Monday, June 25, 2012

When did you last witness safety trumping other considerations?

In popular culture, the opening sentence of a bad novel begins with the clichĂ© phrase, “It was a dark and stormy night…”. Returning late last week from Washington, DC and a NIOSH workshop on the use of workers’ compensation data for occupational safety and health, I was stuck in Toronto-Pearson International Airport at dusk as the clouds darkened ominously. Through the boarding lounge window, I could see a wall of rain sweeping towards the terminal. On the top of every jetway, white strobes began flashing in unison. Over the handheld communicator a ground agent was carrying, I heard the announcement: the tarmac and apron were being cleared for safety reasons: lightning strikes from the dark storm clouds approaching YYZ.


The safety equation on this dark and stormy night was particularly evident. The inbound plane at our gate was a mere five meters from the jetway with a full manifest of passengers. At other gates, flights had been loaded and doors closed. Planes were still landing but backing up, still burning fuel, and clock time for aircrews. Connections were being missed, overtime incurred, and schedules overturned. Despite all these costs, all activity on the field stopped for the protection of ground crews.

Our lounge was full of passengers for Vancouver, BC or carrying on to Sydney, Australia. In almost perfect unison, thousands of people in Terminal 1 pulled smartphones and began checking connections and informing friends, families and colleagues of the indeterminent delay.

Here was an actual example of safety trumping other considerations. You can’t fuel an aircraft, load it with baggage and cargo, or push it back from the gate without workers and the risk of injury to a worker during a lightning storm is significant; an average of 57 people are killed each year in the US due to lighting strikes. Canada has shorter lightning seasons than in the US, yet lightening kills 9 or 10 people and injures between 100 and 150 people each year. Safety is about managing risks and managing the risks in this case means stopping airside operations.

How did people in my very crowded waiting lounge react? Most took the delay in stride. I heard one passenger actual say to the gate agent, “Worker safety should come first.”
After a couple of hours with intermittent starts and stops due to the storm, operations got going again. There was a huge backlog of flights. Our Air Canada flight 033 was fully loaded and had to wait 45 minutes after the doors closed before a crew was available for pushback.

Yes, we arrived home three or four hours later than planned… but we were safe and so were the crews that served us along the way.

There is nothing inherently safe about air travel. What makes it safe is a culture that values safety at every point, in the air and on the ground. Wouldn’t the world be a better place if we could day the same thing about every industry?

“There is nothing inherently safe about [building a bridge, lifting a patient, felling a tree…] what makes it safe is a culture that values safety.”

Monday, June 11, 2012

"what does the research tell us about...?"

Three times in the last week, I received calls or emails that contained a question that began, “What does the research tell us about…?” Each question related to a current issue in workers’ compensation and prevention. One wanted to know which prevention strategies have the best evidence as being effective. Another was interested in the degree to which financial “secondary gain” might be a factor in claim duration. Another asked about the elevated risk victims of a certain common occupation disease claims might have for other serious illnesses (with the implication of compensability).


These are all good questions. Each has real-world implications for policy, case management and prevention. In some cases, there are solid answers from the published literature; in others, the question is unanswered or there is too little information to provide a clear answer at this time.

Behind each question lie important assumptions:
1. Valid, peer reviewed research matters to policy makers and practitioners

2. Scientific hypothesis testing and data analysis in properly designed and ethically applied research provides better information for decision making than conjecture

3. Research that has been subject to scrutiny and review by other researchers is defensible as a basis for decision making

4. The synthesize of the many pieces of research necessary to arrive at valid answers to such questions has taken place.

There is often a fifth assumption: research is “costless”. It is “free” in that most research policy makers need will eventually be published in peer-reviewed journals. However, I get the impression that anyone asking a policy analyst the questions above assumes the information is “out there” and will only take a little scratching about to summarize in a briefing note.

I know that most policy makers and practitioners would never say research is costless if they gave it any thought, but I am certain not one of the people asking me these important questions could put a dollar figure on a given piece of research. Even if they could, (I know I couldn’t), I doubt they would take into account the costs beyond the dollars involved. Every scientist, Master’s student and Ph.D. candidate who applies their intellectual resources to research questions in workers’ compensation, prevention and rehabilitation is foregoing other research topics—an opportunity cost that can have huge implications.

I had the pleasure of welcoming nearly 200 researchers, students and policy makers to the Canadian Association for Research on Work and Health (CARWH) to their conference in Vancouver a few days ago. WorkSafeBC has funded research and researchers for more than 40 years and was proud to be the host organization for this event. WSIB Ontario, WCB Nova Scotia, and IWH Ontario also directly supported this event. Many other organizations were represented through the research presented that was the product of their financial support (the IRSST in Quebec and WCB Manitoba among them). Far from being “free riders”, these organizations understand that research is not costless and have made a commitment to paying a share of that cost. It is not the “price of admission” but it is an admission that there is a price worth paying for answers that will make a difference in workers’ compensation and prevention.

Along with guests from the US, Australia, New Zealand and the United Kingdom, I had the opportunity to meet with researchers, ask questions and discuss areas for further research. The abstracts for this event are still available online. Just skimming through the titles speaks volumes about the new answers to important questions researchers are now investigating.

So, what does the research tell us about these important questions? A lot more than a blog post can do justice. Next time you find your self asking (or being asked) a question that begins this way, ask what you and your organization are doing to support research, researchers and the sharing of data that will make a difference.

Thursday, May 31, 2012

Do random workplace inspections reduce worker injuries?

Occupational safety and health inspectorates have a challenging task. The number of workplaces far exceeds the capacity of the inspectors to visit each one. Most inspectorates manage the challenge by allocating resources to programmed interventions and responsive work arising because of serious workplace incidents or complaints. Random, unannounced inspections are often used as part of the targeting procedure but do random inspections actually reduce worker injuries?

A new study [ David I. Levine, Micheal W. Toffel, Matthew S. Johnson, “Randomized Government Safety Inspections Reduce Worker Injuries with No Detectable Job Loss, Science, Vol 336, 18 May 2012] using California data provides a well-researched answer. Michael Toffel, an environmental management expert (Harvard Business School), along with economists David Levine (University of California, Berkeley) and Matthew Johnson (Boston University) created 409 matched pairs of inspected and uninspected workplaces from Cal/OSHA data. Sectors were representative of the higher risk industries in the state and include construction ( general building, special trade contractors), wholesale trade (durable and non-durable goods), metal fabrication (doors, car parts, aerospace products), wood and lumber products, transportation and others. Firms included in the study had at least 10 employees and some had more than 500. The researchers looked at the records for up to four years before and after the year of inspection.

Their study found 9% fewer injuries following the inspection and 26% lower injury costs but no negative impacts on economic factors such as employment, total earnings, or company survival. Importantly, the random-inspection effects endured at statistically significant levels even four years after the year of the inspection.

The study certainly supports the idea that random workplace inspections reduce both minor and major injuries to workers and costs for employers without economic harm to the enterprise or reductions in the labour force.

All studies like this have limitations. There may be other factors peculiar to California that come into play in this study. The selected firms were single establishment firms in high-hazard industries in a specific region. The study does not look at the effects a percieved risk of inspection might have on uninspected firms. Random inspections within a targeted high-risk sector—particularly if well publicized and supported with actual inspections—may increase the perception of detection among all participants in the sector. This may increase the incentives towards improved attention to safety and health. Perhaps a future study will examine this.

The alternatives to random inspections in a sector include targeting firms based on injury rates, geography, severe incidents, and complaints. Each of these strategies has its advantages and disadvantages. Well-publicized blitzes announced in advance for regions, specific industries or equipment theoretically have an impact. Targeting firms with high rates of injury also makes sense but it is hard to know the true injury rate for small firms. On the other hand, firms outside the announced blitz domain and those with lower than average reported injuries may perceive a lower risk of detection of regulatory violations and, for a few, lower incentives to achieve and maintain safety and health in the workplace.

This may not be the last word on the issue but this research offers practical information for the consideration of policy makers and inspectorates.

Thursday, May 17, 2012

What’s the connection between complacency and risk?

It was a small thing, something noticed out of the corner of my eye, but the subsequent discussion got me thinking about what was really going on in the workplace and what it says about safety culture.


I was in a workplace the other day and noted the absence of a ground pin on an extension cord. I asked the worker using the cord about it and the worker told me it had been that way for a long time. He hadn’t said anything to anyone about it. His supervisor had used the same cord and did not say or do anything about it. He had not been shocked and his equipment kept working. “So, what’s the problem?” he asked.
The absence of injury is not the same thing as the presence of safety. The extension cord with the missing ground pin is clearly unsafe. It creates a defect in one of the important safeguards, barriers and defences in the workplace that are there to manage the inherent risks. Why didn’t the worker, the supervisor or somebody else do something about it?
On possibility could be intentional neglect. Perhaps the supervisor knows about the safety implications of the missing pin but puts production at a higher priority. There is no excuse for intentionally putting workers at risk. Intentional neglect should be sought out and regulations enforced. Another possibility is ignorance. Perhaps the worker and the supervisor are truly unaware of the risk posed by the missing ground pin. We can do something about unintentional neglect through awareness building, inspection and education. There is a third possibility, one that is more pervasive and, to my way of thinking, more dangerous: complacency.
Maybe, at some point, someone did notice the missing pin and did intend to do something about it. Perhaps they took the extra precaution of making certain only double-insulated equipment was plugged into the cord. Perhaps the cord was reserved for non-polarized, two-pronged plugs—at least until the cord could be repaired. Perhaps, as the days past, using the damaged cord just became a habit—with and without the precautions.

If every time a worker used a defective cord he or she received a mild shock, there would be immediate feedback about the defect. That, of course, would be ludicrous. We are fortunate that most new equipment is designed with redundancies like double insulation to protect workers. Safety, on the other hand, does not provide such immediate and personal feedback. In this case, every time the defective cord was used, the worker was not shocked (no negative feedback) and the equipment worked (positive reinforcement for continuing to use the defective cord).

An extension cord with a missing ground pin left in use and unrepaired may be symptomatic of complacency. If the corporate safety culture is complacent in small things, then how can we expect larger hazards to be recognized and risks controlled?

I recall one safety director encouraging his employees to submit notices to him about hazards they noted. No matter how small, he wanted to know about these hazards— he wanted hundreds every month. Random draws from submissions and regular recognition for submitters provided reinforcement for the program. Most of the notes he received were about small oil spills, broken guards, and unsecured equipment—and the notes usually indicated that the defect had been immediately fixed. The safety director explained the benefits of this approach. Sure, the minor issues are fixed but, more importantly, the approach fought complacency. Workers were attuned to safety and alert to hazards.

To finish off the story, I was back at the worksite the next day. The extension cord was fully repaired with a new, heavy-duty three-pronged plug. It was a small thing: a few dollars for the part, a few minutes for the repair. A small victory in the battle against complacency

Monday, April 30, 2012

What was new at the Saskatchewan Workers’ Comp Institute?

A few weeks ago, I attended a unique event in Regina. Since 1998, Saskatchewan WCB and the Ministry responsible for workplace inspections have been holding an annual Workers’ Comp Institute. The event is open to employers, union reps, safety officers, and human resource professionals - in fact, anyone with an interest workers’ compensation. Over the course of the two-day event, nearly 400 participants learned more about the Saskatchewan workers' compensation system and stakeholder responsibilities in it. Many of the concurrent sessions had basic titles like “Case Management”, “Employer Services (Assessments)”, and “Best Practices (Prevention and RTW)” but the content was of interest to novices to workers’ compensation and to students of workers’ compensation systems like me.

A highlight was the celebration of the “Safe Worker” and “Safe Employer” awards. The luncheon celebrating the nominees attracted media attention and was a fabulous platform for advancing the idea of changing safety culture. In introducing the Safe Employer award nominees, the Deputy Minister spoke about the importance of leadership noting that research shows about 70% of corporate culture is set from the top. Three nominees for employer and worker awards were highlighted in video presentations that showed how individuals and firms can make a difference in making workplaces safe and healthy.

Another highlight was the frank discussion about a new and controversial initiative: summary offense ticketing. The Ministry is seeking an amendment to the Summary Offence Regulations of the province. These regulations allow peace officers in different fields to issue tickets (like traffic tickets for speeding). The amendment would allow occupational safety officers to issue on-the-spot-tickets to employers, supervisors, contractors, owners, and workers for certain prescribed offences. The benefit of this program is the immediacy of issuing a ticket. If you are trying to change behaviour, a summary offense ticket is an immediate tool with far lower administrative costs than prosecutions or many administrative penalty processes. Still to be worked out would be the schedule of offences and the values of associated fines (large enough to be a deterrent without being overly punitive). Consultations are continuing to decide which behaviours should be targeted.

The event was well run and included a range of representatives from all stakeholder groups. In the plenary and concurrent sessions I attended, there was no grandstanding; yet, questions from all stakeholders were welcomed and respectfully addressed.

I’m not certain the Workers’ Comp Institute idea is right for every jurisdiction but it seems to be working well in Saskatchewan. Other jurisdictions may find inspiration from the the approach and the content of this very successful event.

Friday, April 13, 2012

What are the top workers’ comp concerns among employers?

A recent US survey by Zywave (a Milwaukee-based provider of software-as-a-service solutions for the insurance and financial services industries) asked 3,500 employers about their top workers’ compensation concerns.

Cost containment topped the list. Cost containment in workers’ compensation includes actions employers can take to reduce their workers’ compensation costs. In the US, this generally refers to steps that reduce injuries, shift costs to second injury funds (similar to “relief of costs” in WorkSafeBC terms), control medical costs, and return injured workers to employment (shortening duration, and therefore, claim costs).

It is not surprising that 65% of those surveyed identified “having a safety-minded culture” as the most effective measure to control workers’ comp costs. If you have a safety culture, you know it. Developing a safety culture, however, is not that simple. Many firms don’t, and those that want to develop one often don’t know where to begin. Many workers’ compensation insurers have loss prevention and industry consultation services that can help but ultimately, it will be the workers, supervisors, managers and owners of firms that create a safety culture.

Another obvious measure to control costs is having a light-duty or return-to-work program. In this survey, nearly 60% of employers said they had such programs but only 45% of respondents reported having a written return to work policy.

About a third of employers surveyed were concerned about increasing exposures in the workplace and a perceived rise in fraud behaviours. Other top concerns related to the nature of the competitive market for workers’ compensation insurance in the US: renewals (cost and possibility of an insurer declining coverage), market availability of workers’ compensation insurance, and insurance carrier stability.

According to the survey, nearly 90% of employers had no idea what their “loss-free rating” was or were not familiar with the term. Loss-free ratings (sometimes called “minimum mod”) commonly appear on premium statements and relate to the experience modification part of the premium calculation.

The loss-free rating is the value the experience modification (often abbreviated to “experience mod” and expressed as a multiplier of the base premium) would be if there were no losses in the experience period. A firm with an experience mod of 1.10 on a base premium of $100,000 would have a total premium of $110,000. If the loss-free rating were 0.80, the total premium would be $80,000. Knowing the loss-free rating shows the employer, in this example, there was $30,000 of potential premium savings if there had been no losses.

The concept of loss-free rating may be hard to explain in US states but in WorkSafeBC’s case, the loss-free rating would be the maximum discounted premium. Showing the loss-free rating and the potential savings on a statement may well be a great conversation starter for firms with surcharges or demerit experience ratings. While it ignores the human suffering and costs, it does quantify savings available through prevention efforts. Put another way, many firms would find the cost and effort at prevention to achieve those savings far less than the cost and effort to achieve an equivalent profit from gross sales. There are also hidden costs associated with worker injuries that are not reflected in workers’ compensation premiums: lost time and lost experience or knowledge, for example.

With cost containment issues topping the list of US employer workers’ comp concerns, and given the apparent lack of understanding around the loss-free rating, the time is right for worker’ comp insurers to test new ways of communicating the value of investing in loss prevention, return to work and safety culture.

Sunday, March 4, 2012

What does the future hold for loss prevention and OH&S inspectorates?

I’ve been keeping a list of the issues, trends and ideas that will shape the future of prevention and occupational health and safety from the perspective of loss prevention (education, consultation) and compliance (regulation, enforcement). Here are my top 10 items:

1. Harmonization
The mobility of capital, labour and goods will drive harmonization across jurisdictions regardless of constitutional or sovereign boundaries. This does not mean there will be a race to the bottom but it does mean there will be an emergence of a minimum set of standards within nations and among trading partners. The challenge for regulators will be to agree on external or new standards. Watch for the rise of (and battles between) competing cross-jurisdictional standards.

2. Inter-agency “Task-force” models
No structure is ideally suited to address every problem. If we precisely define the problem in real-world terms, we can then design the interventions we need to actually fix them. We will see more inter-agency taskforces, “deputized” officers from one service to work with others, and letters of understanding between agencies in support of common causes (tracking bad actors across jurisdictions, for example).

3. Data-Driven Risk Intelligence
We live in a connected world. First aid records (or OSHA logs in the U.S.), paper claims records, and regulations that require firms to keep records of exposures are obsolete, wasteful, inaccurate and (almost) useless from a loss-prevention or OH&S regulatory program perspective. Data — not the paper or forms that contain them — are what will drive change. I don’t mean tables full of numbers published once a year but instantly available, continuously updated, visualized data with intuitive drill-down capabilities. These will become the standard mechanism for programmed inspections, blitzes, and targeted prevention interventions.

4. Social Media Response
Complaint phone lines are almost obsolete; yet, prevention agencies have failed to enlist the millions of people with smartphones on and near jobsites to detect and correct imminent risks. Agencies are all very quick to have a web presence going out, to tweet newsroom items and to seek Facebook followers. Embracing social media this way has the added benefit of fostering societal change.

5. Information transparency
Ultimately, it is information in the hands of consumers, workers and investors that will drive change. The Alberta Ministry of Human Services already allows anyone to search a firm's injury rate, fatality count, injury cost, and Certificate of Recognition status, among other things. The U.S. Department of Labor Occupational Safety & Health Administration provides online access to enforcement inspection reports. Workers, shareholders, business partners and others are going to demand this information. Information has the power to shape reputation, and reputation matters. Transparency will drive better safety and health performance. Transparency will detect discrepancies and injury-reporting/claim suppression. More importantly, it will allow for the creation of new approaches to safety and health that we have not yet conceived.

6. Technology-enabled monitoring
For years, safety regulators and insurers have declined receiving copies of documents such as safety minutes, First Aid ledgers, OSHA 300 logs, and exposure records required by regulation. Regulators struggle with the question of what to do with such data. Smart systems change all that. All safety committee minutes can be received and analysed by intelligent software; all OSHA 300 logs (not just a sample) can be retrieved and the sampling error eliminated to reveal new trends; and exposure records can be used for epidemiological “surveillance” particularly for long-latency occupational diseases. Technology-enabled monitoring has the power to protect people.

7. Safety-culture detection
You can’t fake your safety culture. If you have a good one, the safety rules are almost redundant. If you have a bad one, safety rules don’t matter. Yes, promoting and studying safety culture have been around for years. Detecting safety culture in the dozen or so questions inspectors, loss prevention officers, managers or workers can ask will diagnose the state of a safety culture quickly.

8. There’s an app for that!
Black box monitoring in transport vehicles, forklifts, cranes; “setting memories” cached on processing equipment; personal monitors for sound, motion, stress, toxins; worksite cameras capable of recreating three-dimensional scenes; “augmented reality” and “vertuality” capable of overlaying blue prints, floor plans, wiring and systems on camera images from any perspective in real time . . . there will be (and in some cases, there already is) an app for that. Best practice will make such apps common. And some insurers will offer discounts to employers with them in place.

9. Technology-enabled causation tree analysis
Software and intelligent systems will increasingly be used to establish exactly how safeguards, barriers and defences all failed to protect workers from injury. The antecedents that create active and passive defects allowing the inherent risk to harm injured workers will be actively mapped and the information used for prevention (and potentially third-party liability). Technology will enable (insurers will expect, regulators will demand) shorter periods to complete such analysis.

10. Tele-inspection
Insurers for underwriting and loss prevention purposes and OH&S inspectorates for compliance and enforcement purposes will use technology to do inspections at a distance. More worksites will be “visited”, more lives saved by adding this technology to the repertoire. Whether via remote connection or by use of a proxy (via the on-site safety manager with a helmet-mounted camera), inspections with corrective orders, penalties and even stop-work orders will be issued based on this sort on tele-inspection.

That’s the top of my list.

What do you think? What’s on your list?