Category Archives: Safety Management Systems

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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Filed under Safety Leadership, Safety Management Systems, Safety Regulations, Training, Uncategorized

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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What Behavior Based Safety (BBS) Is And What It Is Not.

BBS theory has been around for many decades, but in the past few years it has become increasingly popular among some businesses and with many safety professionals. The phrase Behavior-Based Safety in its strictest sense refers to the use of applied behavior analysis methods to achieve continuous improvement in safety performance. Behavior Analysis is promoted as the scientific study of behavior, with the primary objective being the discovery of principles and laws that govern behavior. I would say, though, that to be truly effective this must include all behaviors, not just those of the front-line worker.

Many proponents of BBS Claim it To Be:

  • An excellent tool for collecting data on quality of a company’s safety culture.
  • A scientific way to understand why people behave the way they do when it comes to safety.
  • When properly applied, an effective next step towards creating a pro-active safety culture where loss prevention is a core value.
  • Conceptually easy to understand but often hard to implement and sustain.

…But Claim It Is Not:

  • Only about observation and feedback.
  • Concerned only about the behaviors of line employees.
  • A substitution for traditional risk management techniques.
  • About cheating, manipulating people, and aversive control.
  • A focus on incident rates without a focus on behavior.
  • A process that doesn’t need employee involvement.

Yet some safety professionals with which I have communicated claim BBS is the only method to use in safety management and injury reduction. Others I have talked with claim that BBS is too flawed to be useful. BBS proponents often state that conditions do not cause accidents, behavior does. In fact, some BBS proponents state that more than 85% of accidents are the result of unsafe acts. This belief seems to stem from Herbert Heinrich’s theories developed in the 1930’s. Personally, I have not found any solid evidence of Heinrich’s “statistics”, yet time and again I see this so-called “fact” used to support the position on BBS. So, the Heinrich myth lives on. But does this mean there is no value to some concepts of Behavior Based Safety? No, I think there is value in BBS when properly combined with other methods.

BBS says safety is about people, and behavior is the challenge. But BBS does not focus on identifying and correcting hazards and is often seen as “carrot and stick”. Critics claim BBS emphasizes the worker without taking the system into account. Another approach to consider is that of using a Safety Management System (SMS) . The SMS uses planning, risk identification, analysis, operational control, directives and processes, and continual improvement. Safety Management Systems focus on hazards (which I believe to be the true source of injuries) and I would suggest that removing or reducing the risk of injury can be more successful than relying solely on BBS.

It’s important to note that an effective SMS is not about regulations or reprimands: it is about systems and using what works for the given situation. It’s also important to realize that there are pros and cons to both SMS and BBS methodologies. Safety management systems will always be flawed to some degree, as you can’t plan and control for every hazard. And systems can be inflexible while behavioral approaches may be more adaptive. However, behavior is hard to understand and change, while hazard identification and correction can be implemented easily in most situations.

Accidents are complex and a concentration on behavior alone can detract from finding other causes. But a focus on systems alone might overlook some behavioral issues; there are things in BBS that may be useful. So what are we to do? We need to understand that there are many causes to accidents other than just behavior. There may be environmental conditions, physical hazards, management & systems, equipment, etc., to consider as causes.

It’s not unusual for an organization to see these two approaches as an “either-or” proposition. While the strong proponents of each (BBS and SMS) may see them as diametrically opposed, this may not necessarily be true. But there is no “canned” solution; each organization should select the components of various theories and systems that work for them.

What Really Works In Keeping The Workplace Safe?
1. Controlling risks at their source.
2. Vigorous enforcement of the law.
3. Treating people with dignity and respect.
4. Using BBS and Safety Management Systems (SMS) together.

A combination of safety management systems and behavior-nurturing systems might better ensure a higher probability of working safely. BBS and SMS can and do work together. But BBS in its entirety and on its own might cause more harm than good, as it has a tendency to cause a level of distrust between management and front-line workers. In my opinion, bringing BBS into a culture where there is no trust can only lead to disaster.

So I would suggest that using caution with behavioral theories is appropriate. We are always learning new things about human psychology, and what we thought was true about human behavior a few years ago may not be true today. Bear in mind also that employees don’t like being “psychoanalyzed” and many unions are strongly opposed to BBS in any form. There is clear value in injury reduction through removing or controlling hazards (conditions). While behavioral modification might work, it can be complex and involved, and often is met with tremendous resistance. It all boils down to using what works. No one system, process, or theory has all of the answers.

There is no doubt this is a complex, controversial, and even divisive subject. To learn more about combining BBS and Safety Management Systems, join me on January 6, 2015 for my next audio conference on this subject. “Behavior Based Safety: What Works, What Doesn’t, And How It Can Help Your Organization”

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10 Steps to Effective Safety Programs

10 Steps to Effective Safety Programs

  1.  Find an Evangelist.This is critically important. While the steps to follow are not difficult, you do need someone to make it happen and manage it. You need someone in your company that truly believes in making the workplace safe for all employees, can do some research, learn quickly, has the ability to manage multiple projects, and can obtain buy-in from all levels. This might be an existing employee that has shown promise or you may need to bring in someone else. Not every company has someone like this in their employ, but you may and not even know it. Take a good look at your employees, the things they do and what sort of ideas they have had in the past. Start asking around and you might just find someone on staff that can be your Evangelist. If not, there are plenty of very good consultants out there that you might use. I would suggest getting one person to work on contract whose only responsibility will be your new safety project.
  2. Implement an ISMS. This is an Integrated Safety Management System. A lot of words for a means of making things happen and controlling them. Putting an ISMS in place is not really scary or difficult, it just sounds like it.  The ISMS is merely a tool and is not meant as a be-all and end-all. It is designed to help you plan, implement, and control safety measures that will reduce time off from work injuries, increase production, improve employee involvement, and ultimately reduce costs and increase revenue through improved customer relations. A search on the Internet will bring up lots of ISMS examples and help on developing an Integrated Safety Management System.
  3.  Educate & Train. This is probably one of the most important of the 10 steps. Everyone from the CEO to office and warehouse workers must be trained and educated (there is a difference between training and education). We train for skills and we educate for specific knowledge and concepts. Both are essential to a successful ISMS and a safe workplace. How training and education are implemented depends on your situation and resources. I recommend beginning with off-the-shelf, self-paced, interactive training courses in every safety subject appropriate to your workplace, such as chemical safety, materials handling, office ergonomics, etc. You can always move toward more customized courses later, but the important thing is to get the training started right away. These training courses need to be readily accessible to employees from anywhere in the world, 24 hours a day. This is easily done through one of many safety training providers that offer courses and a Learning Management System (LMS) to deliver and control everything. Good LMS’s are available for little money or you can go with an open source LMS like Moodle for free. Also check out MasteryTech or TrainCaster, which both offer courses and an LMS at a very reasonable cost. Try a search for “affordable LMS”.
  4. Make Information Accessible. Lots of ways to do this, but as easy as it is to build and manage an Intranet, it just makes sense to do so. Nearly every business has computers and these computers are connected in some sort of network. With today’s applications, creating and maintaining websites is really a quite simple task that nearly any employee can learn quickly. Once your site is up and running, this is where you post all of the information your employees need to stay safe, like job procedures, your safety policy, safety programs, and just about anything else you can think of. An Intranet is also a great tool for your employees to report accidents and submit suggestions for improvement.
  5. Involve Employees. None of this will be successful without everyone’s involvement to some degree. All safety professionals will agree that safety starts with management, and that ongoing safety in the workplace is the responsibility of each and every employee. Besides, your employees know the workplace better than anyone else and they can do the things that will save you money and increase your revenue. Setting up and running a safety committee is a good way to get employees involved and to continue spreading the word about working safely.
  6.  Identify & Control Hazards. Unsafe situations must be controlled in order to reduce injuries and limit or eliminate lost work days. And you can’t fix a problem that you do not know exists. This is where hazard identification comes in to play. It is actually very easy and does not take much time. Simple walk-around inspections and more in-depth job analysis will reveal the dangers with the biggest chance of causing injuries that put employees out of work. Do an Internet search for “job hazard analysis”.
  7.  Ensure Legal Compliance. Got to do it. If you are not in compliance, all it takes is one unhappy or disgruntled employee to make a call to OSHA and you will have inspectors all over your facility. And you can be certain that if you have not already implemented a very good safety system that OSHA will find violations. Sure they will give you a chance to fix them before they start hitting you with fines, but once you are on OSHA’s radar you may be on it forever. This is not a good thing. Another not so good thing is litigation. If an employee is injured because of a hazard that management knew about or should have known about, both civil and criminal prosecution is possible. Under California OSHA, and soon to be under Federal OSHA, managers can be held personally responsible and can go to jail.
  8.  Automate Recordkeeping. This is really easy. OSHA requires nearly all employers to maintain work-related accident records, including documented accident investigations. OSHA provides a really nice Excel spreadsheet for this purpose. Additionally, I have modified this spreadsheet to make recordkeeping really painless. Use my email link at the end of this article and I will send you a copy.
  9.  Let Your Customers Know Advertise your new safety system and its results to existing and potential clients. This will show just how serious you are about your safety responsibilities and how you want to do the right thing. Make a big deal (it really is a big deal) about your safety system and how it has improved your business.
  10.  Continuous Improvement. None of what has been done so far can remain static if it is going to continue putting more money in your pocket. Part of this safety system must include a means to occasionally re-evaluate it and continually be looking for ways to improve. As your safety system continues to mature, your employees will continue to benefit from a safe workplace and your customers will continue to see your commitment to safety. This is clearly a win-win situation for all stakeholders.

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