Beyond Zero — Leading from the Heart

By Bob Fitzgerald, CSP, CHST

Austin, TX – “Congratulations, your project has reached a safety milestone achievement and avoided OSHA recordable injuries.” While some people believe this means “mission accomplished” and safety has been attained — today, most safety practitioners believe there is always more work to be completed in the area of safety.

While the OSHA (Occupational Safety and Health Administration) recordable incidence rate (RIR) is a common, and in some circles very important, metric, many would agree this lagging indicator is elevated in the traditional injury pyramid. To have no OSHA cases — that is, no injuries that met the criteria to be recorded on the OSHA log — is a good thing. But to claim total victory in safety because no OSHA recordable cases have been achieved is missing the mark. What level of injury or incident is really being counted? What does the workforce think when they know people have been injured, but just not severely enough to “count?” Also, how much does luck factor into safety milestones? What was actually done to achieve this injury-free period?

As safety leaders, we should drive a paradigm shift by reinforcing the concept of safety beyond the milestone achievements — and perhaps offer a slightly different mindset.

We must seek to understand the underlying reason why the OSHA RIR has become prevalent and the apparent gold standard in measuring safety performance. In an effort to provide a structure to owners and those who use construction contractors, the Business Roundtable issued Improving Construction Safety Performance, better known as the A-3 Report, in January 1982 (reprinted in July 1990).

This landmark report convincingly made the case for investing in safety programs and challenged owners and construction users to take a more hands-on role and increase engagement with their contractors. It also provided a seemingly objective method to select “safe” contractors in terms of evaluating the experience modification rate (EMR), OSHA RIR and other criteria related to programmatic elements such as inspections, incident reporting and training. The appendix in the A-3 Report gave owners a tool to “objectively” evaluate their contractors. In turn, general contractors have used it to evaluate their subcontractors. While the report’s intentions were noble and certainly have merit, there could have been unintended consequences with regard to the emphasis on OSHA recordable cases. In fact, many owners and contractors are still using variations of the original A-3 appendix as a qualification document to help select contractors and subcontractors.

There are several ways this reporting could leave gaps in our safety processes. OSHA recordable cases are not compared consistently. For example, one dose of a prescription pain medicine is an OSHA recordable injury, as is a fractured femur. Many believe severity should be factored in by the evaluator, because on the surface, reviewing rates alone might not give the clearest picture. A company with a 2.0 RIR is not necessarily less safe than a company with a 1.0 RIR. And a company with a zero RIR could have achieved that rating as a function of aggressive case management or, as stated earlier, simply luck.

Another outcome is the temptation to focus on the numbers and place emphasis on case management as the driver in achieving safety performance. When monetary bonuses and promotions are tied to OSHA rates, employees could be hesitant to report injuries, either intentionally or unintentionally. In fact, the writers of the A3 Report stated, “The reliability of OSHA incidence rates is solely dependent on judicious reporting by the employer.” Moreover, the original author of the OSHA Blue Book, Steve Newell, who is now a principal with Mercer ORC Networks, has warned the OSHA rates were never intended to be used as a basis for qualification. In a presentation at the 2012 Southern Company Contractor Safety Forum he discussed and warned of the “collective misuse of OSHA data as the primary metric for driving and assessing safety performance.”

Dan Petersen, who was one of the nation’s leading safety consultants, often talked about measuring safety performance in terms of what we “don’t want to see happen.” Instead, he suggested measuring what we “want to see happen.” Many organizations are looking at leading indicators, or activities that can set the stage for good safety results. Trade groups like the Construction Users Roundtable (CURT) and the Construction Industry Institute (CII) are working to provide members with tools and measures to permeate the incident chain and, ultimately, get to the precursors that lead to incidents.

Achieving safety milestones means looking beyond the latest OSHA rate and comparing that with goals or targets — or even achieving zero. When safety leaders set goals to achieve zero incidents, it is important to be clear with those expectations. Should employees focus on zero OSHA cases, doctor/worker compensation cases, first aids or incidents? I suggest we achieve all of those. SafeMap CEO Corrie Pitzer gave a keynote address to Southern Company safety leaders where he challenged the audience with this thought: “When we become leaders of safety, we don’t think in numbers; we think with our hearts.”

In his work, “Pre-Accident Investigations — An Introduction to Organizational Safety,” human performance guru Dr. Todd Conklin remarks that safety is not the absence of incidents; safety is the presence of defenses. We have to think outside the box in terms of achieving zero safety incidents, particularly with regard to OSHA rates. As safety leaders, we need to be compelled to think about how we are managing safety processes and truly taking care of our employees.

Bob Fitzgerald serves as Manager – Project Safety and Health, Engineering and Construction Services for Southern Company located in Birmingham, Alabama, and is an active member of CII’s Safety Community of Practice.

Date posted: February 25, 2014