Record Keeping


The U.S. House of Representatives issued a special report in June of 2008 on the status of recordkeeping and how it has been underreported, “But extensive evidence from academic studies, media reports and worker testimony shows that work-related injuries and illnesses in the United States are chronically and even grossly underreported. As much as 69 percent of injuries and illnesses may never make it into the Survey of Occupational Injuries and Illnesses (SOII), the nation’s annual workplace safety and health “report card” generated by the Bureau of Labor Statistics (BLS).”

While the report does reach some interesting conclusions, it is not something really new to many safety professionals.  In a previous article I reported how a company failed to report an injured employee to keep the incident off the books.  Now we know it happens a lot more than we thought.  We don’t want to think it happens, but incidents cost money and production time.  The fewer incidents that are reported keep certain cost, such as worker’s comp prices and healthcare, from rising.  Also, many safety professionals job are dependent on showing a decline in the number of incidents reported.  Therefore a borderline call may never make it to the OSHA 300 form.  At least now we know that the incident rate reported by the BLS is not totally accurate.  The question is, will this really change anything? 

Let’s hear from you.  We value all your comments and concerns relating to this and any other issues.

Part of my job is researching and reading articles written about safety and compliance.  I have many different sources (none that I want to testify about) for OSHA, DOT, Homeland Security and more.  One of the reoccurring themes everyone (except me) likes to report on, is who is getting fined and how much it is costing them.  Many of OSHA fines are well over the $100,000 mark, and DOT is similar, if not more.  There doesn’t seem to be a lack of companies or organizations to fine.  Whether it is a Disney, a GE or some small construction company, incidents are still happening and the companies are still paying the price. 

Recently, I read where a construction company got fined over $250,000 for 2 employees getting injured (no deaths).  The company had previously been fined over $100,000 and warned by OSHA.  People have told me that the DOT is now going after companies who ship hazardous materials improperly, fail to provide training, failure to have a security plan and other assorted compliance issues.  These fines are reaching well over $100,000.  Remember the fine is not the only cost of incident.  The general rule is an average incident today cost the company about $25,000.  That company will have to sell an additional $700,000 at 4% gross profit to make up that cost.  That is a lot of additional sales for most companies and that is only if you have 1 incident.  Also there is the loss of productivity, and the probable increase in worker’s comp to add to that total.

So what’s the problem?  Most companies are reactive and not proactive.  Look at how many organizations reach VPP or STAR status as a percent of all the companies in business.  Not too many.  As the economy worsens positions that are non-revenue producing are the first to go, such as training or the safety manager.    Even though we know the safety and trainer indirectly add benefit to the bottom line, it is hard to quantify the amount of money they save a company.

Time is money especially in the trucking industry.  I know there are truck drivers who remove their DOT placards after they leave a company to avoid having the state police stopping them for 30-60 minutes.  What is the safety or transportation manager to do?

Really, I don’t have the answer.  Maybe some of you would like to share your success with our readers.  I only know the problem is not going away nor does it seem to be slowing down much.  Each year the top fined areas of OSHA hardly change.  Statistics show injuries and deaths are going down, but I not so sure that is a good indicator of what’s really happening. The reporting system (if the injuries are even reported) has changed to reflect fewer incidents (no first-aid is reported even if the employee sits out half the day).  As an example, I was doing some DOT consulting at a company and an employee was cut and bleeding.  The employee was put in an office until after work hours and then taken to the doctor.  After a few stitches the employee can to work the next day and was told to sit around doing nothing.  He did not miss a day of work and the incident was not reported on the OSHA 300 log.

Maybe we should look more closely are the amount of dollars fined instead of the number of reported incidents to get a true indicator that we are really in compliance and acting in a safe mode.  Safety professionals are always working to get upper management to support the safety effort, and others say we need the support of the supervisors.  Guess what people?  SAFETY NEEDS EVERYONE’S SUPPORT or there will be a breakdown somewhere.  Just like the production line.  Everyone needs to do the job to make the system work.

 

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We most often think of employee safety with regards to manufacturing, construction or other miscellaneous industries with related safety incidents.  But how often do we consider the professional athlete as an employee or the fan in a safety situation? 

Dave from TechLife recently sent me an article by Scott Miller of CBS Sports about the number of breaking wood bats in baseball.  This number is increasing each year, and it is becoming a safety issue for the players (employees) and the fans.  Sports are becoming much more harmful to the employee.  About a year ago a minor league coach (an employee) was hit in the head by a foul ball and died.  The NAICS for sports is 71100 and the recordable rate is 5.8 that is comparable to construction and manufacturing.  We know there is an alarming increase in the number of injuries is sports such as football and hockey, but should athletics and OSHA be concerned about the incident rate in the industry as a whole?

Fans are also “in harms way” when a hard line drive or a bat flies into the stands or a herd of 30,000 people all want to leave a game at one time.  Someone(s) often gets injured.  These injuries will not appear on an OSHA 300 log even though the injury occurred on-site, because the fan is not considered an employee.  What happens when a vistor to your company gets injured, do you record it if it qualifies and a recordable?

Sports today are a dangerous profession.  The employees receive much more medical attention than employees in other professions.  Most athletic teams provide a medical staff both on and off site.  How many of you have a doctor, nurse or trainer on-site?

So when you think of employee safety and health don’t forget to consider the professional and non-professional athletic as an employee too.

A typical day in the life of the EH&S manager might go something like this:


Get in the office at 7 AM and go over all the previous days reports about any incident(s) that occurred.  Next you get that cup of coffee to spill over all those reports.  Now you check out the 50 or so E-mails of which at least 30 require a response.  Now it is time to walk the facility and do a short audit to make sure the people are wearing their PPE.  Go back and check more e-mails, and go over the budget for this month.  It’s 9AM and time for your first managers meeting of the day.  You report on 1 incident and what is happening to the employee.  Now back to the office to write your agenda for the weekly safety meeting and go over the OSHA 300 log.  After a short break you need to go over training records to see who needs what training and when can you get it done. Time to start designing a hazardous materials training class for new employeesas some of your MSDS sheets have changed.  Lunch, and then back to designing the training class you use to outsource, but not in this year’s budget.   Call coming in from the floor about a machine-guarding problem (no one hurt).  Have to go on the floor with maintenance to check the machine (lockout/tagout), they need it running for the production line.  Another call on the Nextel that employee requires minor first aid.  Go back to the office to call supervisors to schedule training, but hey are NOT happy to have to take people away from production.  Your boss calls and wants a report about safety to give to his/her boss.  Day almost over, you go back and check on machine to make sure it is properly guarded and find some flammable hazardous materials left out unattended.  Talk with supervisors about this and how to put them away correctly. 5:30PM, time to leave the building, but have to keep Nextel on just in case.  Oh no, I forgot to get the safety meeting agenda put together, well tomorrow is another day.

Here is who I was today:

  • A manager
  • An IT person
  • Asafety person
  • Administrative assistant
  • A finance person
  • An instructional designer
  • A maintenance person
  • A medic
  • An arbitrator
  • An employee
  • Oh Ya! a family person too!!!


So what do you think, sound something like your day?  How many other jobs do you do that I left out?  Send a comment and we will compile a complete (as possible) of all the jobs a safety manager has to do.  Let’s hear from you.
    

 

The US department of labor estimates that 5.6 million workers risk exposure to bloodborne pathogens, including human immunodeficiency virus (HIV), hepatitis B virus (HBV), and hepatitis C virus (HCV), while on the job. An OSHA Standard Bloodborne Pathogens (1910.1030) Training Program is essential for any person who may be “reasonably anticipated” to face contact with blood and other potentially infectious materials as the result of performing their job duties. Professions at risk include, but are not limited to, healthcare professionals, educators, cosmetologists, tattoo artists, and construction workers. Industries whose employees have contracted infection from bloodborne pathogens while on the job run the risk of an OSHA citation up to $70,000 for facilities not in full compliance with bloodborne pathogens standard.

The Occupational Safety and Health Administration (OSHA) has recently begun to strictly enforce the bloodborne pathogens standard. Facilities not in full compliance with the standard, including failure to provide proof of OSHA standard bloodborne pathogens training to all employees, have received up to 70,000 dollars in fines.

A Bloodborne Pathogen program should include, but not be limited to:

  • Exposure Control
  • Methods of Compliance
  • Personal Protective Equipment
  • Housekeeping
  • Regulated Waste Control
  • Communication of Hazards to Employees
  • Recordkeeping

It is the employers’ responsibility to train and inform their employees about hazards in the workplace.  It is also the responsibility of the employer to pay for all PPE necessary to keep the employee safe.

The Compliance Resource Center provides training and polices and procedures for Bloodborne Pathogens Programs and other OSHA and DOT compliance.

OSHA is reminding employers that beginning today until April 30, 2008, they must post OSHA Form 300A, a summary of the total number of job-related injuries and illnesses that occurred during 2007.

“The OSHA 300 logs provide employers and employees a broad view of where injuries and illnesses are occurring at their worksites,” said Assistant Secretary of Labor for OSHA Edwin G. Foulke, Jr. “Identifying and posting injury and illness information provides employers and employees with useful information to help ensure a more safe and healthful workplace.”

The summary must include the total number of job-related injuries and illnesses that occurred in 2007 and were logged on the OSHA Form 300. To assist in calculating incidence rates, information about the annual average number of employees and total hours worked during the calendar year is also required. If a company recorded no injuries or illnesses in 2007, the employer must enter “zero” on the total line. The form must be signed and certified by a company executive and must be displayed in a common area where notices to employees are usually posted.

Employers with 10 or fewer employees and employers in certain industries are normally exempt from federal OSHA injury and illness recordkeeping and posting requirements. A complete list of exempt industries in the retail, services, finance, insurance, and real estate sectors is posted on the OSHA Web site, www.osha.gov.

Copies of OSHA Forms 300 and 300A are available in either Adobe PDF or Microsoft Excel Spreadsheet format on the OSHA Recordkeeping Web site at www.osha.gov/recordkeeping/index.html.