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June 29, 2016
Safety 2016: OSHA chief emphasizes employer engagement in safety
By Emily Scace, Senior Editor, Safety

At Safety 2016, the annual conference of the American Society of Safety Engineers, Assistant Secretary of Labor for Occupational Safety and Health David Michaels gave an update on his agency’s priorities and his reflections on his time with OSHA to a crowded room of safety professionals. Keep reading to learn what he had to say.

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Much of Michaels’s presentation focused on the agency’s efforts to engage more employers in safety efforts through a variety of channels. One such channel he identified is the agency’s recent shift to conducting Rapid Response Investigations (RRIs) in response to certain reports of severe employee injuries.

In these cases, instead of sending an inspector out to investigate every incident, OSHA instead reaches out to the employer and directs it to conduct a root cause analysis for the incident, then implement and document corrective measures to prevent future incidents. Michaels called the RRI initiative a “collaborative, problem-solving approach” that invites an employer and an OSHA area office to work together towards a common goal of protecting workers.

Michaels also pointed to the recently finalized electronic recordkeeping rule as a tool for improving employer engagement with safety. Under the terms of the final rule, employers with 250 or more workers at a single facility will be required to submit injury and illness information from OSHA forms 300, 301, and 300A, while employers in designated high-hazard industries with between 20 and 249 employees will be required to submit information from form 300A.

OSHA plans to post the information it receives from these reports publicly on its website. According to Michaels, OSHA hopes that the publicly posted information will motivate employers to improve their safety efforts. Employers, he stated, want to be perceived as top performers. If safety performance data becomes public, employers may be incentivized to reduce injury and illness rates in order to attract and retain the best employees and increase profitability.

To illustrate this point, Michaels used an analogy of the sanitation letter grades (A through F) publicly displayed in restaurant windows in many cities. Customers are typically not willing to eat at a restaurant they perceive to be unsanitary; thus, employers who receive a poor sanitation grade lose customers and make fewer profits, motivating them to improve their sanitary practices. Michaels believes the public posting of injury and illness data could have a similar effect and stated that the agency’s goal through the new rule is to drive safety improvement without increasing inspections.

Asked about whether he believes the electronic recordkeeping rule shifts the emphasis in safety too much in favor of lagging indicators (as opposed to leading indicators), Michaels responded that while OSHA encourages employers to use leading safety indicators, lagging indicators such as injury rates cannot be ignored.

“We strongly encourage employers to focus on leading indicators, but if injuries are occurring, those are real,” he stated. If leading indicators are effective, injury and illness rates will follow, he continued.

Michaels, the longest-serving head of OSHA, will step down when the new presidential administration takes office. When asked what piece of advice he would offer to his successor, Michaels said it’s crucial to remember that every employer is different; there is no one-size-fits-all approach to safety. Consequently, OSHA must approach safety from all angles, including both enforcement and compliance assistance efforts, in order to make an impact.

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