Injury rates no longer cut it: What’s the new safety metric?
October 11, 2010 by Fred HosierPosted in: Analysis/Commentary, In this week's e-newsletter, Injuries, Latest News & Views, OSHA news, What do you think?, What's Working in Safety
(Analysis from the National Safety Council Congress and Expo in San Diego) One thing is clear after attending three days of sessions at this year’s National Safety Council (NSC) Congress and Expo: Injury rates are no longer considered the best measure of a company’s safety program by many safety pros.
There was a time, not long ago at all, when many case studies presented at safety conferences would end with, “and the company’s injury rate decreased significantly.”
No one is disputing that fewer injuries is a good thing.
But it’s been clear, since David Michaels was nominated to be the head of OSHA, that he didn’t have much confidence at all in injury rates calculated by the government.
In fact, Michaels made one of his most emphatic statements to date at the conference regarding injury rates: “I don’t believe our injury rates at all.”
Michaels didn’t start making these statements when he was nominated to take the OSHA job. He’s been saying this, as a safety professional, for years.
But now, it’s not just Michaels making this statement. At the conference, speaker after speaker managed to work into presentations that counting injuries is no longer the way to go.
Michaels has suggested that safety incentive programs that promise monetary bonuses, steak dinners or other prizes for zero injuries causes employees, through peer pressure, not to report injuries.
Safety expert Scott Geller of Safety Performance Solutions offered another theory at this year’s conference: “Zero injury” programs can stifle workers from talking about their injuries.
Solutions to problems in business evolve over time, and safety is no exception. Often, yesterday’s solution gets relabeled as tomorrow’s problem.
This idea that injury rates aren’t a good way to measure safety seems to have taken hold with many of the consultants, trainers and other expert attendees seen at safety conferences.
So, what replaces injury counts as the measure of a good workplace safety program? Michaels said once again at the conference that OSHA’s Injury and Illness Prevention Program (i2p2) proposal is the most important part of the agency’s current agenda.
The new standard will be for companies to identify their own hazards, produce plans to mitigate them and then put those plans into action.
And before someone says, “But counting injuries does mean something,” many of the above safety experts would agree. There’s no doubt that when a facility starts racking up injury after injury, not to mention fatalities, it means something.
But the business of safety has evolved once again. And the process isn’t over yet.
What do you consider a good measure of safety success? Let us now in the Comments Box below.
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Tags: David Michaels, injury and illness prevention program, injury rates, National Safety Council, Scott Geller

October 11th, 2010 at 6:15 pm
I agree with the part of the not reporting of injuries in order to get the “prize” I have seen better results with employee recognition programs than the incentive. As you can run these with proactive measures rather than the incentive/peer pressure.
October 12th, 2010 at 10:44 am
It would be helpful to count and report “near miss” reports from employees and provide support (if not reward) for such reports. It seems to me that such a program would encourage worker attentiveness and responsibility as well as reducing actual events.
October 12th, 2010 at 11:07 am
I’ve been saying for years that injury rates are a poor measure of performance. My company uses them, and they’re almost meaningless. Severity rates are a better measure of performance if you are going to use lagging indicators. If a guy has back spasms, is prescribed a muscle relaxer and back at work in the morning and another guy cuts off three fingers, they both count as one Recordable accident. I think a much better measure is to perform risk assessments, and then work to mitigate or eliminate identified risks. Identify a value for those risks eliminated and score accordingly. Eventually you will begin to run out of risks to identify, but then the measurement system evolves once again. It should always be based primarily upon leading indicators.
When I meet with employees I often ask if they think we have a safe place to work. The response at first was almost always, “yes”, based upon the low injury rate. I always countered with, “No it isn’t.” There are many ways to be injured, and many dangerous devices. The only thing making it safe is the people and their awareness. We perform risk assessments. We talk about safety alot. We reduce or eliminate hazards we identify. When we do have an injury it’s usually very minor. We also record and study “near hits”, where something occured but no one was hurt. A near hit is still an accident to us.
Prevention is the best measure.
October 12th, 2010 at 12:21 pm
The “Quality” of the program elements becomes the measurement.
As the quality of the program improves, it begins to pervade the workforce; impacting culture.
Also as quality improves fewer exposures are generated which reduces the probability of an incident. If you measure exposures and mitigate them prior to incidents - - it is being “proactive”
Look at ISO 31000, ANSI z-10 and OHSAS 18000 for direction
October 13th, 2010 at 7:38 am
Some type of classification of injury. Maybe by $ amount or severity. All injurys would still be reported but only the ones meeting certain criteria would count against an injury rate. you may have 10 injuries for the year with $ amount for all at $1500 and severity being minimal for all.
October 13th, 2010 at 8:32 am
If our incident rates are not ‘real’, and that is the opinion of many safety professionals and the head of OSHA, why don’t we do away with them? There must be some value or we would be scrapping the rates.
October 13th, 2010 at 8:51 am
Having to deal with a small employee count (annual exposure hours are 1/2 the benchmark rate) one injury takes our OSHA injury rate above all national averages, a couple of minor reportable injuries disqualifies us from working at many facilities. I have sais for years there need to ba a more balanced way of rating companies injury rates. The EMR is probably one of the best ways to really judge a companies injury patterns. All workers comp claime are reported on the EMR and it also rates severity, cost of claim. In our situation we have a .73 EMR and a 5.35 OSHA. OSHA need to recognize that all companies do not rack up 100,000 hours annually and the smaller companies are penalized for such.
October 13th, 2010 at 9:36 am
Wow, it appears that the country is becoming a country of lemmings lets all follow David Michaels off the cliff of nanny state. Safety is important but so is personal responsibility, if we want to continue punishing all employers for Safety issues we should also punish the individual person violating the safety rules that have been put in place.
October 13th, 2010 at 9:43 am
I’ve never been a big advocate of safety bonuses; however, in the construction industry and other heavy industries, this is a bit of an expectation of employees. In spite of that expectation, I still don’t like safety bonuses, but I do use them. Relative to TRIR, I also use a severity rate calculation. If an organization is being honest with their reporting, then certainly the statistical figures will point to a larger problem. In my opinion, that problem is generally the safety culture of the organization. Companies celebrate financial goals, new large client deals, corporate expansion goals, etc. Safety goals should also be celebrated while being careful to not allow the desire to change the culture (solely using TRIR statistics to prove said change) overcome the desire to have genuine cultural change that evokes pro-activity instead of reactivity and addresses the underlying issues that lead to injuries.
While we reach for goals, I never forget to say that in conjunction with the need to report all injuries when they happen so early intervention, be it first aid or medical, can be applied. Six months ago, I took an HSE Manager position with a company that had ended the previous five years with a 10 + TRIR each year. I’m fostering a culture change of being open and honest about injuries that do occur; learning from formalized near miss reviews; teaching hazard recognition; empowering employees with stop-work authority; using the JSA process and similar tactics we have all used before. We had to start all over at square one and get back to the very basic building blocks of safety. The message delivered to the management team is clear: We have to lead, guide, coach, counsel and train our way to a different path headed to a changed safety culture. Change the behaviors that lead to injuries and with some strategic safety guidance, the culture will change. IIPP could easily be seen as a roadmap of sorts designed to change organizational culture from a safety perspective.
We have a long way to go but we are currently just above a 6.0 TRIR (after peaking at nearly 11.0 in April) and this week we will celebrate having gone an entire quarter with no recordable injuries. We know it was sometime before 2005 since this has happened. I completely understand the risk of driving injuries underground through the use of safety incentives, but I don’t think doing away with this premise is the answer. I think the better answer is learning to use incentives wisely as one spoke in the wheel of true safety culture change.
October 13th, 2010 at 6:29 pm
Take it one step further. try incentivising those who report near misses actually do something with the knowledge. Have the men and woman in the feild get that thier word means something and does make an impact when it comes to safety which inturn will make a significant difference in the bottom line, especially when that 100 million dollar project requires a less then 1.0 T.R.I.R.
It is no wonder we play this game. Clients out there require us to play it. It is calculated risk, basic business principles. Dont get me wrong we have to continue fighting the fight how ever……..you know what i a saying.
October 15th, 2010 at 2:36 pm
Safety requires preparedness and planning with input from all of the potentially affected individuals to the various hazards and issues at their facility or worksite. Some type of operational risk management program which would include input from worker to management personnel is key to be successful in reducing or eliminating injuries. To be affective as others have indicated above after identifying the safety issues that we can identify and mitigate, we need to develop a safety culture that will report near misses and have a system of some kind that can react to them in a quick efficient manner. Chris has a point of incentivizing those who have actually changed the process or work area to make sure the near miss does not turn into an injury. Injury rates tell us if there is a gross problem and if it is high the operation has probably done none of the things I mentioned above. But the ability to hide injuries do to incentive programs can lead to a situation in a company or operation where serious injuries will occur at some point in the near future. Mitigation of safety problems and a cultural shift to a safety mindset I consider the best way to go in a safety program. Each individual needs to be apart of the process looking out for each other in the work area. Essentially we are all assistant safety officers whether at work or at home.
October 18th, 2010 at 12:38 pm
Although injury calculations does tell us on some level how safety is working or how its not it does not, the calculations do not measure the culture change in an environment. I have found that even with good training and good programs and good behavior based safety audits and coaching…..there are some people who utilize all the tools and enpowerment given and CHOOSE to work safely, not risk their lives, and become so connected to their work environment where they take ownership in identifying hazards and communicate them to getting a solution. Then there a few that will do anything to do their job even if it is a risk to themselves, and then those who (few) are not vested in anything, their job, safety training and empowerment, rules, procedures, anything.
So I dont think injury calculations are the total sum of how an employer is working their safety progam.
October 19th, 2010 at 8:52 am
What gets measured, get done! Old saying that is still true today.
Safety Professionals have to have something to measure in order to promote safety in their business.
They have to ensure that all employees, including Management and Supervisory, have “skin in the game,” if their programs are to work properly.
I do not believe in incentive programs, they become entitlements in short order. I do believe we place too much on finding people doing things “wrong” when we should be focusing on people doing things “right!” Make finding people doing the right thing a priority and it will help the Safety Program in any business. Not having injuries, is the “right” thing and should be measured.
October 19th, 2010 at 9:38 am
While I agree with a few of Dr. Michael’s remarks (incentives can drive down reporting), I disagree with the majority of them. Regulators love to point fingers, but fail to accept any responsibility. Until our government wakes up to the simple fact that accident/injury prevention is the shared reponsibility of employers, employees and regulators, preventable accidents and injuries will continue.
Contrary to the messages we are hearing from Dr. Michaels and various union leaders (and I am not anti-union), EMPLOYEES must be held accountable for their actions, REGULATORS must be held accountable in returning to a balance between enforcement AND assistance, and EMPLOYERS must provide comprehensive, pro-active safety management systems with safe behaviors and safe operations as cornerstones.
Continuing with the worn-out rhetoric of employers having the sole responsibility for safe workplaces will tragically result in continued accidents and injuries.
October 19th, 2010 at 11:08 am
DON’T DRINK THE KOshaOL AID!
OSHA continues to brag up it’s present ‘enforcment’ and ‘heavy penalty’ promise to industry and seems to gladly flush much if not all of the cooperative climate established since the onset of the VPP etc… this Political Drama and Grandstanding ultimately taxes worker safety.
The irony of it all…OSHA re-writes it’s old recordkeeping rules because they were not explicite enough to drive the numbers they wanted but doesn’t refund the penalties it had imposed over that time due to the recordkeeping rule’s misgivings resulting in technicalities and unfair levies. Even after rewriting it, nothing has changed. Worse yet, now OSHA openly admits to ‘not believeing any numbers’…a.ka. recordkeeping; still no refund to the companies who got that penalty in the past. Which is it? I guess they get to have it both ways…..again.
Seems nobody on the enforcement side and nobody mining consultation fees from industry want to acknowledge any level of improvement with safety in industry. I don’t know how many times private sector safety pros have to be slammed like this before they’ll step forward and engage this issue. One where OSHA and many consultants hold control over companies who aren’t thinking for themselves but allow those “outside” the real world of safety to decide what is real or what works and what does not. This is an attempt to harvest your dependence on them.
In spite of this negative and political spritied attempt to deman your profession, take pride in the improvments you’ve made and continue to trust your teams. Give yourself permission to believe in what you’re doing and continue to build upon; Employee Involvment, Executive Leadership, Training, and Aggressive Incident Invesitgation and Claims managment; then to keep the wolves at bay, consult the OSHA regs directly and work toward compliance “for sake of compliance if need be” and always take it at least one step further. Reward strong performances randomly and spontaneously. An authentic acknowledgent that reinforces good behavior has a net gain impact. Avoid rewarding employees in a manner that can manipulated by not reporting or be subjected to the likes of OSHA or these consultants who depend on bad numbers to justify their existance. Trust and empower the employees to be the pluse of your safety culture by giving them the time, tools, and authority to drive improvments and sustain hard fast rules.
Have you ever watched a baseball game and witness the atristry and finess then read the box score the next day….it’s not the same is it? But the box score like BLS data is history. It can help us understand where we’ve been and this is important.
Forgive the rant…but I know better…hard work and good ideas have made an impact and our workplaces are safer. I am proud to be part of this and excited about taking it further. Don’t let OSHA’s wet diaper distract you from any efforts you believe is making a difference. Good Luck to ALL!
October 19th, 2010 at 2:35 pm
In all programs especially Safety, you must have metrics to gauge your success and failures. Awards and Prizes are not the answer, conning employees into working safe for personal awards doesn’t work they will hide things for weeks. Safety training is the answer, starting from the top down, week end week out. When a worker commits a Safety violation, or a near miss what do you do ? Allow this person to go back to work with his/her hand slapped. Examples must be made, day off work without pay, up to three days off work without pay, up to termination. Violators will take notice, and it’s up to the front line supervisors to control their workers or he/she will face the same disciplinary action. Discipline is the key, just like the military, it may sound childish, but it works along with training. Foreman, Supervisors, Managers, employees will buy into the program they help create for the benefit of themselves and the company they work for.
October 19th, 2010 at 4:26 pm
Don, I appreciate your point of view, but I have to respectfully disagree. It has been proven time and time again that a company cannot get to a strong safety culture through the use of an iron fist. While I agree that there may be the “Toxic few” in any work group that don’t want to come on board with a positive safety culture since it involves change, but certainly the old adage of you will catch more flies with honey applies here. Getting employees, at all levels, engaged in the safety process with ownership in that culture and safety process will yield much greater results than creating a safety culture based on fear. Having employees that feel empowered, not afraid, to bring a safety issue forward has a significantly greater chance of working for the better. The fear factor will drive information about near misses and injuries underground and they will not be seen again until they become direct hits.
I agree with your thought that getting buy in from employees is critical, but getting there through trust, empowerment and open dialogue will pass the road of disciplining your way to a strong safety culture by miles and miles every single time. Hence, the concept of behavior based safety. As I said in my earlier post, we, as safety professionals have to foster an environment that relies on coaching, counseling, guiding, leading and training to reach strong, positive safety cultures in which every employee knows they are valued, that their safety is of the utmost concern of the company, and that they are as much the safety eyes of the organization as I am. It is my job to give their eyes the appropriate vision through training and dialogue and empowering them to feel safe in pointing out a safety shortcoming so that we can work together to solve the issues.
October 20th, 2010 at 9:35 am
This is an interesting topic, there are quite a few people that believe in the “Honey not vinegar” or “Carrot not stick” scenarios and companies are suppose to by into it, if that is such an excellent method why doesn’t OSHA use it for there method, lets face it they do not really believe it works either otherwise they would use it, after all they are all about worker safety “Right”.
Now back to reality there is no one method that will work with everyone some all you have to do is ask, some the carrot works, some the stick works and some none of the above work. I do believe that in Austraila and possibly even Britain workers share the penalties, if they do something unsafe they can even go to prison, I’ll bet that would get their attention. Oh and by the way I am not for bigger government which this type of policy would result in.
October 20th, 2010 at 11:14 am
Many of you saw how fatality rates dropped consistent with most all other rates measured by the government, insurance, and those who pay for government and insurance: industry. How would OSHA’s chief or consultant/experts in lock-step w/ OSHA argu that correlaton I wonder. Does it not lend some relationship to improvement?
Kind of hard to fake fatality rates or manipulate reporting of such. The numbers are a guide and aren’t likely any less or more accurate than in the past. Either way, the serves as a guide and an input into the decision/law making process for all (industry, government, insurance).
I’m still waiting for the government to invest in simple and important step in our world of safety by acknowledging how industry has shown real and important improvement. But this would clearly be in conflict with the currents administrations present posture. Too bad politics trumps what is best for safety in industry.
There is value in what the BLS reports but it doesn’t serve as the sole compass for continued improvment.
Don’t be afraid to read between the lines when OSHA says it doesn’t believe the numbers coming from the system it created and governs from.
Maybe a better question is; What value does the current system have and what single measure presents the greatest value to your organization. The answer can be quite different and still be correct.
I2P2 as a “guide” has value. As a rule or law steps into telling how companies should run their programs. The strongest programs may not be greatley effected but run the risk of seeing their performance diminish. Weak programs should improve but won’t reach their full potential.
If I may…..”Don’t tell people how to do things. Tell them what to do and let them surprise you with their results.” — George Patton
October 20th, 2010 at 12:16 pm
The amount of time given over to providing safety training is a key measurable factor in determining commitment to Safety by everyone concerned. The number of form 300 entries with adequate accident reports and records of corrective actions, are all still main tracking points for determining a Safety program’s ultimate effectivemess. Well developed & communicated expectations for emplyee safe behavior and management accountability & involvement, is absolutely required.
Turnover rates and safety-related funding & HSE dept staffing are indicators of a business’s true General Rule compliance commitment.
October 26th, 2010 at 9:21 pm
As far as workers sharing the costs, workers are the ones with the injuries. Workers have been and are paying.
Clear expectations are important (I think that’s part of the “discipline” discussion). Employers who do not stop unsafe workpractices before injuries occur are the same employers who would not allow employees to produce defective products (or no product at all). If an employer can reprimand for defective work, why allow unsafe acts and hazardous conditions? Employers with a progressive enforcement policy do not tolerate unsafe situations or workers that insist in repeating unsafe acts and the workers konw that and act accordingly. Proactively eliminating hazards and intervening when employees take unsafe actions (before they get injured) reduces employee injuries. Employers have the resources and responsibility to provide PPE, ventilation, engineering controls and to set workplace safety guidelines and enforce them.
In 1970 OSHA was passed by Nixon because of a court system clogged by civil and criminal law suites for workers trying to get medical coverage for injuries incurred at work. Employees traded the right to sue their employers for no-fault worker compensation insurance in the OSHA Act - paid for by the employer. Employers must provide a workplace free from recognized hazards, if they don’t, they pay the worker compensation costs. Pretty straightforward.
October 27th, 2010 at 10:15 am
In terms of injury rate “accuracy” being questioned due to incentive program influence on reporting; might we agree that it may have an impact but doesn’t negate the value of the data completely? There are many other issues that may impact accuracy even more.
Namely:
-Fraudulent claims by workers where injuries sustained outside the workplace or at a previous employer are brought in and falsely framed into their current employer’s system/data.
-Or cases where the facts leave the claim questionable for any number of reasons including a Doctor’s vagueness or not willing to cooperate in a fair and appropriate manner. I would expect most if not all experienced safety professionals in heavy industry have seen where the employee has coerced the Doctor by knowing the employee’s true agenda and seeing it regurgitated word for word in the Doctor’s notes for work restrictions.
To go after Safety Incentive Programs as a singular reason for causing inaccurate BLS data or suggest that it cannot be “believed” goes too far in my opinion.
The figure heads in Safety are sometimes too removed from the day to day realities of safety. BLS data might be an input into the goal setting process but I’d never expect data, completely accurate or not, to solve any of the safety concerns within my own company.
I don’t feel Michaels pre-occupation with the in-accuracy of the data due to safety incentive program can amount to much in the real world. He’ll find a way to make industry pay one way or another, but will it improve our system and ultimately protect workers?
Early in my Safety career one of the best pieces of advice was given to me by an OSHA inspector; an experienced one I might add: “Don’t get caught looking for mice or you’ll get run over by an elephant.”