How to avoid the new OSHA “culture penalty”

Creating a strong safety culture can be challenging for any organization. Recent regulatory changes are placing an organization’s safety culture under additional scrutiny. In the EHS Today article The Risks of Using Injury and Illness Reporting as Measurements of Success, Mark Kozeal discusses how an OSHA rule change penalizes those with cultures that discourage reporting.

“Under OSHA’s update to its 2016 rule on recording and reporting workplace injuries and illnesses, such programs would be in violation of the law,” Kozeal notes. “Whether this incentivized culture was purposeful or inadvertent doesn’t matter. What matters is that any practice that incentivizes employees for not reporting an injury or illness or denies employees incentives if they report an illness or injury, can now be cited by OSHA.” This means that a poor safety culture can now affect the bottom line.

First steps to avoiding the “culture penalty”

Now that there is the possibility of additional regulatory costs associated with failing to create a strong safety culture, the importance of near-miss reporting is multiplied. As we discussed in Using RMIS technology to improve incident and near miss reporting, two factors are essential to developing a healthy safety reporting culture:

There is no quick fix when it comes addressing the factors that inhibit reporting. However, taking a number of practical steps that include making it easier to submit reports (addressing practicality) and allowing for anonymous reporting (reducing fear) can be a foundation upon which to build an effective safety program. With more data to draw from, the ability of risk managers and safety professionals to identify, analyze, and take strategic action to reduce the likelihood of injury is vastly improved. Over time, this can contribute to a breakdown in perceptions of uselessness and acceptance of risk.

Lowering the submission hurdle and implementing anonymous reporting are certainly two important things that the right risk management information system (RMIS) technology offers to avoid cultures that disincentivize reporting. But these steps are still only half the solution. The other half requires changing the perspective on the value of incident data collected.

Changing a culture by changing the value of collected data

If an organization uses incident reports to measure “success” in safety programs, then reporting an incident actually works against that unit’s objectives. The pressure to make incident numbers drop can raise the bar on what merits being reported. This discourages the reporting of legitimate incidents and causes potential underreporting.

Kozeal notes, “The trouble with using reported injuries and illnesses as a barometer of workplace safety isn’t so much in what is reported as it is in what is not reported. In some instances, employers may have created a culture that incentivizes not reporting injuries and illnesses or withholds ‘rewards’ for those employees that come forward and report an injury or illness.” In this case, the value of incident reports becomes negative and places bonuses or other rewards at risk.

Shifting to a positive reporting value

By shifting to a near-miss focus, incident data gains a positive value. If near-miss reports help identify preventable future incidents, then those reports have a beneficial value (instead of a punitive one). This incentivizes more reporting, since additional data points (near-miss incidents) increase the potential of finding new root causes. More reporting leads to better trend identification, which leads to taking specific safety-related actions.

In this framework, the focus shifts from lagging indicators (injury/illness reports as a measure of success) to leading indicators (identifying which near-miss reports forewarn future incidents). In Leading Indicators: How we learned what to do today to prevent churn tomorrow, Guilherme Lopes chronicles the numerous cohort studies and other analysis he conducted to finally discover the factors that drove their customer churn. This same process can be used for finding correlations to safety issues.

The power of leading indicators

In The data-driven risk manager, we discuss variance in the value of data:

Not all data is equally valuable. ‘Creating a data-driven culture starts with being able to accurately measure and present reliable and actionable information,’ says Scott Busse in a Risk Management Magazine article. Leading indicators, metrics that foretell potential risks or negative outcomes, tend to be the most actionable type of information. Rather than looking at the after effects of actions taken in the past, leading indicators predict events in the future.

The power of leading indicators lies in their ability to drive a real-world conversation about what to do in response. Finding out that A leads to B may take considerable digging, as Lopes documents. But once that connection is made, the conversations about how to increase/decrease A are much more straightforward. “If that is the problem, why don’t we just do this?” These types of questions drive the root-cause changes that move the needle.

If the percentage of new hires, for instance, corresponds to increases in near-miss incidents in the warehouse, an organization may need to reexamine its onboarding procedures. Spikes in near-miss slips due to wet floors could lead to a change in janitorial schedules. Often times, the required action will seem relatively obvious once the cause and effect is found.

To be data-driven, you first need data

These institutional changes rely on data to inform decision making. This not only means a streamlined near-miss reporting procedure, but also a robust audit solution to ensure that procedures are being followed, and to track which units are complying with data-collection efforts. “Worker safety is not something that can be left to chance,” Kozeal states. “Organizations that don’t have the internal staff or knowledge to review policies, practices, and procedures for current compliance should have an external expert conduct a workplace safety audit to ensure compliance.”

Whether conducting internal audits to directly analyze compliance with ongoing safety programs, or using internal audits to prepare for external reviews, audit technology can be a critical tool in reshaping a safety culture. Designing a reward structure that incentivizes participating in compliance efforts, both at the reporting stage and in the root-cause strategy sessions, not only increases the odds of building a healthy safety reporting culture, but also helps your organization avoid potential penalties from OSHA.

Making the change your organization needs

Changes to the OSHA rule mean that a safety culture with incident reporting disincentives not only threatens the safety and well being of employees, but also increases the risk of fines and penalties. Origami Risk can help you create custom, mobile near-miss reporting solutions that lower the collection burden and provide the data needed to search for critical leading indicators. With powerful, intuitive auditing capabilities, you will be able to see who is developing root-cause solutions, and measure what types of effects those efforts have on safety incidents.

Moving from a culture where employees reporting incidents are considered “tattletales” to one where each report is seen as a potential clue to preventing a fellow teammate’s next injury is a serious undertaking. With the right RMIS, however, it becomes a lot more manageable.


Check out our related case studies below on changing EHS culture.

With adaptable audit functionality, convenient online and mobile access, and company-specific branding of audit forms, Compass is now using Origami Risk to promote a safety culture that engages all of its companies’ associates rather than being enforced from the top down.

 

DHL uses Origami Risk to allocate losses to individual cost centers. This provides incentives for accident reduction, safety improvements, and loss prevention.

 
 

Contact us below to get in touch with our experts to figure out how you can create a strong safety culture for your organization.