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Author: Amoako, Moses Title: An Evaluation of Company XYZ’s Safety and Health Program Elements

Towards Participating in an OSHA Voluntary Protection Program

The accompanying research report is submitted to the University of Wisconsin-Stout, Graduate School in partial

completion of the requirements for the

Graduate Degree/Major: M.S. Risk Control

Research Adviser: Dr. Brian Finder, CIH

Submission Term/Year: Spring, 2013

Number of Pages: 82

Style Manual Used: American Psychological Association, 6th edition

I understand that this research report must be officially approved by the Graduate School and that an electronic copy of the approved version will be made available through the University Library website

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My research adviser has approved the content and quality of this paper. STUDENT:

NAME: Amoako, Moses DATE: 03/06/2013

ADVISER: (Committee Chair if MS Plan A or EdS Thesis or Field Project/Problem):

NAME: DATE: 03/06/2013

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This section for MS Plan A Thesis or EdS Thesis/Field Project papers only Committee members (other than your adviser who is listed in the section above) 1. CMTE MEMBER’S NAME: DATE:

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Amoako, Moses. An Evaluation of Company XYZ’s Safety and Health Program Elements

Towards Participating in an OSHA Voluntary Protection Program

Abstract

Organizations today face the risk of losses which result from employee-based injuries and

illnesses. This study analyzed the causal factors which contribute to the occurrence of employee

injury-based losses that ultimately would delay Company XYZ’s intentions of gaining OSHA

VPP approval. The primary method used for the study was to review literature covering

common injuries and illnesses associated with the utility industry as well as risk control best

management practices. The organization’s historical injury-based data was collected and

analyzed based on injury type and body parts which incurred harm. Additionally, a check-sheet

which utilized plan-do-check-act (PDCA) concept was developed to compare the company’s

safety/risk management efforts with OSHA’s VPP requirements, OHSAS 18001, ANSI Z10, and

BBS.

The results of this study indicated that the company incurred employee injury/illness

incidents rates which were above the utility industry average. Also, the study identified that

sprains and strains were the most common injuries incurred by employees. The study indicated

that the employees who were injured performed variety of physical activities. Additionally, it

was identified that aspects of the company’s safety management activities relating to planning,

implementation, and management review were lacking. In order to improve the organization’s

safety performance, it was recommended that proactive indicators from best practice

management systems including OSHA VPP, OHSAS 18001, ANSI Z10, and BBS be integrated

into the existing OH&S programs.

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Acknowledgments

First of all, my thanks go to God Almighty who made it possible for me to be successful

on the risk control program. Also, I would like to thank the risk control staff which includes Dr.

Elbert Sorrell, Dr. Brian Finder, Dr. Bryan Beamer, and Mrs. Mary Volk. I sincerely appreciate

their support and assistance during the pursuit of this degree. Particularly, I would to thank Dr.

Elbert Sorrell, Program Director, for his immense encouragement and counsel while on the

program. Similarly, my profound appreciation goes to Dr. Brian Finder, my research advisor,

who provided the valuable guidance and the counsel that I needed to complete this research

project.

Finally, I would like to specially thank my wife, Vivian Amoako, for her incredible

encouragement and support which has inspired me to achieve this goal. Thank you all and God

bless you!

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Table of Contents

.................................................................................................................................................... Page

Abstract ............................................................................................................................................2

List of Tables ...................................................................................................................................6

List of Figures ..................................................................................................................................7

Chapter I: Introduction .....................................................................................................................9

Statement of the Problem ...................................................................................................11

Purpose of the Study ..........................................................................................................11

Goals of the Study ..............................................................................................................11

Background and Significance ............................................................................................12

Assumptions of the Study ..................................................................................................13

Definition of Terms............................................................................................................13

Chapter II: Literature Review ........................................................................................................15

Injuries in Utility Companies .............................................................................................15

Loss Analysis .....................................................................................................................17

Incidence Rates ......................................................................................................17

Worker Compensation-Based Loss Analysis.........................................................19

Accident Analysis, Correction , and Follow Up ....................................................21

Leading Indicators ................................................................................................24

Lagging Indicators ................................................................................................24

Safety Incentives ...............................................................................................................25

Injury Prevention ...............................................................................................................28

Hierarchy of Hazard Controls ................................................................................28

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OSHA Voluntary Protection Program (VPP) ....................................................................30

The VPP Application Process ................................................................................31

VPP Management Strategies/Activities .................................................................33

Advantages of VPP ................................................................................................34

Risk Control Best Practices ...............................................................................................35

OHSAS 18001 .......................................................................................................35

American National Standard Institute Z10 ............................................................38

Behavior Based Safety .......................................................................................................39

Summary ............................................................................................................................42

Chapter III: Methodology ..............................................................................................................45

Data Collection Procedures ................................................................................................45

Data Analysis .....................................................................................................................46

Chapter IV: Results ........................................................................................................................48

Trends of Work Related Injuries from 2009 to 2011. ........................................................48

Analyzed Data on Worker Compensation Costs from 2005 to 2010.................................53

Analysis of Company XYZ’s Safety/Risk Management Efforts in Relation to OSHA’s

VPP Requirements, OSHAS18001, ANSI Z10, and BBS…..…………………………...55

Chapter V: Conclusions and Recommendations............................................................................60

Limitations .........................................................................................................................60

Conclusions ........................................................................................................................61

Recommendations .................................................................................................................................. 64

Recommended Future Research ........................................................................................67

References ......................................................................................................................................68

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Appendix A ....................................................................................................................................79

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List of Tables

Table 1: Injury and Illness Data from 2009-2011……..…………………………………………48 Table 2: Nonfatal Injury and Illness Incidence Rate…..……..…….……………………………49 Table 3: Summary of Company XYZ’s Risk Control/Safety Management System Evaluated…56

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List of Figures

Figure 1: Nonfatal injury and illness incidence rate……………………….…………………….50 Figure 2: Recordable incidents by departments (2009-2011)..…………….…………………….51 Figure 3: Recordable injuries by type (2008-2012)...…………………….……………………...52 Figure 4: Recordable injuries by body part from 2008 to 2012...………….…………………….53 Figure 5: Comparison of number of worker compensation insurance claims per calendar year

from 2005-2010......……………………………………………….……………………..54 Figure 6: Comparison of total worker compensation insurance cost incurred per calendar year

from 2005 to 2010...……………………………………………….…………………….55

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Chapter I: Introduction

Contrary to what numerous management-based individuals would prefer in the

workplace, employees continue to experience occupational injuries and illnesses (Boden, 2006).

According to the Bureau of Labor Statistics [BLS] (2011), 3,063,400 recorded workplace

occupational illnesses and injuries occurred in private industry throughout the United States of

America (2010 injury rates). The Occupational Health and Safety Administration (OSHA), a

federal agency that regulates worker safety and health, states that injuries result in substantial

loss of revenue to the injured, the employer and the nation, including direct costs such as medical

and legal expenses (OSHA, 2010). Employers bear additional costs with regards to performing

accident investigation, training to replace the injured employees, and loss of productivity.

Furthermore, the victims’ injuries typically lead to extensive worker compensation costs to the

employers. Sengupta and Burton (2011) confirmed that in 2009, cash benefits paid to injured

workers in addition to the medical payment for healthcare amounted to $58.3 billion. In another

report by Liberty Mutual Research Institute for Safety (2011), injuries which caused the victim

to miss six or more days from work in 2009 cost employers $50.1 billion in workers

compensation cost. By all appearances, American workplaces remain prone to substantial cases

of accidents which lead to significant social and financial costs.

In 1982, OSHA established the Voluntary Protection Program (VPP) safety management

system to assist organizations to develop and implement risk control techniques to prevent

workplace injuries. The VPP management system consists of four elements which are intended

to promote a safe work environment. These elements include management leadership and

employee involvement, worksite analysis, hazard prevention and control, and safety and health

training (Friend & Kohn, 2010). Collins and Jervis (2001) found the VPP approach to be generic

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enough to enable its successful combination with existing systems in any type of organization or

industry. In essence, it is likely that the OSHA voluntary protection program is identified by

companies as a comprehensive and effective safety management system that can be utilized to

reduce workplace injuries.

The OSHA VPP gained recognition as a broad-based risk control system, as a result,

approximately 1, 600 worksites became eligible to participate in the program (Bennett & Deitch,

2007). The application process for OSHA VPP recognized status first includes the completion of

a self-assessment checklist to determine a given company’s eligibility for participation. Second,

applicants must prove that they maintain a health and safety management system which includes

the four previously stated VPP elements. Finally, OSHA indicates that its officers are required

to conduct an evaluation which reviews the performance of the company’s specific site in

relation to total case incidence and the days away, restricted or transfer (DART) rates (OSHA,

n.d.). According to the VPP application instructions, the company’s DART cases for the past

three years are compared with the most recently published BLS rates. Approval to VPP status is

awarded to applicants identified by OSHA as those who are utilizing safety programs which

result in injury prevention and incident rates that are below the industry average (n. d.).

Company XYZ is a utility company that seeks to participate in the OSHA VPP program.

As part of the VPP application process, Company XYZ completed the self-assessment of its

safety performance which indicates that the organization has incurred injury rates that are higher

than the industry average. The company is determined to gain the OSHA VPP approval since

this status helps promote the occurrence of further safe practices and thus lead to reduced

workplace injuries and illnesses. During the years 2010 and 2011, Company XYZ’s eighty-four

employee workforce experienced fifteen OSHA recordable injuries which required medical

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treatment. Three out these fifteen incidents resulted in twenty seven lost days to the employees.

Additionally, for the same period of 2010 and 2011, the company incurred seven motor vehicle

incidents. These incidents resulted in damage to the company’s equipment and vehicles which

were involved in the accidents. As a result of these motor incidents, the company incurred a

variety of expenses including payments to repair the damaged property, elevated insurance costs,

and loss of revenue caused by the related downtime. In 2009, the company experienced OSHA

recordable incident rate of 7.4 as compared to their industry average of 4.2. During the same

year, the organization’s DART rate was 3.7 as compared to the industry average of 2.5. A

comparison of both the recordable and DART rates for the period indicates that the company

suffered injuries which exceeded their industry averages. Thus, the occurrence of employee-

based losses is above the industry average at Company XYZ, resulting in reduced productivity

and creating a delay in the company’s ability to gain VPP approval.

Purpose of the Study

The purpose of this study is to analyze causal factors which contribute to the occurrence

of employee injury-based losses and thus impede company XYZ’s intentions of gaining OSHA

VPP approval.

Goals of the Study

1. Analyze trends of injuries from 2009-2011 at company XYZ.

2. Analyze data on worker compensation costs from 2005-2010 which were incurred by

Company XYZ

3. Analyze company XYZ’s safety /risk management efforts in relation to OSHA’s

Voluntary Protection Program requirements

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Background and Significance

Company XYZ has expended $221,172 on worker compensation costs which resulted

from occupational injuries incurred by employees between calendar years 2006 and 2010.

Furthermore, in 2010 and 2011, the organization suffered fifteen OSHA recordable workplace

injuries, of which three of these incidents resulted in twenty seven days worth of lost time.

Whenever a worker is away from duty as a result of an injury, another needs to be either hired or

else assigned to work additional hours to replace the injured employee. In some instances, the

replacement process is costly, in that it involves additional training and orientation of the

substitute worker. This situation places significant fatigue on the fewer employees who might be

required to perform the ever increasing production activities. In addition, the company

experienced seven motor vehicle incidents in the years 2010 and 2011 which caused damage to

the company vehicles and equipment. On one occasion, the company’s truck was involved in an

accident with another privately owned automobile which caused damage to both vehicles. The

repair of the damaged equipment and vehicles cost substantial amounts of money to the

company. Furthermore, these incidents resulted in production downtime, time spent in accident

analysis, and increased insurance premiums to the company. These conditions significantly

downgraded the organization’s assets including finances, equipment, productivity, customer

service, and also reduced employee earnings while such individuals were out of work due to

injury. This study intends to identify the causal factors which are contributing to the injury of

company XYZ’s employees as well as causing various forms of property loss. Reduced injury

rates generally result in increased profitability of a company and heightened employee morale.

With improved incident rates, the company is likely to gain approval to participate in the OSHA

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VPP. Participating in OSHA VPP holds the potential to further minimize or even eliminate

workplace injuries and ultimately preserve the numerous assets of the company.

Assumption of the Study

1. Records of employee injuries are accurate and current.

2. Information which is provided with regard to Company XYZ‘s risk control practices is

truly reflective of what the organization is performing to prevent asset-based loss.

Definition of Terms

Occupational injury. Any injury, including a fatality, which results from a work-related

incident or exposure involving a single incident (Incident Rates, n. d.).

Occupational illness. Any abnormal condition, disorder or other injury resulting from a

work-related exposure to a biological, chemical or physical agent. These include both acute and

chronic illnesses or diseases that may be caused by inhalation, absorption, ingestion or direct

contact (Incident Rates, n. d.).

Total incident rate. It is a mathematical calculation that describes the number of

recordable incidents that a company experiences per 100 full time employees in any given time

frame (Incident Rates, n. d.).

Days away, restricted or transfer rate (DART). A mathematical calculation describing

the number of recordable injuries and illnesses per 100 full-time employees that results in days

away from work, restricted work activity and/or job transfer that a Company has experienced in

any given time frame (Incident Rates, n. d.).

Bureau of labor statistics (BLS). An agency of the United States Department of Labor,

this federal agency functions as the primary data-gathering agency of the federal government in

the field of labor economics. The Bureau of Labor Statistics is responsible for collecting,

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compiling, and analyzing work injury and illness statistics (Wisconsin Department of Workforce

Development, 2012).

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Chapter II: Literature Review

The purpose of this study is to analyze causal factors which contribute to the occurrence

of employee injury-based losses and thus impede company XYZ’s intentions of gaining OSHA

VPP approval. This chapter contains literature on utility-based injuries and illnesses as well as

loss analysis. Other topics included in this chapter are injury prevention measures and the

OSHA Voluntary Protection Program. Additionally, two risk control best practice safety

management systems, the American National Standard Institute (ANSI) Z10 and Occupational

Health and Safety Assessment Series (OHSAS) 18001, will be covered.

Injuries in Utility Companies

Most utility workers perform their duties in a variety of environments, and as a result,

they tend to incur diverse occupational injuries and illnesses. Utility companies engage in water

supply operations, gas delivery systems, as well as electricity generation and distribution (Center

of Excellence, 2008). Employees working in these service areas perform diverse physical

activities such as heavy lifting, working in extreme weather conditions, manual excavation,

working at heights, and in close proximity to energized power lines. The physical force exerted

by utility workers is significant enough to cause musculoskeletal disorders (MSDs) (Professional

Safeguard Resources, 2012). MSDs are a leading cause of lost work days recorded by utility

workers. In the calendar years of 2006 and 2007, utility-based companies suffered 3,770 cases of

MSDs that caused employees to stay away from work (Centers for Disease Control and

Prevention, 2009). As Kelsh et al. (2009) noted, utility workers experience several types of

MSDs because most tasks performed by these individuals involve significant physical exertion

by the body. Most of the activities involve ergonomic risk factors such as repetitive motion,

excessive force, awkward postures, and stationary positions (Professional Safeguard Resources,

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2012). Geigle (2009) also believes that these risk factors contribute to occupational injuries such

as sprains and strains. Campbell (2004); (Marklin & Wilzbacher (1999) found that both

distribution and transmission utility companies incur significant sprains and strains. In 2006,

26.8% of injuries sustained by transmission companies were sprains and strains. At the same

time, sprains and strains accounted for 43.6% of recorded injuries suffered by distribution

companies (Professional Safeguard Resources, 2012). Remarkably, MSDs accounted for a

significant number of injuries experienced in nearly all of the different types of utility operations.

From immediate injury standpoint, it has been determined that gas and electric employees

are also exposed to arc flashes, shocks, electrocutions, and explosions, which cause burns to

these workers. Burns are caused by arc flash which is also defined as “a flashover of electric

current through air from one exposed energized conductor to another or else to ground” (Wulf,

2004, p. 53). Electric line workers who maintain transmission and distribution lines nationwide

are exposed to arc flash hazards. Weigel (2006) claims that on a daily basis, a worker is serious

injured or killed by an electrical arc flash accident every two and a half to five hours in the

United States of America (USA). This suggests that arc flash injuries can reach a record high of

3,650 cases annually. The effect of arc flash incidents can be fatal to workers in that the heat

released at the epicenter of the blaze reaches 36,000˚F, and this extreme heat causes severe burns

to the skin and ignites clothing. It has also been determined that the molten debris caused by the

extreme heat can result in injures to an employee’s eyes (Fluke, 2006).

Electrocution and electrical shock are major injuries experienced in the utility industry.

Spies and Trohman estimated that 1,000 people die as a result of exposure to electricity annually.

For any 100,000 hospitalized patients who suffer burns from electrocution or shock, only 3%

survive in the USA. In addition to burns, electrocution may result in cardiovascular disorders

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and inhibitions of the central nervous system (2006). Taylor J., McGwin G., Jr., Valent F., &

Rue W., also found that electrocution is the fifth leading cause of fatal injuries in the US (2002).

Electric related injuries cause significant loss to most utility companies. To prevent recurrences

of these injuries, the applicable loss acts must be analyzed to identify likely reasons for the

undesirable asset downgrading event.

Loss Analysis

While utility operations continue to experience significant losses because of injuries, it is

prudent to perform a loss analysis of these detrimental events in order to minimize any identified

risks. Loss analysis is an effective tool for evaluating certain forms of data in order to identify

the general risk factors that characterize the undesired event. The review of past loss data

enables safety professionals and managers to detect trends or sources of injuries. Loss analysis

provides direction for the safety professional to determine the root causes of harm and to identify

which areas require specific loss control intervention or improvement (Yuma County, 2009). An

effective analysis is based on available relevant loss data which includes incidence rates, worker

compensation records and accident reports.

Incidence rates. Incidence rates provide an indication of how many employee loss

situations have occurred, and/or may define the severity of the accident. Essentially, incidence

rates measure post performance status and are regarded as reactive tools in loss control (Incident

Rates, n.d.). Jovasevic-Stojanovic and Stojanovic (2009) believe that incidence rates are reactive

safety status indicators that provide post-event information regarding accidents, incidents or near

misses in addition to the consequences of these events. Nationwide incidence rates are derived

from occupational injury and illness data which is compiled, analyzed, and published annually

by the BLS (Wiatrowski, 2004). Even though the BLS is responsible for nationally published

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data, the guidelines for documenting injuries and illnesses are defined by the OSHA record

keeping regulations. OSHA requires employers to maintain data pertaining to fatal and nonfatal

work-related injuries and illnesses that qualify as recordable cases (Bureau of Labor Statistics,

2005). OSHA recordable cases are viewed as injuries that result in death, loss of consciousness,

days away from work, restricted work or job transfer, and medical treatment beyond first aid.

These include work-related injuries diagnosed by a physician or licensed health care practitioner

(OSHA Recordkeeping Handbook, 2005). Recordable injuries are utilized to calculate several

incident rates. There are different major incidence rates which define case types or severity and

permit comparison of injuries and illnesses among industries and establishments. OSHA has

defined specific formulas which enable organizations to calculate the different incidence rates

(Bureau of Labor Statistics, 2012). OSHA (2008) provide standardized criteria for calculating

the rates based on 100 employees working for 40 hours a week, and 50 weeks per year, which

adds up to 200,000 labor hours. Five of the most utilized incident rates include:

Recordable Incident Rate (IR) or Total Injury Case (TCIR)

IR = (Number of OSHA Recordable Cases x 200,000)/(Total Number of Hours Worked

by Employees)

Lost Time Case (LTC)

LTC = (Number of Lost Time Cases x 200,000)/(Total Number of Hours Worked by

Employee)

Lost Work Day Rate (LWD)

(Total Number of Lost Days x 200,000)/(Total Number of Hours Worked by Employee)

Days Away, Restricted or Job transfer (DART)

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DART = (Total Number of DART incident x 200,000)/(Total Number of Hours Worked

by Employee)

Severity Rate (SR)

SR = (Total Number of Lost Days)/ (Total Number of Recordable Incidents)

The most utilized of the above loss-based metrics is the recordable incident rate. It is used as the

basic measure of comparison for injuries and illnesses among companies and across industries.

Other injury ratios include Lost Time Case (LTC) and Lost Workday Rates (LWD). Lost time

involves injuries and illnesses which result in an employee’s inability to work a full day. An

exception is that a fatality is not considered a LTC. LWD and LTC rates are utilized to

determine the number of lost time cases and lost workdays in a company (Incident rates, n.d.).

Whenever an injured employee could work or is assigned an alternate task to accommodate the

limitations caused by an injury or illness, this condition is recorded as a DART event. The final

injury ratio to be discussed is the severity rate. This rate provides the number of lost workdays

per recordable incident (Incident Rates, n.d.). For new VPP applicants, OSHA requires that their

three-year rates for both TCIR and DART should not be above the most recently published BLS

national average for the specific industry (OSHA Instruction, 2003). Consequently, incidence

rates serve as trailing indicators for measuring the performance of an organization’s safety

system (Wachter, 2012). In addition to incidence rates, there are several additional lagging-

based indicators, including worker compensation data, which provide information for performing

a loss analysis.

Worker compensation-based loss analysis. According to Pozzebon (1990) and Bose

(2008), workers’ compensation programs provide support for employees who have sustained

work-related injuries and illnesses by offering the injured individuals income assistance, medical

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care benefits, and rehabilitation services. Sorenson (2007) found that most organizations in the

USA incur substantial losses as a result of worker compensation costs. This has adversely

affected most companies’ operations and profitability (Hansen & Zahlis, 2005). Dunning, et al.

(2008) noted that in the year 2005, 4.2 million recordable work-related injuries prevented 1.2

million employees from being at work, which resulted in direct and indirect costs exceeding

$200 billion to employers. Hansen and Zahlis (2005) contend that even though the frequency of

claims has dropped, especially in situations of lower payments, compensation costs for severe

cases and fatalities continue to rise. Davis (2012); Hansen and Zahlis (2005) agree that the drop

in the frequency of lower claims has been caused by the economic recession which also led to a

reduction in payrolls.

With the rising cost of insurance benefits, most organizations seek to minimize losses

incurred from worker compensation costs by utilizing a variety of strategies (Sorenson, 2007).

Shafer (2009) argues that the success of any strategy targeted at reducing the worker

compensation cost begins with performing an effective loss analysis. An assessment of medical-

based data provides the employer with significant information to ascertain specific hospital

services which have been billed or where injuries are detected (Sorenson, 2007). Early detection

of work related injuries can enable timely treatment, thereby allowing employees to remain at

work. This strategy is utilized to reduce worker compensation costs when injured employees

return to work within a short period of time (Bose, 2008).

Shafer (2009) believes a company’s return-to-work rates should be analyzed in relation to

the organization’s established goals. Whenever only few workers return to work after all the

apparent acceptable loss prevention practices have been implemented, such should be regarded

as an indication that further investigation need to be performed to identify the reasons for this

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type of a performance gap. Bose (2008) discussed a variety of reasons why employees may fail

to return to work including the fear of losing worker compensation benefits, the inability to

receive restricted duty on the job, family oriented resistance, and/or stringent company policies.

An assessment of loss indicators serves as a valuable tool for injury management. Employers

continue to spend a substantial amount of money on worker compensation costs, yet it is possible

to minimize this financial drain through proactive accident analysis and prevention focused

follow-up.

Accident analysis, correction, and follow up. Failures of equipment, people or systems

lead to accidents in the work place (OSHA, 2006). In order to prevent the reoccurrence of such

events, each accident must be analyzed in sufficient detail. Accident analysis utilizes available

incident information to determine the root causes of the event (Stringfellow, 2010). The analysis

process involves the assembling of accident data, classification of loss information, computation

of occurrences and arriving at risk control conclusions (Gillilan, n.d.). Basically, accident

analysis involves a four step process. These steps include assembling the accident related data

and sorting of loss information into defined groupings or types and counting the event

occurrences. Finally, accident analysis comprises systematic processes of utilizing the data

collected to prescribe appropriate risk control interventions (Harleysville Insurance Company,

2008).

To assemble data for analysis during a fact finding process, a variety of records are

utilized by most organizations. Typically, the OSHA 300, 301, and 300A logs, accident

investigation reports, and worker compensation records are analyzed (OSHA, 2005). The OSHA

Form 300 comprises a log/summary of work-related injuries and illnesses while the Form 301

injury and illness incident report provides additional statistics indicating how the accident

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occurred. The third OSHA log is known as Form 300A or Summary of Work-Related Injuries

and Illnesses. This log facilitates the process of calculating and posting incident rates during the

months of February, March, and April of the following year (OSHA, 2001).

Accident prevention is an effective strategy that is utilized to eliminate future loss (Bose,

2008). In order to prevent the reoccurrence of similar loss causing events, accidents must be

investigated with the purpose of determining causal factors (Boraiko, Beardsley, and Wright,

2008). This fact-finding process must be thorough so as to gather detailed information on

hazardous activities and conditions that caused the accident. The accident investigation system

will be effective and valuable when it utilizes strategies requiring that all accidents, including

near hits, are reported in a timely manner (National Safety Council [NSC], 1997). In finding the

root cause of an incident, several accident causation methods are utilized. Petersen (2003) states

that accidents result from a series of factors with the injury being the final event while the

National Safety Council states that accidents are caused by inadequate equipment, personnel, and

management. An effective investigation is one which identifies specific causes which, when

corrected, lead to the permanent elimination of the hazard (Peterson, 2003). According to

Haddock (1999), investigators have relied upon the International Loss Control Institute’s (ILCI)

loss causation model to identify the root causes, basic causes, and immediate causes of accidents.

The model defines root causes as the lack of control at the organization or management system

level. Root causes emanate from inadequate systems, inadequate program standards, and

inadequate compliance to standards in an organization. The second stage of accident causation is

known as basic causes and this includes human errors and job/system failures. The last stage

covers the immediate cause of an accident that results from substandard acts and conditions

which precede unintended damage or harm to people, property, and process. This phase of

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accident causation is characterized by substandard oversight activities from planning, design, to

operation. These activities include inadequate operational procedures, limited system standards,

poor compliance design processes, and lack of routine maintenance schedules. Eventually,

inadequate activities and processes lead to accidents. In order to identify the substandard

activities or procedures which led to loss-based events, the accidents must be investigated.

Essentially, an accident investigation is a reactive approach which identifies possible causes of

an accident. (Tronsker, n. d.).

When accident investigations are complete, reports are prepared to inform management

concerning the causal factors of the loss event to allow for appropriate corrective actions

(National Safety Council, 1997). Accident investigation reports also provide valuable safety

related information regarding past events. Furthermore, these reports contain records which may

assist in answering questions on the effectiveness of past investigations or corrective measures

whenever similar events reoccur (Stalnaker, 2000). Since accident investigation reports provide

data for loss analysis, the information gathered should cover different elements. These elements

include details of the injured person, name, job title, age, and length of employment. Additional

information such as nature of injury, body part, severity of harm, location of event, and

environmental conditions when the accident occurred should also be documented (Boraiko,

Beardsley & Wright, 2008). The National Safety Council (1997) indicates that investigation

reports must provide detailed answers to questions such as:

What happened?

When did it happen?

Where did it happen?

How did it happen?

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Answers to these questions are normally analyzed in conjunction with other available data in

order to provide information for any subsequent corrective action. Thus, accident investigations

are undertaken as a fact finding approach to identify all causes in order to prevent future loss-

based occurrences.

Leading indicators. Grabowski et al. (2007) defined a leading or proactive indicator as

a type of accident precursor which indicates conditions or events of measure that have the ability

of predicting the occurrence of an incident. According to Toellner (2001) these indicators utilize

a variety of approaches to measure safety performance by reporting and managing positive safe

behaviors. To predict potential accidents, most organizations utilize leading indicators such as

job hazard analysis, safety audits, perception surveys, and training (Spear, 2010). These

upstream indicators are valuable tools to safety because when poor or unacceptable performance

occurs in the execution of these activities, modifications or changes can be implemented before

injuries actually occur (Stricoff, 2000). While leading indicators are valuable tools for

preventing accidents, they are not without drawbacks. Øien (2012) contends that they are costly

to implement because of the significant resources involved. Leading indicators provide early

warnings which determine preventive risk control interventions.

Lagging indicators. Lagging indicators are reactive because they measure post-event

losses. The most common reactive indicators utilized in the US include OSHA total recordable

injury/illness index, DART, and lost days rates (Petersen, 2003). Other applicable indicators

comprise of insurance claim data which include the loss ratio and experience modification rate

(EMR) (Spear, 2010). Several concerns have been raised regarding trailing indicators. These

indicators have a low level of confidence because the recording process may have significant

subjectivity. For example, there is considerable variation in interpreting and managing OSHA

25

recordkeeping guidelines. Therefore, determinations regarding OSHA recordability of injuries

may be subjective because of inconsistences in medical decisions (Spear, 2010). Another issue

noted is that because trailing indicators are associated with losses or negative news, employees

are not motivated to report them, especially to management (Petersen, 2003). According to

O’Brien (1998), reactive indicators such as the OSHA recordable index may not accurately

reflect the organization’s safety performance and thus could be misleading. Most safety

professionals agree with the weaknesses identified with lagging indicators, yet upper

management continues to accept them as the basis of performance management. Additionally, it

is believed that trailing indicators will continue to be utilized in the USA because OSHA, a key

stakeholder in health and safety management requires that injuries should be logged and tracked

using incidence rates (Spear, 2010). Watcher (2012) contends that even though lagging

indicators are reactive, they are relatively easy to measure and understand. Peterson (2003)

concluded that since trailing indicators are likely to remain a tool in practice, it would be prudent

to combine reactive approaches with proactive elements including severity analysis. Even

though concerns have been raised regarding trailing indicators, they are widely utilized as a

measure of safety performance in most organizations. To complement previously stated injury

prevention efforts, organizations deploy hierarchy of controls to minimize the risks employees

may be exposed to.

Safety Incentives

In recent years, safety incentive systems or programs have become an accepted practice

in organizations (Government Accountability Office [GAO], 2012). The GAO estimates that

25% of United States (US) manufactures have a form of a safety incentive program in place.

Most of these systems are established to reduce accidents and lost time through reward packages

26

that reinforce safe behavior and discourage unsafe practices (Higdon, 2007). Kneavel and

Holzberg (2010) also affirm that safety incentives confirm management’s awareness and

recognition of an employee’s safe work practices. According to Goodrum and Gangwar (2004),

there are two types of safety incentive systems in practice. One system recognizes fewer injuries

and illnesses as the basis for rewards. The second system provides rewards to acknowledge

behavior based safety practices. Even though both systems have been practiced by different

companies, they have attracted several criticisms from industry players.

An injury based incentive system is controversial for a variety of reasons. Contentions

are that an injury/illness-based rewards program creates avenues for workers to under report the

property or personal damage which occurs on-site (Morrison, 2012). The injury-based incentive

system may also overlook the contributions of equipment and facilities towards accidents.

Apparently, it assumes that accidents are exclusively caused by human factors. For example,

workers who incur injuries purely because of equipment failure may not receive any reward. On

the other hand, employees may practice unsafe acts but still escape injury, thereby earning an

award (Goodrum & Gangwar, 2004). OSHA argues that injury/illness-based incentive programs

which focus on utilizing reactive indicators may not readily predict the causes of the incident

(Fisher & Phillips LLP, 2012). In another report, OSHA states that injury-based reward

programs discourage workers from reporting injuries freely. For example, Hopkins found that

British Petroleum (BP) paid incentives to its workers in Texas City prior to an accident in 2005.

Investigations revealed that in the calendar year 2004, BP’s recordable injury rate was one third

of the industry average, thus leading to the payment of additional financial rewards to employees

(2007). Situations such as this place an entire workforce at risk since the employers cannot

identify the existing hazards that need correcting (OSHA Up to Date, 2012). In a study

27

conducted by GAO, experts and industry officials concluded that rate-based incentive programs

may discourage injury reporting. The report suggests that workplaces policies such as post-

incident drug and alcohol testing may discourage employees from reporting injuries (OSHA Up

to Date, 2012). Employees may not report injuries for fear of losing incentives or being

individually victimized for causing a crew to lose a reward (Geller, 1996).

It is believed that behavior based safety incentive systems are preferred since they are

intended to reward positive and safe practices that will ultimately assist in preventing injuries

(Goodrum & Gangwar, 2004). This pre-loss practice measures leading indicators such as

completed safety inspections, the percentage of employees trained, and reporting of unsafe

conditions or near hits (Kneavel & Holzberg, 2012). In essence, behavior-based incentive

programs eliminate the problem of injury hiding by decoupling rewards from the number of

accidents reported (Goodrum and Gangwar, 2004). Behavior-based incentive programs are

proactive and may lead to genuine safety performance improvement. Most professionals believe

that incentives can improve performance, but that inherent problems may surface as a result of

the manner in which they are implemented.

Injury rate-based incentives continue to attract significant criticism from regulatory

agencies and a section of safety professionals, yet these programs remain popular largely because

they are easy to administer and may superficially improve injury statistics (Daniels & Marlow,

2005). Incentive programs should be reviewed regularly to ensure that any identified flaws are

eliminated (Kneavel & Holzberg, 2012). Safety incentive programs have pros and cons although

when such are utilized by organizations with a proactive approach, then improved safety

performance will likely be the outcome.

28

Injury Prevention

In order to prevent the occurrence of accidents, risk control professionals may utilize

what are often referred to as engineering and/or administrative controls. These controls are

enacted as a means of treating an organization’s moderate to high risks and thus minimize the

potential for loss to occur/recur.

Hierarchy of hazard controls. Safety professionals utilize several systematic processes

and actions that are rated according to effectiveness in minimizing risk to acceptable levels at

workplaces. These classified actions are also known as the hierarchy of controls and may

include a combination of elimination, substitution, engineering systems, and administrative

procedures (Hierarchy of Risk Control, n.d.).

Moderate to high level of risks which are identified in the hazard analysis process must

be eliminated or controlled by utilizing one or a combination of approaches from the hierarchy of

control (Monash University, 2010). The choice or selection of the control is determined based

on the severity of the risk identified. OSHA eTools (n.d.) ranks these controls in their order of

effectiveness:

Elimination /substitution

Engineering controls

Administrative controls

Personal Protective Equipment

The most effective method of control available is by eliminating of the risk. Jensen

(2007) states that elimination controls utilize processes which avoid creating the hazard in the

first place. Where the hazard already exists, the system should be redesigned to eradicate the

risk (The University of New South Wales [UNSW], 2007). Engineering controls are rated next

29

to elimination in terms of efficiency. In essence, this approach requires physically changing a

prevailing hazard to separate it from the employees (UNSW, 2007). The next level of approach

include the administrative controls which provide protection to employees through certain forms

of relief such as work breaks to reduce the time a worker may be exposed to the hazards (OSHA,

n.d.). A drawback with this practice is that since the hazards are not eliminated, the failure of

employees to comply with stipulated administrative procedures may lead to exposure to hazards

(International Labor Organization [ILO], n.d.). Ultimately, administrative controls may be

effective depending on the extent to which employees are compliant with company rules.

Personal protection equipment (PPE) is the least effective control system within the

preventive hierarchy. This approach requires employees to wear clothing or devices which serve

as a protective barrier against hazardous exposures. These devices or clothing are normally worn

to protect the eyes, head, and other parts of the body (Jensen, 2007). PPE is the least effective

risk reduction approach and should only be utilized when other controls may not sufficiently

abate the hazard. Most forms of PPE are uncomfortable, decrease work performance, and may

cause other health hazards. Several of these devices have health and safety implications when

not used correctly. Hence, workers require training on wearing and handling PPE safely (ILO,

n.d.).

In general, hazard controls are selected according to their effectiveness to eliminate or

minimize workers exposure to hazardous conditions. One type of control may be found to be

more effective than another in a given situation depending on the specific hazard and other

conditions prevailing. Ultimately, it is the company’s responsibility to develop, implement, and

subsequently maintain the hazard control in order to prevent the occurrence of employee and/or

property-based loss.

30

OSHA Voluntary Protection Program (VPP)

The VPP was formally announced by OSHA in 1982 and since that time it has fostered

partnerships with worksites and organizations to promote safe and healthy workplaces.

Businesses participating in the VPP regard OSHA standards as a minimum level of safety

performance and therefore implement rigorous rules that enable them to provide better protection

for the employees (OSHA, 2009). VPP is categorized into three rankings of excellence as star,

merit and demonstration. The star credential is awarded to businesses that have comprehensive

safety and health management system in place. These organizations are identified as utilizing

these programs to significantly reduce injuries and illnesses (Garner & Horn, 2000). The second

status of recognition is the merit program. This status is awarded to organizations which have

demonstrated commitment to the ideals of the VPP but fall short of attaining the star recognition.

Such businesses have eligibility to gain star credential through improved safety performance

(Bennette & Deitch, 2007). The third class of recognition is the demonstration status.

Demonstration programs allow companies to implement alternative approaches which enable

OSHA to test the efficacy of different systems (All about VPP, n.d.). Essentially, the VPP is a

partnership system which recognizes and prompts its participants to incrementally improve their

risk reduction systems.

The VPP approach is an OSHA initiative which recognizes superior worker safety and

health management systems. The OSHA VPP system promotes the development of site-specific

occupational health and safety programs which are implemented by organizations (Swartz,

2000). The VPP initiative is based on a cooperative approach which embraces OSHA,

employees, and employers, with all playing a role in promoting workplace safety practices

(OSHA instruction, 2003). Distinctively, the VPP supports performance-based safety systems

31

and places emphasis on key elements such as management responsibility for worker safety and

health as well as repeated identification and control of hazards (OSHA, n.d.). To achieve the

primary goal, VPP emphasizes the implementation of four core elements at each participating

organization or worksite. These four elements are management leadership and employee

involvement, worksite analysis, hazard prevention and control, and safety and health training.

The VPP initiative must be integrated into the organization’s safety and health management

system through leadership support. The leadership element is referred to as the foundation of the

VPP since the system will fail without management support (Lyon & Vaughn-Peterson, 2005).

The program is strictly voluntary and a company intending to participate submits an application

describing their system towards worker protection efforts for the review of OSHA officials

(OSHA instructions, 2003).

The VPP application process. The initial application process includes a self-evaluation

as well as submission of company safety performance documentation, which is then followed by

an on-site assessment. The VPP application process is defined by OSHA and begins with the

self-assessment performed by prospective applicants. Potential sites and organizations utilize a

checklist to identify and evaluate if they meet qualifications to participate in the VPP program.

(Swartz, 2000) A critical element that provides information of a company’s qualification for

VPP status is the prior three years of total recordable and DART rates, and OSHA requires that

these performance indicators must be below their respective industry averages. After the

assessment is performed, a gap analysis is conducted to enable any identified deficiencies to be

corrected (Swartz, 200; VPP: Recognizing Excellence in Safety and Health, n.d.). According to

Swartz (2000), the assessment survey contains questions which assist companies to determine

32

items requiring improvement. For example, questions on the availability of documents and

programs to be reviewed by OSHA include:

Written PPE program

Written Hazard Communication Program

A complete listing of worksite chemicals

Lockout/tagout program

Safety meetings

Facility inspections

Material Safety Data Sheet for each chemical

Document identifying employee training

Facility emergency plan

For instance, a company which identifies items that require improvement from this list may

establish corrective actions to address them prior to forwarding the VPP application (Swartz,

2000).

The application packet requires basic information regarding the company’s name, type of

business undertaken, and number of employees engaged, along with any union information.

Subsequently, the organization presents three years of safety performance data including the total

case incidence ratio for OSHA recordable nonfatal injuries/illnesses as well as DART rates.

Applicants who are successful at this application-based stage will receive a notification from

OSHA to schedule a date for an on-site assessment (Bennett, & Deitch, 2007).

The on-site assessment process involves a walkthrough to observe working conditions

and a review of documents covering hazard controls programs such as lockout/tagout, confined

space, and respiratory protection. Additional data to be reviewed include the company’s OSHA

33

300 logs, accident investigation reports, and worker compensation data (VPP: Recognizing

Excellence in Safety and Health, n.d.). On completion of the assessment process, a report is

presented to the respective organization which indicates recommended improvements for

identified performance gaps. When all corrections are made, OSHA officially writes a formal

letter which authorizes the organization to participate in the VPP (Bennette & Deitch, 2007). In

summary, the VPP application process involves self-evaluation of the applicant’s own programs

followed by OSHA’s onsite appraisal of the existing safety system.

VPP management strategies/activities. Four basic elements define the implementation

of the OSHA VPP. As stated previously, these elements include management leadership and

employee involvement, worksite analysis, hazard prevention and control, and safety and health

training. The management leadership and employee involvement elements are regarded as the

driving force of the VPP since the effectiveness of the initiative relies on executive support. This

component requires management to provide the safety policy together with adequate resources,

and be committed to support the VPP. To foster the cooperative approach of VPP, the workforce

is required to be trained and involved in the implementation of the program. It must be

recognized that employee and supervisory training complements management’s commitment to

implement the VPP initiative.

Worksite analysis comprises a variety of risk control techniques which are utilized to

promote worker protection. These include an analysis of leading and lagging indicators, training

programs, site inspection, job hazard analysis, industrial hygiene sampling, and a review of

existing OSHA logs (Bennette & Deitch, 2007). Hazard prevention and control is the third

element, and it defines methods and approaches for preventing and abating hazards. These entail

OSHA hazard controls programs such as lockout/tagout, confine space entry, engineering

34

methods, safety rules, and the development of procedures and practices (OSHA VPP Policies

and Procedures Manual, 2008). The fourth VPP element is training and includes training topics

which are classified under regulatory and job-specific programs. This element provides

guidelines pertaining to the design of formal and informal training programs for employees and

supervisors. For example, training provides an opportunity for workers to receive education in

hazard communication, the proper use of PPE, and the effective handling of emergency

situations. Additionally, this element requires that training programs such as new employee

orientation should maintain appropriate documentation of attendance and the specific training

topics which were covered (Jervis & Collins, 2001). The four VPP elements provide the

guidelines for management and employers on effective implementation of the system.

Advantages of VPP. There are many benefits to be derived from participating in VPP.

First, VPP embraces management principles that promote total quality concepts and recognize

excellence. The program creates cooperation among employers, employees, and OSHA (Swartz,

2000). Additionally, participants in the OSHA VPP do not receive penalties for code violations

identified on their sites, but rather, an opportunity is provided for the organization to correct the

unsafe conditions. The VPP allows employees to obtain ownership of the program and become

motivated to preserve the ideals of their management system (Swartz, 2000). Another benefit is

achieved through reduced injuries leading to improved asset protection and the minimization of

human and financial liabilities such as worker compensation costs. Thus, companies become

profitable and can be favorably positioned to compete in their business fields (Bennette &

Deitch; 2007, Swartz, 2000). Contractors who participate in VPP are likely to achieve improved

safety performance and also prompt the associated employees to take pride in their respective

worksites (Swartz, 2000).

35

Risk Control Best Practices

A variety of management systems identified by OSHA are comparable to VPP and are

utilized to promote global injury and illness prevention. Two of these programs are the

Occupational Health and Safety Assessment Series (OHSAS) 18001, and the American National

Standards Institute (ANSI) Z10 standard which was developed by the American Industrial

Hygiene Association (AIHA). The ANSI Z10 standard is a consensus-based standard that is

widely accepted for utilization by businesses as a safety management system on a voluntary basis

(OSHA Injury and Illness, 2012; Rancour, 2005). These two systems have several elements in

common for promoting injury prevention at the workplace. (Swartz, 2000; Abrams, 2006).

OHSAS 18001. OHSAS 18001 is a safety management system which was originally

developed by British Standards Institution (BSI) in 1999 for the business community and

provides guidelines for auditing occupational health management systems. In 2007, OHSAS was

harmonized with the International Standards Organization (ISO) 1400:2004 to embrace

environmental management systems (Seabrook & Winterholer, 2003). OHSAS is structured

along the management concept called plan-do-check-act (PDCA) (Rancor, 2005). In broad

terms, the “plan or planning” section defines the general requirements which are needed to

deliver results in accordance with the organization’s Occupational Health and Safety (OH&S)

policy.

Four specific sub-units fall under the OHSAS 18001planning process. The first is the

Occupational Health and Safety (OH&S) policy. This segment requires top management to

define and authorize the organizations OH&S policy. It must include commitment to continual

improvement and clearly indicate the OH&S objective. This planning element must define how

an organization will communicate its framework for goal setting and remain current (NCSI,

36

2012). The second planning element provides guidelines for outlining hazard identification, risk

assessment and risk control practices. The third planning segment addresses legal aspects and

other requirements and it defines rules and procedures for identifying all legal commitments

regarding the OH&S policy. This segment evaluates the relevance of the policy with respect to

the organization’s operations. Additionally, the organization needs to communicate relevant

information on legal and other requirements to persons working under the control of the

company and other relevant interested persons. The fourth planning component defines the

objectives of the program. Directions for organizations to establish and maintain documented

OH&S objectives are describe in this section. For example, this aspect ensures that elements

such as legal requirements, OH&S hazards and risks are contained in the organization’s safety

policy. Additionally, this section defines other major program objectives which involve

financial, operational and business needs as well as the views of other parties which must be

included in the company’s OH&S program (OHSAS 18001, 2007). Ultimately, the planning

process of the OHSAS standard provides the foundation for the implementation of the OH&S

policy.

The “do” element of the PDCA process involves the implementation and operation of the

OH&S policy. This standard prescribes that the OH&S policy should define the structure and

the responsibilities for personnel who manage the safety system. It places responsibility for

providing resources for the safety program on management. This section of OHSAS further

defines how reports on the OH&S policy performance should be presented to top management

for improvement. Included in this component is training and awareness. Training is important

for the successful implementation of the OH&S policy. Training must be conducted in order to

prepare employees for effective implementation of the program (NQA, 2009). Additionally,

37

documentation and data control as well as emergency response and preparedness are deemed

essential ingredients for any effective program (OHSAS 18001, 2007; NCSI, 2012).

After the implementation stage, the policy must be checked and corrective action needs to

be taken where there are identified deficiencies. The safety performance of an organization

should be monitored and measured regularly for the purpose of improvement. For example, the

OH&S policy performance is measured utilizing several data sources including lagging and

leading indicators. These include records of accidents, near-misses, lost workdays, and other

historical asset downgrading data (OHSAS 18001, 2007; NCSI, 2012).

The final component of the OHSAS 18001 process addresses management reviews and

actions required to improve the performance of the safety systems. For example, accident and

incident investigations must be emphasized by the OH&S policy in order to identify the root

causes so that future occurrences are prevented. Furthermore, sub-standard practices should be

identified and corrected on a continuous basis (NQA, 2009). Management should ensure that

audits are conducted and results are reviewed to determine suitability, adequacy and

effectiveness of the program. Management reviews must be documented and address possible

needs for changes to the policy or other program elements when required. This is what provides

direction and guidance for the continuous improvement process. (OHSAS 18001, 2007; NCSI,

2012). OHSAS provides a variety of advantages including enhanced worker protection, a

potential reduction in incident rates, and savings made on worker compensation costs.

Additionally, OHSAS standards may lead to improved operational performance through policies

and procedures (NQA, 2009). In essence, the benefits of the OH&S are achieved through

implementation, evaluation and management review of the program.

38

American national standard institute (ANSI) Z10. The ANSI Z10 Occupational

Health and Safety (OH&S) Management System is a consensus standard which was developed

by the American Industrial Hygiene Association (AIHA) in 2005. This standard provides an

outline for improving the OH&S management systems with the objective of reducing workplace

injuries and illnesses (Manuele, 2006). Palassis (2007) states that major components covered in

this document include:

Management leadership and employee participation.

Planning.

Implementation of the OH&S management systems.

Evaluation and corrective action.

Management review.

The ANSI Z10 is identical to the OHSAS 18001 in that both standards are based on the

PDCA model. Similar to the OHSAS, ANSI Z10 requires leadership involvement in the

management of the safety system in order to comply with this standard. Several sub-elements

must be established by the leadership of the organization including the OH&S policy as well as

the health and safety policy. Businesses must institute processes that allow for employee

participation in the system (Manuele, 2006). The management component defines the roles and

responsibilities of the organizations’ leadership.

Similar to OSHAS, the first section under ANSI Z10 is the planning component, which

defines process and strategies for implementing the standard. It includes goal setting and

performing a hazard analysis in order to prioritize identified OH&S concerns for eventual

abatement actions (Palassis 2006). The second step is the implementation and operation of the

standard. This section prescribes the operations required for applying the standard. A variety of

39

elements are specified for hierarchy of control which include elimination, substitution,

engineering, administration, and PPE.

Design review and management of change are important aspects of the ANSI Z10

implementation process. Management of change systems are established whenever new changes

in operations are enacted, which require that safety designs are updated for existing facilities and

equipment. Appropriate strategies need to be established to identify and eliminate hazards at the

process design stages. Based on design reviews, required changes shall be determined and

applied to the system for improvement (Manuele, 2006). Also, training and awareness programs

are necessary for the effective implementation of the system. Additionally, the program should

provide well-structured lines of communication and document control processes so that audit

results would be provided to those responsible for the correction of flaws. (Manuele, 2006). The

ANSI Z10 requires that the OH&S systems performance be measured and monitored utilizing

several methods. For example, conducting accident investigations, performing audits and

implementing corrective actions assist organizations in preventing future loss-based occurrences.

Feedback should be provided to guide the planning process for continuous improvement.

Finally, ANSI Z10 specifies a management review of the OH&S by emphasizing evaluation of

process requirements and results of assessments in order to continuously improve the system

(Palassis, 2006). In summary, ANSI Z10 uses a continuous improvement process to reduce

hazards, incidents, and lost time at workplaces.

Behavior-Based Safety

Another safety delivery approach which has emerged in recent years is Behavior-Based

Safety (BBS). This approach has been promoted by a section of safety professionals on account

that it enhances worker involvement and participation in health and safety initiatives (Swartz,

40

2000). This safety approach emphasizes identification of critical behaviors while employees

observe other fellow workers. According to Swartz (2000), critical behaviors are practices that

workers are compelled to implement in order to protect themselves from residual risk which was

not originally eliminated by management. BBS in a way assigns blame to employees for most

accidents. BBS is founded on the belief that most of the accident are caused by unsafe acts of

workers (Smith, 1999). With this background, the root causes of accidents may not be tackled.

Additionally, since BBS apportions faults to employees, it has the potential of promoting under

reporting of injuries (Swartz, 2000). However, proponents of this program believe the BBS

approach provides positive systems that employees utilize to minimize occupational risks and

prevent accidents (Geller, 2005). Kaila (2006) agrees with Geller and affirms that BBS promotes

the concept of being concerned with each other’s safety and continuously striving to prevent

unsafe behaviors. This model can be adopted by an organization, yet may only yield positive

results when combined with proactive safety management systems (Swartz, 2000). While most

companies embrace BBS, it continues to face high criticism from most safety professionals.

Although BBS may not be an effective tool for injury prevention in companies where

management commitment to safety is lacking, the program continues to be implemented utilizing

variety of approaches.

BBS is a collaborative approach in which management and employees alike generally

agree to support occupational safety and health systems at the workplaces (Turnbeaugh, 2010).

Swartz (2000) agrees with Turnbeaugh and affirms that most companies which promote BBS

view the concept as one which allows appreciable worker involvement and participation in the

organization’s health and safety efforts. Worker participation is identified in several aspects.

For example, employees may provide important feedback on the tasks they perform as well as

41

information on typical challenges they encounter while at work. In certain situations, employees

provide information on injuries, illnesses and near-misses that have happened as well as explain

why and how specific hazards occur and also suggest solutions (Swartz, 2000). Yet Swartz

argues that most BBS programs are often combined with incentive systems similar to those

discussed within the incentive section of this chapter. For example, companies which promote

incentive packages utilize injury statistics as a benchmark for rewards. This may lead to a

situation which encourages under reporting of incidents in order to justify the effectiveness of the

BBS practice (2000). Geller (2005) believes that individuals usually pursue specific goals in

anticipated of particular outcomes or benefits. This principle describes what is known as the

ABC model in BBS. In the ABC system, “A” stands for activator or antecedent or person, “B”

represents behavior or actions of an individual, and “C” denotes consequence or events that

follow an employee’s conduct. The BBS approach applies this ABC model to implement

interventions which improve behavior at individual, group, and organizational levels (Geller,

2005). It is believed that a person’s behavior in a particular manner may be motivated

significantly by the consequences of that action. For example, employees successive behavior in

a specific situation or condition may be dictated by praise or appreciation, discipline or feedback

received in a prior event (McFarlane & Ocon, 2007).

Employees’ behavior may be modified to prevent workplace injury through application

of positive reinforcement. It is identified that behavior produces consequences and these

outcomes will then result in specific actions which also determine whether that behavior will be

repeated or avoided (McFarlane & Ocon, 2007). For example, positive remarks received by an

employee for executing a task with the right procedure increases the probability of this behavior

being repeated or learned. On the contrary, negative consequences increase the probability of the

42

behavior being avoided. As a proactive approach in BBS, successful companies apply the

technique of positive reinforcement which serves as an incentive to motivate employees to work

safely (Turnbeaugh, 2010). Ultimately, BBS may be utilized effectively to reduce workplace

injuries and illnesses when management and employees embrace positive reinforcement which

leads to individuals developing safety oriented conducts.

Summary

Fundamentally, utility employees perform different duties in a variety of environmental

settings and thus carry out physical activities which involve overexertion with most of these

assignments being performed in extreme weather conditions. Consequently utility workers are

prone to several occupational illnesses and injuries including MSDs, burns caused by electric arc

flash, electrocution, and disorders of the central nervous system. In order to measure the impact

of these injury-based losses, organizations utilize several reactive indicators which include

incidence rates, worker compensation claims and accident data.

Several risk control approaches are utilized to prevent injuries and illnesses at the

workplace. For example, accident investigations are conducted in order to identify the causes of

loss-based events which assist in preventing the reoccurrence of similar incidents. Additionally,

a variety of proactive techniques such as such as inspections, employee training, and workplace

surveys are identified as tools that assist in minimizing injury-based losses. Also, organizations

implement safety incentive programs which reward workers for reduced injuries recorded at the

workplace. Another effective injury preventive approach involves the application of hierarchy of

controls. These include, in order of effectiveness, elimination, engineering, administrative

controls, and PPE. Besides, several occupational safety and health management systems have

been identified as possible programs which may be implemented to improved workplace safety.

43

Four different safety management approaches are noted as having the potential of

improving an organization’s safety performance. These include OSHAVPP, OHSAS 18001,

ANSI Z10, and BBS model. The OSHA VPP essentially provides recognition for organizations

with excellent safety performance records. VPP is a cooperative initiative between organizations

and OSHA which requires companies to implement four program elements. OHSAS18001 and

ANSI Z10 are both consensus safety management standards. The two standards are modeled on

the quality management concept of plan, do, check, and, act principle which underscores the goal

of continuous improvement of an organizations’ safety management system. Finally, BBS is a

safety technique which enables organizations to involve their employees to participate in the

company’s safety and health improvement efforts. With this program, workers’ behavior may be

reformed with the intent of preventing workplace injury by motivating employees to develop and

preserve a safe work culture.

There are several recognized tools that can be utilized in an organization to identify and

analyzed causes of injury-based losses. An evaluation of loss-based data such as incidence rates,

worker compensation claims will provide information about types of injuries and cost incurred as

a result of the downgrading events. Another approach would involve a gap analysis on the

current health and safety program elements in relation to risk management systems such as

OSHA VPP, OHSAS, ANSI Z10, and BSS model. This will provide potential deficiencies

which might need to be addressed. In order to ultimately reduce injuries, the causal factors

would be identified from both the loss-based data and the gap analysis involving the safety

program elements. Recommendations will be provided based on the identified injury-based

causal factors utilizing both qualitative and quantitative assessments. The recommendations will

44

cover elements and/or procedures which can potentially assist to improve the safety performance

at company XYZ and ultimately reduce the injury-based losses.

45

Chapter III: Methodology

The purpose of this study is to analyze causal factors which contribute to the occurrence

of employee injury-based losses and thus impede company XYZ’s intentions of gaining OSHA

Voluntary Protection Program (VPP) approval. This study evaluated quantitative and qualitative

data to measure injuries-based losses at company XYZ. The goals of the study are:

1. Analyze trends of injuries from 2009-2011 at company XYZ.

2. Analyze data on worker compensation costs from 2005-2010 which were incurred

by Company XYZ.

3. Analyze company XYZ’s safety/risk management efforts in relation to OSHA’s

VPP requirements, OHSAS 18001, ANSI Z10, and BBS.

Data Collection Procedures

The injury and illness data was obtained with permission from Company XYZ’s safety

department. The data which was compiled by the safety department was hand delivered to the

researcher in a hard copy format without names or other personal identifiers. Similarly, the

worker compensation data which also did not include personal identifiers was provided to the

researcher in a hard copy format. Additionally, data regarding Company XYZ’s management

practices was obtained personally by the researcher through a reviewing of several documents

obtained from the safety department. These documents included the company’s safety manual

written programs, and administrative as well as work procedures which provided information on

employee training, hazard identification, analysis, and treatment. All the hard-copy injury/illness

data as well as company XYZ’s management’s practices were stored in locked area during times

when such was not being analyzed by the researcher. These documents were destroyed at the

conclusion of the research project.

46

Data Analysis

Injury-based data was used to determine incidence rates for each year considered.

Additionally, the analyzed information was presented in graphs and tables. Information utilized

included:

Incidence rates

Injuries

Workers’ Compensation-based Cost

The worker compensation-based costs were classified and analyzed on the basis of injury type

and departments. Injury loss data was also analyzed based on the machine/activity where the

worker was hurt. In performing the loss analysis, information will be presented in tables and

charts.

In addition to analyzing of injury-based losses, other program elements were analyzed. A

gap analysis was conducted utilizing the risk control best management practice elements which

are based on the continuous improvement concept of PDCA. These safety program components

which were extracted from OHSAS 18001, ANSI Z10, VPP, and BBS were used to evaluate the

performance of existing safety system and practices at company XYZ. A check-sheet (see

Appendix A) was developed and used as the benchmark for best management practices which

were stated in the literature review. The comments section of the checklist will provide

additional information which will assist the researcher to determine the significance or relevance

of a specific element for the purposes of classification and analysis. This benchmark was further

used to perform a gap analysis in relation to the existing safety system and daily operations at

company XYZ. Utilizing document reviews, the researcher compared the checklist elements

with company XYZ’s current operational practices. The evaluation indicated Company XYZ’s

47

operational activities which conform to best risk management practices and those which revealed

gaps. Ultimately, these risk control best practice program components cover a variety of

workplace safety practices which have the potential of promoting a continuous improvement of

company XYZ’s OH&S efforts.

The information obtained from the organization’s injury and internal process/procedure

gap analyses were then used to develop recommendations involving program elements and

processes which would contribute to improve the safety performance of Company XYZ as well

as potentially reduce workplace injuries.

48

Chapter IV: Results

The purpose of this study was to analyze causal factors which contribute to the

occurrence of employee injury-based losses and thus impede company XYZ’s intentions of

gaining OSHA Voluntary Protection Program (VPP) approval. The methodology that was

utilized for this study involved gathering of safety data on management systems and historical

injury-based documents from Company XYZ. The following goals of the study formed the basis

on which the injury-based documents were analyzed.

Goals of the study

1. Analyze trends of injuries from 2009-2011 at company XYZ.

2. Analyze data on worker compensation costs from 2005-2010 which were incurred

by Company XYZ.

3. Analyze Company XYZ’s safety/risk management efforts in relation to OSHA’s

VPP requirements, OHSAS 18001, ANSI Z10, and BBS.

Trends of Work Related Injuries from 2009 to 2011

The researcher analyzed specific injury-based data from 2009-2011 at Company XYZ.

Table 1

Injury and Illness Data from 2009-2011

Year Total

Number of

Recordable

Cases

Total

Number of

employee

Hours

Total Number of Days

Away from work,

Restricted or Transfer

(DART) Cases

Total

Number of

Days Away

Cases

Total

Number of

Days Away

2009 6 161,840 3 1 2

2010 8 159,936 3 3 27

2011 7 152,320 1 0 0

49

Table 1 above indicates the recordable injury and illness cases incurred by Company

XYZ between the period of 2009 to 2011. The data covered included entire hours worked by all

employees, total cases involving days away from work, restricted work activity, and/or job

transfer cases, cases involving days away from work, and the number of days away from work.

In Table 1, the DART and days away from work rates for 2010 significantly stand out with a

value of 3 in each case. As indicated in Chapter II, recordable injury data is utilized to calculate

several incident rates which define case types and permit comparison of hurts and illnesses

among industries and establishments as illustrated in Table 2.

Table 2

Nonfatal Injury and Illness Incidence Rate

Year Incidence Rate Company XYZ Utilities Industry’s Averages

2009 Total Recordable Incident Rate 7.4 3.3

Days Away from Work Rate 1.2 1.0

DART Rate 3.7 1.8

2010 Recordable Incident Rate 10 3.1

Days Away from Work Rate 3.8 1.0

DART Rate 3.8 1.7

2011 Recordable Incident Rate 9.2 3.5

Days Away from Work Rate 0.0 1.0

DART Rate 1.3 1.9

50

Figure 1. Nonfatal injury and illness incidence rate.

In reviewing the data in Table 2 and Figure 1, it is identified that for three successive

years, Company XYZ experienced incidence rates which were above the national averages of the

utilities’ industry. Both Figure 1 and Table 2 indicate that in 2009, for every 100 employees, 7.4

personnel experienced a recordable injury or illness. Likewise, in 2010, for every 100 workers,

10 employees were involved in a recordable job related injury or illness. Furthermore, for every

100 employees, 9.2 workers experienced work related injury or illness in 2011. Similarly, during

the calendar years of 2009 and 2010, the Company incurred DART rates which were above the

industry average for utilities. Likewise, for the same period of 2009 and 2010, the company

experienced lost workdays which exceeded the national average. However, in the year 2011,

Company XYZ recorded slightly lower values than the national averages for both DART and lost

workday rates.

51

Figure 2. Recordable incidents by departments (2009-2011). The above Figure illustrates the number of recordable incidents incurred by each

department from 2009 to 2011. A trend arises from Figure 2 which indicates that departments

such as Electric Line, Gas /Water Meter, Meter Readers, and Gas/Water Distribution which

perform outdoor duties, incurred significant incidents during this period.

52

Figure 3. Recordable injuries by type (2008-2012).

Figure 3 indicates injuries by types which were recorded by company XYZ over the

period of 2008 to 2012. It is identified that a multiplicity of injuries were experienced by the

company over this period. The figure illustrates a trend which identifies a significant number of

MSD-related injuries such as strains and sprains as well as contusions which were incurred by

employees.

53

Figure 4. Recordable injuries by body part from 2008 to 2012.

The data in Figure 4 indicate the employee body parts which suffered injuries at

Company XYZ from 2008 to 2012. Significantly, most of the injuries were associated with the

back, shoulder, and knee.

Analyzed Data on Worker Compensation Costs from 2005-2010 Which Were Incurred By

Company XYZ

The researcher intended to classify and analyze worker compensation-based data on the

basis of the injury type and departments. However, the researcher was unable to receive the

relevant data from the company. Whether or not the worker compensation (WC) data based on

injury and department was unavailable is unknown. The worker compensation data which was

handed out to the researcher is analyzed and presented in Figures 5 and 6. These figures indicate

the number of claims recorded and worker compensation costs paid by Company XYZ from

2005 to 2010.

54

Figure 5. Comparison of number of worker compensation insurance claims per calendar year

from 2005-2010.

Figure 5 presents a comparison of the number WC claims per calendar year. This figure

indicates that consistently, the number of claims filed decreased from 9 to 4 between calendar

years of 2005 to 2008. Also, the figure identifies that the lowest number of entitlements were

filed in 2008. Significantly, the trend changed after 2008 with the number of claims

continuously increasing in 2009 as well as 2010. Figure 5 indicates that the highest number of

cases for WC entitlements were recorded in 2010.

55

Figure 6. Comparison of total worker compensation insurance cost incurred per calendar year

from 2005 to 2010.

Figure 6 illustrates a comparison of total WC cost incurred per calendar year from 2005

to 2010. The figure identifies a significant surge in the total WC cost for the calendar year 2007.

Additionally, Figure 6 illustrates that for the periods of 2005, 2006, and 2008, the total cost

incurred ranges from a low of $1,570 to $3,649. The years 2009 and 2010 indicates slightly

higher total cost incurred in the sums of $21,620 and $12,197 respectively.

Analysis of Company XYZ’s Safety/Risk Management Efforts in Relation to OSHA’s VPP

Requirements, OSHAS18001, ANSI Z10, and BBS

To accomplish the third objective, information was drawn from the literature review

utilizing risk control best practice elements to develop a benchmark/check-sheet for evaluating

the safety management system at Company XYZ. The assessment check-sheet which was

56

developed by the researcher was based on the PDCA format with the evaluated elements

classified under the following broad headings:

Safety Policy/Leadership.

Planning

Do/Implementation

Check/Corrective Action

Act/ Management Review

The evaluation of these elements/activities which was performed by the researcher is indicated in

Appendix A. Table 3 presents a summary of data which was generated from the above five

elements of the best practice assessment process.

Table 3

Summary of Company XYZ’s Risk Control/ Safety Management System Evaluated in Appendix A

Activity/ Criteria Number of

Activities Evaluated

Activity Percentage Needing

Improvement* Present Not Present

Safety Policy/Leadership 10 9 1 10%

Planning 9 7 2 22%

Do/Implementation 9 7 2 22%

Check/Corrective Action 11 10 1 9%

Act/ Management Review 6 1 5 83% *The percentage improvement is calculated using activity “not present” as a ratio of all elements evaluated in each segment. The results presented in Table 3 depict the number of safety management activities that

were either present or not present at Company XYZ, based on the check-sheet utilized for the

assessment. The most remarkable finding from Table 3 is that 83% of elements/activities

associated with Act/Management Review components were not present at the company. The

57

assessment of this category in Appendix A indicated that there was not a formal scheme set in

place by the organization to review the OH&S management system. Also, it was identified that

there was no activity present which would enabled the company executive to evaluate the

suitability, adequacy, and effectiveness of the OH&S management system. The result indicated

that Company XYZ did not have a follow up scheme which provided the basis for continuous

improvement of the OH& S management process.

Additionally, Table 3 indicates that both the Planning and Do/Implementation activities

were not adequately present and needed 22% improvement of these components. The evaluation

in Appendix A indicates a few elements were not present within the planning segment. For

example, procedures for hazard identification and risk assessment do not take into account the

design of work areas and processes. Also, the result indicates that employees have little

knowledge of the objectives of the health and safety management systems. On the other hand,

the evaluation identifies that Company XYZ maintained procedures for ongoing hazard

identification, assessment, and the determination of the necessary controls.

A more focused evaluation of the Do/Implementation activities reveals areas requiring

improvement as well as elements that were in practice at this organization. The assessment

identifies elements not present to include activities for the training of employees in hazard

identification and analysis. Seven elements were present at Company XYZ under this group

which includes activities related to employee participation in accident investigation as well as

procedures utilized to determine controls. Additionally, it was evident that employees were

consulted when changes which affect OH&S operation were implemented. Furthermore, the

check-sheet identifies several training activities that were utilized by Company XYZ. These

include established training programs for supervisors and employees, and procedures necessary

58

to determine the training needs of workers. Also, it was identified that training was delivered by

competent individuals. Likewise, the evaluation indicates that reporting procedures were

designed such that employees can anonymously communicate safety concerns. Additionally, the

results indicate that employees were recognized through positive reinforcement for proactive

safety acts. The assessment also affirms that incentive packages were not pre-planned and

rewards were not provided to recognize fewer injuries/illnesses experienced or reported by

employees. Nevertheless, celebrations were performed once a milestone was achieved.

With regard to the Check/Corrective Action activities, the check-sheet evaluation

indicates that significant elements were present, with only 9% needing improvement. The only

activity which was not present was that the company did not perform internal audits of its

systems. The activities present include implementation and documentation of routine inspections

and training of employees who perform workplace assessments and hazard identification

activities. Additionally, the evaluation indicates that incident rates were the primary benchmark

for measuring safety performance. Finally, the evaluation indicates that Company XYZ had a

formal system in place which promoted the reporting of near hits.

In summary, the results of the study indicate that the total incident rate consistently was

above the national utility average for the three years considered. Also, for two years, 2009 and

2010, the company’s DART and Lost day rates were above the industry’s average. Additionally,

departments which performed outdoor duties recorded injuries consistently for the three year

period of 2009 to 2011. The results illustrate trends which identified injuries associated with

musculoskeletal disorders. With repect to WC, the results indicate that consistently, the number

of claims filed per year decreased from 9 to 4 during the calendar years of 2005 to 2008, but

surged slightly in 2009 and 2010. Also, the total cost incurred for the period of 2005 to 2010

59

was rather erratic with the most significant amount of $178,519 being recorded in the year 2007.

Finally, the results revealed that activities/criteria which fall under management

review/correction and implementation components of the risk control management system were

in need of improvement. Essentially, this chapter reviewed the purpose and the goals of the

study as well as results of the data gathered in conjunction with the literature reviewed. The data

from this section offered the basis on which valid conclusion and recommendations will be

provided in Chapter V.

60

Chapter V: Conclusions and Recommendations

The purpose of this study was to analyze causal factors which contribute to the occurrence of

employee injury-based losses and thus impede company XYZ’s intentions of gaining OSHA

Voluntary Protection Program (VPP) approval. The following are the goals of the study:

4. Analyze trends of injuries from 2009-2011 at company XYZ.

5. Analyze data on worker compensation costs from 2005-2010 which were incurred

by Company XYZ.

6. Analyze Company XYZ’s safety/risk management efforts in relation to OSHA’s

VPP requirements, OHSAS 18001, ANSI Z10, and BBS.

The research instrument which was utilized for data collection involved gathering safety data on

management systems/activities and historical injury-based documents from Company XYZ. The

study examined employee-based losses by analyzing historical injury and worker compensation

data in relation to reviewed literature. Additionally, a check-sheet which was developed based

on risk control best practices was utilized to evaluate processes of the prevailing safety

management systems/activities at Company XYZ. The goals of the study served as the basis for

the type of data which was collected as well as the subsequent analysis.

Limitations

The worker compensation data used for this study was limited to the number of claims per year

and total cost per year. This is because the worker compensation-based data provided by

Company XYZ did not include relevant historical records required for analysis on the basis of

injury type and department. Thus, the worker compensation-based loss data for the study was

not analyzed on the basis of injury type and departments.

61

Conclusions

Based on the data collected for this study, the following conclusions can be drawn with regard to

the causal factors which contribute to the occurrence of employee injury-based losses and thus

impede company XYZ’s intentions of gaining OSHA VPP approval:

The findings reveal that Company XYZ’s prior three years (2009-2011) total recordable

and DART rates were above the national average for utilities. As discussed in the study,

these post-event loss indicators are symptoms of possible safety performance gaps which

are present and may contribute to the occurrence of accidents/incidents at Company

XYZ.

The company did not meet the eligibility criteria to participate in the VPP program.

A review of the injury data indicate that between the calendar years of 2009-2011,

employees from several departments including Electric Line, Gas /Water Meter, Meter

Reader, and Gas/Water Distribution consistently experienced significant incidents during

this period. Also, for this period, the Gas/Water Distribution and Meter Reader

Departments experienced the highest overall occurrence of injuries. The persistent

occurrence of injuries by workers in these departments can be attributed to the physical

tasks as well as the types of environment in which these employees performed their

duties. This may suggests that employees in these departments experienced appreciable

exposure to injuries during their normal work duties.

The study indicates that the injuries incurred by the employees include significant MSD-

related cases such as strains and sprains. It is possible to conclude that the employees

experienced the MSD-related injuries because these individuals performed tasks which

involved significant physical exertion by the body. It is also possible that these injuries

62

could contribute substantially to the amount of lost time which is experienced by

employees at Company XYZ. As discussed in the study, MSDs are a leading cause of

lost work days for utility workers and therefore it is possible that Company XYZ could

experience similar working conditions.

Additionally, the study finds that the body parts which frequently experienced injuries

include the knees, shoulders, back, fingers, elbows, and thumbs. It can be concluded that

these body parts sustained injuries possibly because the employees performed diverse

physical activities such as heavy lifting, working in extreme weather conditions,

kneeling, manual excavation, and working at heights which exposed them to a variety of

hazards and risk factors.

The highest numbers of worker compensation claims were recorded in 2009 and 2010

with the lowest being registered in 2008. Also, the company incurred a significant surge

in the total worker compensation cost from $5,151 in 2006 to $178,519 in 2007.

Based on the risk control best practice check-sheet evaluations, it is identified that even

though the OH&S systems were reviewed by the safety committee, the component of

management appraisal is not formally implemented at company XYZ. It appears that the

OH&S management system may not experience a formal review by the organization’s

executives which could propel a continuous improvement process of the program.

The check-sheet assessment reveals that the organization’s planning activities were not

adequately present and indicated a 22% deficiency of these components. It appears that

procedures for hazard identification and risk assessment do not take into account the

design of work areas and processes. This could possibly produce workplace conditions

which were not designed with the objective of “fitting the job to workers” at Company

63

XYZ. Also, there is an indication that employees did not possess adequate knowledge

regarding the goals and objectives of the health and safety management systems. The

lack of adequate knowledge of the goals and objectives relating to the OH&S system by

workers could lead to apathy in employee involvement and participation in various safety

improvement initiatives.

The study finds that the company’s do/implementation elements experienced a 22%

deficiency of these activities. The elements which were not present in this grouping

include training of employees in hazard identification and analysis. The absence of this

type of training may deny employees of the relevant skills needed for effective loss

control activities at the workplace which may be creating significant safety delivery gaps.

This condition may possibly result in the use of substandard procedures which cause

employees to overlook potential hazards which are causing injuries.

The findings reveal that significant elements were present within the Check/Corrective

Action activities, requiring only a 9% improvement in this area. It is identified that

Company XYZ has not performed internal audits of its risk control/safety-based

systems/activities. The nonexistence of audits is likely to result in weak overall

assessment of the adequacy and effectiveness of the safety system. Without effective

assessment, it is possible to conclude that the organization’s executives could not

substantiate needed changes to the policy or other program elements as required.

The study reveals that incident rates were used as the primary benchmark for measuring

safety performance at company XYZ. As discussed earlier in this study, reactive

indicators such as incident rates may not accurately reflect the organization’s safety

performance and thus could be misleading. It appears incident rates were used to

64

evaluate safety performance at Company XYZ because these ratios are relatively easy to

measure and understand. This collaborates to prior discussion in this study which

attributed this practice to the continual acceptance of incident rates by most company

executives as the primary benchmark for safety performance measurement.

Recommendations

In order to promote a the reduction of loss-based causal factors, it is recommended that

established procedures, activities and policies be implemented to reduce the occurrence of

employee injury-based losses which impede Company XYZ’s intentions of gaining OSHA VPP

approval. Accordingly, the following recommendations are provided for company XYZ:

To minimize the number of injuries/illnesses and improve the incident rates, proactive

strategies should be targeted at hazard identification, analysis, risk assessment and

controls. This may include the application of predictive strategies such as regular

job/process audits, job evaluations, safety checklist, toolbox talks, and provide training in

risk assessment techniques for supervisory personnel. These may complement existing

and other strategies listed in subsequent recommendations.

Incident rates should not be used as the sole safety performance measurement. Instead,

this should be used in conjunction with proactive indicators which provide early

warnings and determine viable preventive risk control interventions. These activities

may include:

Safety job inspections.

Job safety analysis (JSA).

Design and implementation of training programs.

Observing of workers.

65

Determining the root causes for identified losses.

Conducting employee perception surveys.

The risk assessment of operations, equipment, facilities, and process design stages should

be accompanied with the appropriate hierarchy of hazard controls. This will mitigate the

risk factors associated with tasks/and the nature of environment in which

employees/departments perform their duties. The hierarchy of hazard controls may be

utilized in the following ranking of effectiveness:

Elimination/substitution.

Engineering controls.

Administrative controls.

Personal Protective Equipment.

Implement management of change strategies whenever new safety designs are applied to

existing operations, facilities, and equipment. The following considerations as defined by

OSHA Process safety management ( n.d.) should be addressed prior to the

implementation of any change:

The impact of the change on safety and health.

Modification of operating procedures.

Necessary time period for the change.

Informing and training employees and all who will be impacted by the change

prior to the implementation.

Proactive interventions and strategies should be targeted at controlling/minimizing the

exposure to physical activities which include repetitive motion, excessive force, awkward

postures, and stationary position risk factors. The mitigation of these risk factors may

66

have the potential to significantly reduce the occurrence of MDS-related injuries which

were the most prevalent cases at Company XYZ. This could be achieved by conducting

an ergonomic assessment of the specific physical activities performed by employees.

Company XYZ may integrate injury management strategies such as early return-to-work

programs. An effective injury management policy may lead to reduced worker

compensation costs when injured employees return to work within a short period of time.

Company XYZ’s executives should establish a regular and formal management review

process for the OH&S system. This would provide management with the relevant

information on the adequacy, effectiveness, and suitability of the OH&S system, and

thereby form the basis for continuous improvement of the plan.

The management of Company XYZ may consider conducting an awareness campaign

which would provide adequate knowledge regarding the goals and objectives of the

health and safety management system. This can motivate employee participation and

buy-in to the safety improvement initiatives.

The integration of training programs in hazard identification and analysis could empower

employees to play active roles to support the loss control objectives at the locations

where people, equipment, materials, and the environment are downgraded.

Audits conducted by independent personnel are very important for the continuous

improvement of a safety management system. One of the requirements of OSHAS 18001

managements system is for companies to establish and maintain an internal audit

program. This will assist an organization to periodically determine whether the OH&S

management system conforms to the planned arrangements as well as be effective in

meeting the organization’s policy objectives. Therefore regular audits should be

67

established by Company XYZ to facilitate an update and overall improvement of the

safety management system.

Integrate best practice safety management systems such as OSHAS 18001, ANSI Z10,

VPP and BBS into the current programs. This has the likelihood to enhance continuous

improvement of safety delivery and performance at Company XYZ.

Recommended Future Research

Further ergonomic evaluations should be considered on field activities such as pipe installation

tasks involving significant tightening of bolts which have recently caused MSD-related injuries.

68

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Appendix A: Risk Control Best Practices.

Activity/Criteria Present

(Y/N)

Comments

Safety Policy/ Leadership

Does the company have a written safety and health

management system in place?

Yes May not exist all in one document

Has management defined and authorized the

organization’s safety policy?

Yes

Is the policy consistent with the scope of the OH&S

program?

Yes

Does top management accept responsibility for

safety and health administration?

Yes

Are assignments for safety and health documented? Yes Recently published by the Safety

Committee

Do the individuals assigned responsibility for health

and safety have the authority to correct hazards?

Yes Safety Specialist, Departmental

Safety Representative

Are adequate resources dedicated to workplace

safety and health activities?

Yes

Does the organization’s safety policy demonstrate

commitment to injury and illness prevention efforts?

Yes

Is the company safety policy reviewed regularly? Yes Joint Safety Committee

Do the employees of the company understand the

goals and objectives of the health and safety

management systems?

No More work is needed

Planning

Do the procedures for hazard identification and risk

assessment consider the routine activities of the

organization?

Yes Pre-job briefings, beginning to

create JSA’s, some Certifications of

PPE hazard assessment, IH

assessment

Do the procedures for hazards identification and risk

assessment consider non-routine activities of the

organization?

No

80

Activity/Criteria Present

(Y/N)

Comments

Do the procedures for hazard identification and risk

assessment consider the effects of the design of

work areas and processes?

No Working on Management of Change

Do employees understand the goals and objectives

of the health and safety management systems?

No More work is needed in this area

Is health and safety effectively integrated in the

company’s overall management planning process?

Yes

Does the organization have objectives and programs

for injury prevention?

Yes

Does the company perform hazard analysis covering

routine activities?

Yes Pre-Job Briefings

Are procedures established to determined

appropriate hierarchy of controls?

Yes Not formal

Is there an effective hazard analysis system in place

for routine operations?

Yes

Do/ Implementation

Has the organization established procedures for

workers to participate in hazard identification?

Yes Pre-Job briefings, Safety Cards,

Safety Representative audits

Has the organization established procedures for the

workers to participate in determining controls?

Yes Safety Team, Sub-Committee

Are procedures available to permit workers to be

involved in accident/incident investigation?

Yes Includes injured employee, direct

supervisor, department manager, and

President

Are employees consulted when changes which

affect the OH&S operations are implemented?

Yes

Do employees participate in the development of

OH&S programs?

Yes

Does the company provide safety and health training

for managers and supervisors?

Yes OSHA 10-Hour class is being

planned

81

Activity/Criteria Present

(Y/N)

Comments

Does the company provide safety and health training

for the employees?

Yes

Are procedures established to determine whether

employee training needs are meant?

Yes

Is training delivered by competent individuals? Yes Safety Specialist or outside

consultant

Are employees trained in hazard identification? No Not formally

Are employees trained in hazard analysis? No Not formally

Is there a system for employees to report hazards

and have them addressed?

Yes Safety. Cards, email, one-on-one

conversation

Does the hazard reporting system designed such that

employees can anonymously state safety concerns?

Yes Safety Cards

Are employees recognized through positive

reinforcement for proactive safety acts?

Yes Safety observation process (needs

improvement though

Does the company have incentive package in place

for low injury rates recorded?

No Recognition is not pre-planned, but

celebrations are held once

milestones are achieved.

Check/Corrective Action

Are incidence rates the primary benchmark for

measuring safety performance?

Yes

Does the organization have a system for performing

safety and health inspections?

Yes Monthly Safety representative

Audits

Are routine safety and health inspection performed

at least monthly?

Yes

Are employees who perform safety inspections

adequately trained in hazard identifications?

Yes Hazard Identification Training has

been provided

Does the company perform internal audits of its

systems?

No

Are the routine inspections documented to indicate

what needed to be corrected?

Yes

82

Activity/Criteria Present

(Y/N)

Comments

Is there a formal system for reporting near misses?

Yes

Does the organization have accident investigation

procedures set in place?

Yes

Are accidents investigated to determine root causes? Yes

Are prompt measures implemented to correct

deficiencies identified during accident

investigations?

Yes

Is feedback communicated to improve the planning

of OH&S operations?

Yes

Act/Management Review

Is there a system set in place for management to

review OH&S management systems?

No

Does top management review the OH&S No

Does the review determine the suitability of the

OH&S system?

No

Does the review determine the adequacy of the

OH&S system?

No

Does the review determine the effectiveness of the

OH&S system?

No

Does the review provide follow ups for continuous

improvement of the OH&S processes?

No