Voluntary public disclosure of corporate environmental problems and progress has gained momentum recently. Several groups that promote environmental reporting and responsibility include the Public Environmental Reporting Initiative, Coalition for Environmentally Responsible Economies, Business Council for Sustainable Development, Global Environmental Management Initiative, Council on Economic Priorities, Investor Responsibility Research Center, and the Chemical Manufacturers Association Responsible Care Program.Among the often addressed and highly visible issues of air emissions, greenhouse gases, ozone depleting substances, water effluents, hazardous wastes, radioactive releases, landfill depletion, ground water pollution, product stewardship, life cycle management, and environmental risk assessment one area is often ignored - workplace health and safety. For reasons subject to much speculation, OSHA compliance and worker safety continues to be given low priority in the growing national trend toward environmental responsibility.
Five steps can be taken by employers to demonstrate they are equally committed to environmental conditions inside their plants as they are to those that affect the general public. These are:
Report OSHA Inspection Enforcement Statistics
Workplace safety and health inspections are performed by federal OSHA and so-called "18(b) State Plan" states. Section 18(b) of the OSH Act promulgated by Congress in 1970 permitted states to operate their own safety and health enforcement programs provided such programs were approved and continually monitored by federal OSHA. Currently, 25 states operate their own programs. These are generally administered through state departments of labor.
There were 128,495 workplace inspections performed in FY92 by the federal government and state labor departments. This represents a much smaller number of the total covered workplaces that could be inspected each year. Inspected worksites, even in high hazard industries, are rarely reinspected on a random basis more than once every several years unless a subject of an employee complaint or fatality. It is clear from these circumstances that not every worksite will have existent data for any given reporting period.
In spite of this, employers whose worksites receive an OSHA inspection, and whose OSHA alleged violations become a final order during its selected reporting period, should report the following selected enforcement statistics for each inspection:
Number of non-grouped "serious" violations per employee at site for all worksites with 10 or more employees. Number of "willful" violations. Number of "repeat" violations. Number of violations assessed with "failure-to-abate" penalties. The employer should report the following additional statistics for all worksites under their control or ownership during their selected reporting period :
Number of inspections initiated in response to employee complaints. Number of inspections initiated in response to fatalities or catastrophes. Number of sites approved by OSHA's Voluntary Protection Program (VPP). If any approvals withdrawn, provide reason. Report Annual Lost Work Day Injury Rate
One generally recognized measure of workplace safety is the lost workday injury rate (LWDI). This index represents the number of injuries or lost workdays related to a common exposure base of 100 full-time employees working a 40 hour work week for 50 weeks per year. It allows normalized inter- and intra-industry comparisons or trend analysis.
Employers should calculate the LWDI from data reported on their annual OSHA No. 200 "Summary of Occupational Injuries and Illnesses" in accordance with the familiar formula: LWDI = (N/EH) x 200,000 where N = number of injuries or lost workdays, EH = total hours worked by all employees during calendar year and 200,000 = base for 100 equivalent full-time workers (40 hr./wk, 50 wk./yr.)
The LWDI should be calculated for each physical site. It should be reported with the employers primary 4-digit Standard Industrial Classification (SIC) from the 1987 SIC Manual published by the federal Office of Management and Budget and the most recently available 4-digit national average LWDI for that SIC code as published by the federal Bureau of Labor Statistics in its Annual Survey of Occupational Injuries and Illnesses.
Report Ratio of Certified Professionals to Number of Employees
Industrial hygienists certified by the American Board of Industrial Hygiene, Lansing, MI or safety professionals certified by the Board of Certified Safety Professionals, Savoy, IL are recognized in the field as being those individuals most qualified to render occupational safety and health services to employees. Management commitment to worker safety may be gauged by reporting either of the following two employment ratios:
Ratio of employed full-time (non-contracted) Certified Hygienists and/or Certified Safety Professionals per employees controlled nationally, if safety and health function is organized on a centralized basis or, Ratio of employed full-time (non-contracted) Certified Industrial Hygienists and/or Certified Safety Professionals per employees at site, if safety and health function is organized on a decentralized basis. Disclose OSHA Numbers 200 and 101
Employers are obligated to maintain annual logs of workplace related injuries and illnesses by recording incidents on the OSHA No. 200 "Summary of Occupational Injuries and Illnesses" and OSHA No. 101 "Supplementary Record of Occupational Injuries and Illnesses." Employers must post these records for a set period of time each year and must produce them upon demand by an OSHA compliance officer. Data contained in these records are used to calculate the LWDI as noted above.
OSHA continues to target high hazard industries for unannounced inspections based upon comparisons of industry average LWDI with the same statistic for private sector national average rate. Since workplace injury data is deemed so critical to effective prioritization and use of limited government resources, employers should make this same information publicly available upon request.
Report Experience Modification Factor
Worker's compensation insurance experience modification factors are used by underwriters to set premium rates for their insured. Basically, these values are determined by comparing the insured's actual losses within specific occupational classifications to expected losses for that same classification. This factor allows a relative performance evaluation of specific employers based on experience. Employers should disclose their experience modification factor along with loss histories and employee job classifications upon which the factor is based.
The five actions recommended above would provide a consistent means of quantifying corporate workplace safety and health activities, demonstrate corporate good citizenship, and go a long way in bringing industrial hygiene and safety into mainstream public consciousness.
Copyright 1997 OSHA DATA (tm), Maplewood, NJ.
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