The Overall Benchmark for Safety Performance: Keeping People Safe
Since the creation of OSHA in 1970, the agency has played a crucial role in improving safety in U.S. workplaces. For example, OSHA has estimated that the number of worker deaths are on average down from 38 worker deaths a day in 1970 to 15 a day in 2022.
Unfortunately, this estimate is also a grim reminder that much progress is still needed. Despite having a system of standards and enforcement, 15 people die each day just striving to earn a living. Therefore, the question should not be solely compliance-centric such as, “Do we meet OSHA requirements?” The question employers should be asking is, “Are we keeping people safe?”
Years ago, I was hired to drive around Florida doing safety audits to assist a company in their response to recent OSHA violations. One interviewee shared their definition of an auditor as someone who “…after the war is lost, rushes in and bayonets the wounded.” Well, they deserved credit for making improvements, albeit spurred on by an enforcement stick.
I have always felt fondness for organizations that are committed to compliance with safety regulations. Navigating the numerous requirements applicable to specific hazards requires significant time and resources, and that’s just to get started. Once a company deciphers what it is supposed to do, it is then obligated to follow through, continuously implementing and adapting safety measures as circumstances, hazards, and regulations change.
These are noble efforts. But 15 fatalities a day? This proves that sometimes OSHA compliance is simply not enough. Let’s consider some reasons why.
First, OSHA does not regulate all hazards, even critical sources of injuries such as poor ergonomics, which is one of the most frequent causes of injuries. For these “unregulated” hazards, enforcement relies on the "General Duty Clause" of the OSHA law that requires employers to provide a work environment free from recognized hazards that are causing or are likely to cause death or serious physical harm. Determining what specific safety performance standard applies without a regulation defining it can be challenging.
Even where regulations exist, some are woefully outdated for ensuring worker health. Most notably, many of the permissible exposure limits (PELs) which set limits on air contaminants were adopted around 1970 and do not align with current scientific advancements. Even OSHA acknowledges this issue. Furthermore, limited resources make it challenging for OSHA to hold all eight million businesses accountable. If someone isn’t seriously injured, or no one files a complaint, OSHA might never darken an employer's doorstep.
Perhaps it’s time for many employers to become “unhinged”—as in, detached from the idea that once OSHA compliance is achieved it’s time to relax. Setting sights beyond compliance might just save a life.
What does “beyond compliance” look like? Active involvement of top management, demonstrating a genuine concern for safety. Employee engagement and self-accountability. Setting safety goals and metrics to monitor ongoing safety improvements. Recognizing and celebrating safety success. These types of actions are hard to find in the regulations, but they’re just as important—some might say more important—than satisfying a compliance checklist. Safety tends to work best when it transcends the mind and enters the heart. It’s been said, "Paper doesn't save people, people save people." Safety works when caring people are driving it. When a good safety culture is in place, then the standards a company sets for itself ensures they return safety to their loved ones.
