Who Cares If It’s Recordable? How Misapplied Practices in OSHA Injury & Illness Recordkeeping Infringe on the Ethics of Care

Extracts from Leslie Rex Stockel, PhD, CSP, SMP, FASSP’s article on misplaced safety practices and ethics of care:

· “Approximately half a million dollars of annual salaries were sitting in the room spending at least an hour trying to decide … whether the case should be counted as an OSHA recordable case”

· “This decision would impact the organization’s yearly safety goal and everyone’s annual bonus”

· “The OSHA recordkeeping regulation is subject to interpretation, subjective opinion and manipulation”

· “Recordkeeping practices [may help in some ways] … However, they also can put pressure on a bidder to micromanage incident reporting procedures”

· “This can result in inappropriate pressure being applied to workers, making them feel intimidated or conflicted for reporting a work-related injury”

· “extensive time and resources can be expended by practitioners in arbitrating questionable cases of whether to record or not to record”, taking valuable time away from operational risk

· “Safety professionals often face a tension between their own ethical and moral codes and the organizational constraints placed upon them”

· “In poorly managed safety cultures, the incident investigation system can be viewed adversely by employees as an interrogation and blaming process”

· “This condition, compounded with an undue emphasis on recordable avoidance, can explicitly and implicitly communicate to workers that the organizational leadership cares more about the statistical outcomes than the worker’s … well-being”

· “This situation is in violation of the fundamental ethics of care philosophy”

· “An overt emphasis on avoiding incident recordability … creates a temptation and pressure by administrators to sacrifice or second-guess medical treatment to split the fine hairs of regulatory requirements and exploit loopholes”

· “safety performance measures focused on the zero-recordable objective represent a utilitarian de jure approach that only superficially boosts the organization’s public appearance”

· “This misguided emphasis does little to engage workers in a mutually beneficial culture where they perceive themselves as cared for by leadership and subsequently care about organizational success”

· “OSHA never intended for this reporting and recording system to be used as an internal performance measurement device”

· “A particular flaw in using the recordkeeping system for performance tracking is that recordability criteria do not always equivocate with the actual severity of the incident”

· “At a minimum, organizations should consider dividing the administrative decision-making function from the investigation process: separating those who determine the root causes of the incident from those who coordinate injury treatment and medical case management from OSHA recordkeeping”