Friday, October 16, 2009

No I Haven't Given Up

Anonymous said:
"This has nothing to do with the post, but Abel, where are you? You have not posted in a month! We miss you...."
Thanks, since I've never had an employer open up his arms and say "Glad to see you," it's kind of nice to be missed by at least one person who reads the blog.

You know how fraternities and sororities have Hell Week? CSHOs have Hell Month. And it's not a one time event, it happens every year. Some years are worse than others, and Hell Month becomes Hell Six Weeks. But finally I've gotten to the point where all my OSHA-1s are entered, and I have some kind of handle on the citations. So what shall I rant about? How about this from a previous comment:
"I wonder what the unions and their cronies Barab and Solis will say when their policies increase fatality counts instead of decreasing them. Using their logic, I guess that would make THEM accomplices to murder...? Sadly, a little more than 5000 died while on the job. Lets see what that number is in 2010, 2011, and 2012. My bet ---- higher if they continue down this path."
Here's one for you: I agree that the counts are likely to go up, because of the administrations policies! Before you become apoplectic, however, let me explain (I'm not making a political statement here, so save yours).

Look at these numbers:







120 M




121 M




124 M




126 M




128 M




131 M




133 M




135 M




136 M




136 M




138 M




139 M




140 M




143 M




146 M




147 M




136 M


If the fatality counts are the best indicator, then the previous administration failed, notice the increase in fatalities between 2002 and 2006? Up over 10%, BUT look at the employment, going up, and the rate, basically flat.

Unemployment is currently at 9.8%. At some point in the future, that number will come down, presumably because of the administrations economic policies. When unemployment does come down, I would fully expect the number of fatalities to go up. The number of fatalities will go up because the administration will increase the number of jobs.

All this really does, of course, is highlight the fallacy of fatality counts, so let me state this simply: Counts are almost worthless, fatality rates are the best indicator of success. It will be interesting to see if things change now that BLS has gone to hours based fatality rates instead of FTE based rates.

On a related topic, back on March 30, 2009 I posted a rant about the paper "The impact of OSHA recordkeeping regulation changes on occupational injury and illness trends in the US: a time-series analysis" by Friedman and Forst. The basic premise of the study was that the change in OSHA's recordkeeping standard caused an artificial decrease in injury rates from 2001 to 2003. I made my argument against that position back in March, but now in October, while reviewing the fatality data, I discovered another argument, the drop in fatalities between 2001 and 2002.

So why is the drop in fatalities relevant to the drop in injury rates? Anyone familiar with Heinrich's Pyramid or the refined version from Bird, knows that for every fatality there are 30 lost work day cases and 300 recordable cases. Since the recordkeeping standard didn't change the definition of a fatality, with such a significant drop in fatalities (not just the counts, but the rate as well) between 2001 and 2002, one would reasonably expect a correspondingly large drop in serious injuries as well.

Anyone have any other ideas for topics I could rant about?


  1. Thanks for posting again! I was hoping my comment would elicit a post by about distracted driving as a topic? Apparently it is the #1 killer in the workplace- The US DOT had a summit 2 weeks ago but no one really mentioned it as a workplace issue, I would think this would be an OSHA concern as well?

  2. We can rant about the NEP on Recordkeeping.

    Let's see ... it's not that difficult to "prove" under reporting when you're ignoring over-reporting. Shoot, with that illogical approach, I would be able to prove that conducting OSHA inspections actually raise worker exposures to serious hazards.

    How you may ask? Easy. Count the incidences where it actually does (I agree it's beyond extremely rare! But lets just say that it happens once for argument sake) occur and ignore all the times where the CSHO spots a hazard for abatement. Voila, CSHO inspections increase worker exposures to serious hazards.

  3. Abel,
    Regarding your October 16 blog, Fatality rates absolute and if it happens a significant amount of times within a company or a SIC, it is a barometer predicting a company's accident or injury rate and the businesses' accident rate. While Surfing websites, I found an article that I cited below. The authors write about the Experience Modification Rate (EMR). The calculations based on a company's safety records (injury claims) of the past three full years. This study helps to calculates workers’ compensation insurance premiums. EMR is an indicator of the relationship of money spent on safety and efforts on safety in the workplace. Of course, this is over a time period. I have not read the article thouroughly, but the premise may have statistical validity! As for the usual method for calculating accident or injury rates, there are error deviations when employers complete accident recordings, such as using full time employees as a formula driver or mixing in fatalities with days away to end up not an accurate assessment. My personal view is that Universal health care will become a mechanical machine lacking the ingredients of quality care,translating into increased days away from work, increased death rates,and poor care which can cause an employee to not be their best at work. That will put themselves and others in jeopardy.
    Your comment is correct,
    'The number of fatalities will go up because the administration will increase the number of jobs.'
    I believe there are natural rates of fatalities in the workplace just as there are natural rates of unemployment. I have no idea what that rate is, but there is a direct relationship to a point and then the curve should flatten out and hopefully reverse. Even better, it will go below the lowest rate recorded but that is only a wish. I do not know the history of Solis or Barab, but from what I have read they they want to be sheriffs entering town to set things right which may have negative consequences! Nobody likes a pushy person, right? Before I close, I will say that your article, 'No I Haven't Given Up' was informative! I hope to read more.



    Journal:APPLIED ERGONOMICS: The Affect of Safety Initiatives on Safety Performance: Ergonomics in Building and Construction: Volume 36: Issue 4:July 2005:Pages 461-469
    Authors: Peter Hoonakker, Todd Loushine, Pascale Carayon, James Kallman, Andrew Kapp and Michael J. Smith.

  4. Response to Kevin M.
    EMR is not so much a relation of money spent on Safety as Money spent on Injuries. The problem with the correlation is that a scratch on the head from a nail gun, (near fatality) is only a couple of bucks at a local clinic, where a strained back from an overweight, 60 year old worker cost more money and affects the EMR to a greater degree. Additionally the EMR could be calculated on a combined score of the Manufacturing division and the construction division. A company that erects construction hoists may have zero incidents, but the in house Marine Motors division has a high incident rate - giving them an EMR of 1.7. A serious car accident by someone driving to a jobsite will greatly affect the EMR, regardless of who is at fault. This would have nothing to do with the safety program of the company as a whole.
    The EMR is a good tool, but it should not be the only tool utilized to evaluate a safety program. The purpose of the EMR is to evaluate the money spent, and in many cases this encourages the employer to put the worker back on the job too early, or pay for his care under the table.

  5. Again--let's rant on the Recordkeeping NEP. As long as targeting is based on employer self-reporting of injuries/illnesses, employers will be under-reporting their rates. So, we could spend thousands of CSHO hours reviewing records OR we could find a better way to target inspections.

  6. First, the Recordkeeping NEP comes next.

    Second, Kevin I've seen studies like that one before, and there can be a good relationship between the number of injuries and the amount of money spent on S&H, especially if the injuries are consistent (say nursing staff in a nursing home getting back injuries) and the company is diligent about reporting claims. But, as the commenter after you pointed out, the relationship is really about money spent on injuries. As an employer, if my employee gets a splinter, I'm going to pay for it out of pocket to keep my EMR from going up.

    And then there are industries like logging, which seem to be an all or nothing kind of workplace, you don't see high injury rates. The DART rate for the logging NAICS was 2.5 in 2007, vs 2.1 for all industries and 7.3 in air transportation. The fatality rate, on the other hand, was 4.8 fatalities per 100,000 workers for all industries, but 135.3 for logging (5488 fatalities with 144.5 M employees, vs 92 fatalities with 68 k employees). I'll take my chances slinging burgers, and not just because I'm old.

    Here's something else that blows me away, there are a couple of states out there that do not require WC for illnesses.

  7. Do the employment numbers listed above include government positions - say an OSHA field agent or administrator? Or do they just reflect private sector jobs like construction worker?


  8. Jesse: Those numbers are total employment, including government.

  9. ...Then I think it is an absolutely legitimate argument that as government grows and industry shrinks there will naturally be a decrease in injury RATES.

    Let's face the fact that right now the US is simply replacing more hazardous (and more profitable) jobs with less hazardous (non-profitable) jobs.

    Some call it too many chiefs and not enough Indians.

    Hazardous jobs are not becoming safer as much as they are simply becoming extinct. To what ends? I don't know for sure.. but I can play out a scenario where we over-tax and over-regulate ourselves into an even further broken economy.

    We ARE losing jobs in sectors with HIGHER injury rates and creating jobs in sectors (government) with LOWER injury rates and that WILL effect the overall rates not just the AMOUNT as some would like to argue.

    What they forget that 1 in fishing is worth oh about 1,000,000 in administrative.

    The rate above is not a good enough indicator.

    For example: if the fishing industry stopped tomorrow it would effect the total employment by probably about .00001% but would effect the death toll by about .5%.

    Business Statistics