received. It is extremely easy for information to be published very rapidly on blogs and social media, and it can be extremely distressing if the next of kin of a victim finds out about an accident through such unofficial, unconfirmed channels.

The goals of your crisis communication should be to protect your organization’s reputation, reduce tension, demonstrate commitment to values, to communicate promptly and continuously, to maintain control of the flow of information, and, of course, to end the crisis.

So what can you do? Think carefully about the messages you send out. Consider using just two to three key messages that include things like: Facts, Concern, Commitment, and Actions to take. I suggest that these be no more than ten seconds each and no more than 30 words, and then keep repeating these three messages. . .
Famous Example: STOP! DROP! ROLL!

There are some keys to navigating a crisis; these include:
• Consider, above all other factors, the health/safety of visitors, employees, public and community.
• Gather all facts as rapidly as possible.
• Immediately notify, and maintain contact with, appropriate local authorities (Police, Fire, etc.).
• Notify legal advisers when appropriate.
• Maintain records of all proceedings.
• Encourage candid discussion of solutions.
• Communicate quickly and fully with one another and public.
• Develop answers to predictable questions.
• Monitor events and adapt as necessary.
• Lead and facilitate investigation.
• Don’t be afraid to say “I don’t know”.

There is much, much more to consider in crisis communication, including how to deal with the media, press releases, matching the message to the audience, how to use social media to your advantage, understanding risk communication, putting together a crisis management plan and team, and understanding the skills required of a spokesperson. All of these, and more, will be covered in my upcoming audio conference titled “Safety PR: What To Say When A Serious Incident Hits Your Organization”, February 3, 2015. Learn more or register at:

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OSHA Injury Recordkeeping: Avoid Costly Mistakes

Did you know that more than half of OSHA inspections end up with violations of the OSHA Recordkeeping Standard? Most employers are filling out the required forms, but they’re not doing it correctly, which can result in fines. This is not unexpected, as the OSHA rules for classifying an injury and completing the forms can be confusing. There are some common mistakes made, and with a little attention to detail, one can avoid these errors.

First, we need to understand the difference between Recording and Reporting:

  1. We Record certain workplace injuries on the OSHA 300 forms when specific criteria is met.
  2. We must Report to OSHA, by phone or in person, specific events including: Death, hospitalization of 1 or more employees, any amputation, or loss of an eye.

A workplace injury must be Recorded (on the OSHA 300 forms) if it occurs in the work environment and results in one or more of the following: Death, Days away from work, Restricted work activity, Transfer to another job, Medical treatment beyond first aid, Loss of consciousness, or Significant injury or illness. There are some exceptions, including injuries resulting from taking medication, personal grooming, or during voluntary participation in a wellness program.

One question often asked is “What is the work environment?” Well, OSHA’s definition may not necessarily be what you and I think. OSHA says the work environment is primarily composed of: (1) The employer’s premises, and (2) other locations where employees are engaged in work-related activities or are present as a condition of their employment. OSHA considers most locations where an employee is doing “…activities in the interest of the employer” to be the work environment. Generally speaking, this can include working from home, traveling for business, and even injuries that happen in the company parking lot. There are exceptions and specific criteria that must be met. For example, injuries that occur during an employee’s commute are generally not considered work-related. Additionally, whether an employee is “on the clock” or not has no bearing on determining if an incident is work-related. That means, if an employee is injured during their break time, it could qualify as being work-related unless it meets one of the exceptions.
One of the common errors I have seen concerns recording the injury of a contractor employee. Under OSHA rules, it is the organization that supervises the contractor employee on a day-to-day basis that is responsible for recording the injury. This includes temporary workers that you supervise on a day-to-day basis.
Another common error occurs when completing the OSHA 300 Log. There are several columns on the Log that must be completed; some of these columns require the employer to enter a number or text, and some require the entry of an “X” or check mark. Mix these up and you can end up with a $5,000 fine. One mistake that happens often is not properly describing the injury on the OSHA 300 Log. This column on the Log requires that the employer enter 3 things: (1) a brief description of the injury, (2) what body part was affected, and (3) what directly caused the injury. A correct example would be “Fracture, Left leg, Fall from ladder”. An incorrect entry might look like this: “Broken arm”. The problem with this entry is that the body part was not identified, nor was the injury cause. When identifying the body part injured, the employer must be specific, including not only naming the body part but identifying right or left, etc., if there is more than one of said body parts.

Completing the OSHA 300 forms is something most employers are required to do, and it’s also something that many employers are not doing correctly, which can cost you. If you want to learn more about common mistakes made in OSHA Recordkeeping, my next live audio conference on “How To Avoid OSHA Recordkeeping Mistakes” is January 20, 2015.

Please visit to view this event description or to register.

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