OSHA 300A: A Poster or a Performance Benchmark?
A quick reminder: February 1st was the deadline to post your annual OSHA 300A form, and it must remain posted through April 30th. Employers with more than ten employees and whose establishments are not classified as a partially exempt industry must record work-related injuries and illnesses using OSHA Forms:
It’s now mid-February, last year’s business results have been calculated, the Super Bowl is done, Academy Awards have been won, March Madness is approaching, W-2s are out and your 300A has been completed and posted. Workplaces are abuzz about profit, growth, objectives, taxes, the best films, point spreads, brackets and Injury/Illness Incidence Rates (IIR).
What’s that you say? Most of your employees don’t even know where your 300A is posted; never mind what your IIR rates were. They’re more interested in actors’ and actresses’ bios, statistics of professional NFL football players and college basketball team rankings than their own company’s safety results. As a safety professional visiting many small businesses, I don’t disagree with you. Every year, most 300As are completed, calculated and posted without much ceremony.
Is that because it’s a mandated requirement—something to complete and move on? So are annual 1040s, but we surely compare whether we pay more or less taxes than last year(s). In reality, the OSHA 300A is an important scorecard of your company’s safety program. It can tell you how you did compared to prior years and compared to industry peers. In fact, your 2012 results could be an early indicator to what your 2014 Experience Modification might do when your 2012 results roll into your ERM (Enterprise Risk Management) calculation (and stays for 3 years). In growing use, subcontractors are being asked to submit their OSHA Log data as a requirement of prequalification processes. Establishment specific Days Away Restricted Time (DART) and Days Away from Work Injury and Illness (DAFWII) data are being used by OSHA for next year’s Site-Specific Targeting inspection plan.
Shouldn’t you be paying more attention to that little 300A form and what it represents? Here are a few questions to consider:
- Are company owners or executives informed how injury rates compare to prior year(s), historical and industry averages? (The 300A must be signed by the top corporate officer.)
- Do you compare your rates to that of your industry?
- Are you evaluating for trends over time?
- If your DART rates are trending up, it’s likely your future Insurance Experience Modification may follow suit. Could you do more in the current year to curtail that trend, prior to the actual mod increase? (Note: And by then you might have 2 bad years impacting your Mod.)
- Do you keep or post chart(s) comparing your incidence rates over the years?
- Are your incidence rates discussed in safety meetings and tailgate huddles? (There’s a possibility your past Establishment Specific Injury and Illness Incidents Rates are in the public domain and posted on the Internet by OSHA.)
- Are the company’s incidence rates used in goals or performance evaluations?
- Do you have an understanding as to what the numbers mean?
- Would a Dashboard or Scorecard generate and maintain more interest than posting only numbers? For example: ♦ Exceeds Target ♦ Meets Target ♦ Marginal ♦ Not Acceptable (where you display only one color/result at a time).
- If you’re in the Marginal or Not Acceptable categories, should you put an emphasis on changing that right now and not just wait and hope the results are better, when new numbers come out a year from now? Shouldn’t you implement changes and measure rates and results more frequently?
- Do you have targets that are better than BLS (Bureau of Labor Statistics) Industry Benchmarks (Averages)?
Take Advantage of Safety Data
Even I find it challenging that there’s overwhelming data and statistics on teams and individual players, in all types of formats, tables and charts, for fantasy football. However, try and find anything close to that for worker safety statistics. Until I can invent the Fantasy Safety League, we use what we have.
For data, you could go to the Injuries, Illnesses, and Fatalities (IIF) Page, a page that could rival the IRS Tax Tables, in statistics, data and complexity. Fortunately though, the BLS offers an easy to use Injury and Illness Incidence Rate Calculator and Comparison Tool.
Enter the hours worked and the numbers of cases from your 300A Log. Next, select a year (you’ll have to compare your 2012 against 2011 until 2012 statistics are available later), Industry Area (Private industry, All U.S.; or Private industry, [Your State if applicable], a Supersector, and select the NAICS code for your industry. Then simply click “Calculate” to display your results compared to your industry.
Since incidence rates can often fluctuate in any given year, you should calculate several years of data and plot your rates over time, in order to evaluate longer term trends.
This chart shows Job Transfer/Restriction cases were above national average, increased dramatically and heavily impacted JT/R and DART Rates, in 2011 & 2012. Those trends might have been missed, by just posting numbers, and not analyzing the results.
It’s also a good idea to compare yourself both against your industry, All U.S., and your industry, [Your State], in case there are local differences from national averages. Only states who participate in the BLS Survey of Occupational Injuries and Illnesses are listed in the BLS Tool. So for states like New Hampshire, you can use the neighboring state with the most similar industry traits, or where you actually work (i.e. contractors in the north country might compare to Maine, but southern contractors may be more comparable to, or work more in, Massachusetts).
Hopefully, you now have a tool and information to see how you did, and what results your organization’s safety efforts are producing. I hope your 2012 incidence rates were lower than 2011, and lower than your industry average. If they are, celebrate that with your employees! If either is trending up, or for more information, please contact your local independent Acadia Insurance agent or your Acadia Loss Control Representative.
Acadia is pleased to share this material for the benefit of its customers. Please note, however, that nothing herein should be construed as either legal advice or the provision of professional consulting services. This material is for informational purposes only, and while reasonable care has been utilized in compiling this information, no warranty or representation is made as to accuracy or completeness. Recipients of this material must utilize their own individual professional judgment in implementing sound risk management practices and procedures.