One of our employees was standing at the base of a structure when a gust of wind caught a sheet of plywood 90 feet above him and caused it to land directly on his head. As I helped the paramedics load the employee into the ambulance, I caught a faint whisper. “No prescriptions, okay?” It was our project manager and I found the utterance disturbing. Why? The project manager knew perfectly well that a prescription would make the injury recordable.
The Injury Recording Mentality
This experience fundamentally changed my perception of how injuries are recorded. The fact that in an incident of this magnitude, the project manager was worried only about recordables was troubling enough. What made it even more disturbing was that in his mind, responsibility for avoiding a recordable injury was in the hands of the safety manager, or shall we say for the purpose of this article, the “case manager.” Shouldn’t that be the project manager’s primary concern?
Although it’s an extreme example, this is a fundamental problem in all industries. End results are often valued more than the means to achieve them. Let there be no doubt that if you want a 0.0 recordable incident rate, there are 2 ways to achieve it:
- Honestly by ensuring that the work is done safely so no injuries or illnesses occur; or
- Dishonestly by managing your OSHA 300 log to make it look like the work was done safely.
Manipulating the OHS 300 log isn’t hard. In my time, I’ve seen many blatant reporting violations get swept under the rug. I’ve even quit a job and taken the injury information directly to OSHA — and there was still no citation issued!
Common Underreporting Scams
Underreporting is an epidemic! Here are some of the common scenarios. I hope none of them sound familiar.
The Voodoo Doctor
“I shall make your injuries disappear!”
The Voodoo doctor goes by a more common term: “company doc.” If you’ve managed
injured workers and their recordable status, you know these guys. They’re the “preferred” docs that will give you whatever you want, as long as you keep bringing them business. They’ll back date, document unneeded physical therapy as being required and consider restricted work regular duty — all in the guise of “helping the company out.”
“Pay no attention to that man behind the curtain.”
Remember the pure shock when Dorothy, the Tin Man and company found out the
Wizard had no powers, and was actually just a feeble little person behind the curtain? It’s like that with recordkeeping. There will always be the wizard of recordkeeping, the one who can interpret the recording rules to suit any scenario. Common wizard-speak includes:
- It’s not restricted because . . . ;
- Well, the other doc said he didn’t need the prescription. . .;
- Doc, were those stitches necessary or just cosmetic?;
- Doc can we give him 4 over the counter pain relievers instead?;
- That antibiotic was just precautionary, like a tetanus shot!;
- This guy is out to get us! I have 800 witnesses saying that say he wasn’t hurt;
- This is a pre-existing injury, why do we have to pay for it?; and
- He already had bad knees and elbows before he fell off the scaffold.
The wizard is basically a liar, both to himself and management. The recordkeeping standard leaves little to no room for interpretation. In 2001, it was revised to close the loopholes that many safety professionals had relied on to avoid reporting.
See No Evil, Hear No Evil, Speak No Evil
“It’s easy to ignore it if everyone else does, isn’t it?”
The wizard at least makes attempts to “clean up” the paper trail to keep it from being recordable. The 3 monkey worshipper just pretends it never happened. Sometimes the ignorance is real. Often it’s deliberate and calculated on the assumption that there’s less than a 1% chance that OSHA will ever detect it. Many case managers even erect a mental checklist to justify ignoring the case:
- Employee treated properly by physician and provided restricted duty? Check.
- Management happy on site and off site that we haven’t had recordables? Check.
- Everyone gets to keep their safety incentives? Check.
- Safety Manager is successful? Check.
- The injury was properly recorded on the OSHA 300 log. . . well, not exactly.
- The incident that caused the injury got a strong corrective action and management attention. . . well, no, after all it was only a first aid or that’s at least what we’re calling it.
- Did we just fool ourselves into thinking we were better than we are, and did we put ourselves in a position to hurt more people because we ignore our injuries? Check.
- Did we reinforce with the employees that safety really isn’t the priority that we’ve been saying it was? Check.
Ignoring something is easy, but when you ignore it outside of the law, there are indirect
consequences. I have personally been to dozens of 1 million man hour safety
celebrations and most of them have some an employee in the audiences using crutches
or in a sling.
Recordable injuries have become a standard that management, customers, contractor associations, trade organizations and insurance carriers use to evaluate safety performance. And as the old saying goes, what gets measured is what gets done. Unfortunately, it doesn’t always get done honestly. After all, if a contractor has to have a below 2.0 recordable incident rate to even bid a project, what do you think they’re going to do? Sadly and ironically, this metric developed by OSHA and the Bureau of Labor statistics to improve safety has been distorted to the extent that it often leads to precisely the opposite result.