What We Really Get Wrong On OSHA Recordkeeping
It’s that time of year again when we start to see reminders and updates designed to make us think about our OSHA record keeping, and it all seems to get a little old as we see the same advice over and over again: remember to have an executive sign the 300A summary, make sure you review and update everything by February 1st, don’t forget the 300A has to be posted from February to April, etc. We also start to see lists of the “top things companies get wrong with OSHA record keeping”, and they all tend to be similar: having the wrong person in the company sign the 300A, forgetting to post a 300A in years with no recordable incidents, not maintaining a copy of the certified version of the log, etc. The trouble with all this advice is that none of it gets at the heart of what’s really wrong with the injury and illness record keeping practices in many businesses.
In many cases, the thing that’s really wrong with our “OSHA Record Keeping” is that we view it as “OSHA Record Keeping”; that is to say it gets thought of as a purely regulatory exercise that gets little other attention. Yes, it’s a required exercise for most companies in the U.S. with more than 10 employees because it’s mandated by OSHA; however, it’s an exercise that is meant to yield valuable information when it is handled properly. Any incidents that end up being recorded in the OSHA 300 log are potential indicators of things to come. They are records of injuries sustained by the people we employ and depend upon, and somewhere in these records there are lessons to be learned if we take the time to look.
At this point in time, many companies have come to the realization that safety, quality and productivity are inextricably linked, but they are still failing to use the information that is (or should) be available to them to take an active approach to identifying and correcting the issues that have a negative impact on their business. Injuries and illnesses in the workplace are an indication of a problem in the workplace. Every time they occur, quality and productivity are impacted right along with safety; not always to the same degree or in equal proportions, but each area is impacted, whether we immediately recognize that or not. By mandating the collection of injury and illness data in the workplace, OSHA is forcing us to add to the other indicators that most businesses collect without a regulatory mandate; such as scheduling and productivity data, rework data, and profit/loss data. What we as a business choose to do with all this data is up to us.
Modern data collection tools and software can greatly simplify the collection of all this data. When this information is aggregated, and viewed side by side, it can absolutely tell a meaningful story. When it is viewed on an ongoing and timely basis, it can provide us with indicators to trends that, left unchecked, could have increasingly negative impacts on the company. If the viewing of this information is only done once a year, or its done on a cursory basis as part of a mandated regulatory exercise, the chance of it being used to improve the company are greatly diminished.