Many companies have had to complete and post their OSHA 300A Annual Summary for 2021. While it is an exercise required by OSHA, it also gives good indications as to how a company is doing more so as a lagging indicator.
OSHA considers a Recordable Injury as being severe enough to require medical attention beyond first-aid or requiring a worker to miss even one day of work or be on restricted duties or be temporarily transferred from their normal job to one that better suits the restrictions placed on the injured worker by the medical professional. There are many other nuances within the OSHA Recordkeeping standard that further define and explain an OSHA Recordable that you can review at a later opportunity.
Information that can be gleaned from an OSHA 300A Annual Summary include the number of Total OSHA Recordable injuries, basic overall severity of this number of Total OSHA Recordable injuries, indicate potential patterns in the types of injuries, the number of injured workers with a severity enough to be considered an OSHA Recordable per total number of workers, and the amount of lost time or Days Away per the total number of hours worked.
The numbers and ratios that can be determined by examining the various sections of the OSHA 300A Annual Summary and comparing them with other numbers on the OSHA 300A Annual Summary. The Number of Cases indicate, as the section title indicates, the number of each type of OSHA Recordable case the employer had in the given year. The higher the number in each type of case, the more total number of OSHA Recordable cases the company had in the given year.
The severity of an injury can be determined by looking at the number of days the injured worker missed or the number of days the worker was on restricted duties or in a temporary job situation. The more days in any of these three columns, the more severe the injury was.
The Injury and Illness Types section compiles the very basic types of injuries that can indicate a pattern or trend. For example, it would be evident that if there were a significant number of the total Recordable Injuries that were respiratory conditions or hearing loss that would indicate a pattern to further investigate. However, if all of the injuries are marked as “Injuries” that would show that all of the injuries are more of a traumatic or acute nature.
By adding the total number of OSHA Recordable injuries and illness and dividing that by the Average Number of employees, you can get the number of injuries per employee within your company. Another useful ratio is that of the Total Hours Worked by all employees divided by the number of Days Away from Work, which would need to be estimated using hours, which would give you the number of hours “lost” per number of hours worked by all employees.
Using the NAICS code, companies can compare themselves against other companies in the industry by using the Total Number of OSHA Recordables, the average number of employees, and the Total hours worked all inputted into a formula OSHA uses to determine various injury and illness rates then compare the rates against the statistics provided by the Bureau of Labor Statistics (BLS).
One thing, in my opinion, that is very important to observe is that of the signature and Title of the Company Executive that signed the OSHA 300A Annual Summary. The person that signed this form is the one responsible for the overall safety of the workers at that establishment as they should review the numbers on this form and understand how these numbers affect the workers at the establishment. This person is the person responsible to institute the changes and allocate the resources necessary to provide “…employment and a place of employment which are free from recognized hazards that are causing or likely to cause death or serious physical harm…” to their employees.
Low numbers or even high numbers on the OSHA 300A Annual Summary does not give the best indication as to the safety culture of the company however it can be used as one of the tools to indicate the affects of the activities that a company is doing to improve their safety efforts.
There are many more leading indicators that can be tracked in real time that give a better “on-the-spot” evaluation or determination of how your company’s safety efforts are affecting worker safety however since we compiled these year-end statistics, we may as well look at them to see if we can get any useful information.
These ratios may seem abstract and not all that meaningful however when tracked over time such as year over year, it can be seen if the overall effect of the effort is improving, getting worse, or staying the same. This may be information to use to show that the effort needs to be changed or if more needs to be added to the current effort to continue the improvements.
I did not put a lot of comparisons and ratios in this article as it is using lagging indicator information, workers have already suffered a workplace injury, illness, or fatality to be on the OSHA 300A Annual Summary and this information is just one tool in our toolbox as we strive to improve overall worker safety and health and the overall culture of a company.
Please note that I will review how to change the “informal” management system to remove the rewards for risky behaviors and encourage safe behaviors in March as a continuation from the January 2022 blog posting.
For more information and/or assistance, contact:
Wayne Vanderhoof CSP, CIT
Sr. Consultant/President
RJR Safety Inc.