Classifications of Workplace Injuries – Why are we Deluding Ourselves?
By Goran Prvulovic, MOccHlth&Saf, CPMSIA, RSP (Aust.)
“The human brain is a complex organ with the wonderful power of enabling man to find reasons for continuing to believe whatever it is that he wants to believe.”―(Voltaire)
Disclaimer
The views expressed in this paper are the authors’ alone and do not reflect any formal opinion of the authors’ current or former employers or any other party. They are provided for the purpose of general discussion. Before relying on the material in this paper, readers should carefully make their own assessment and check with other sources as to its accuracy, currency, completeness and relevance for their purpose.
Introduction
Recording and classification of workplace injuries in Australia has historically been unregulated and lacking in guidance for employers. Apart from severe injuries specifically mandated by the regulatory authorities and associated standards, little information exist to assist employers with appropriate recording of injuries, especially in the selection of lagging performance indicators associated with injury frequency rates other than lost time . This creates an existence of practices and behaviours aimed at undermining severity of injuries resulting in a loss of opportunities for improvements in overall organisational safety performance. In some cases, these practices can also create further damage to injured persons and as a result increase adverse legal exposure for the senior decision makers.
Even when recorded accurately, injury frequency rates have very limited value as a lag performance indicator. Although widely acknowledged as a better lag indicator, accumulated financial losses arising from workplace injuries are still sparsely used by many organisations.
Workplace injury recording, questionable classification practices, misguided perceptions and perceived benefits as well as more appropriate choices of safety performance lag indicators are not extensively covered in Australian literature. The importance of those subjects to safety culture and performance deserve further discussion and evaluation.
Recordable Injuries and Injury Classification
Despite all efforts and progress made in Occupational Health and safety, disabling workplace injuries continue to occur. On top of the 186 workplace fatalities in 2013 alone, many Australians sustained injuries which resulted in a complete absence from the workplace or restrictions in hours or duties. Just in 2011-2012, a total of 128,050 cases of injuries occurred in Australia, resulting in a temporary or permanent incapacity to perform work of one week or more (Safe Work Australia, 2013). Those are only injuries which are deemed to be reportable or notifiable by each regulatory jurisdiction. Their timely reporting is mandatory and required by legislation. In addition, there are other groups of injuries which are often left unreported, undermined and relatively unrecognised by organisations and regulators.
· Medically treated injuries (MTI’s) which require medical treatment beyond the first aid capability or authority of an industrial paramedic and;
· Restricted work injuries (RWI) which are injuries resulting in some restrictions of duty or work hours lasting less than one week.
Neither of these non-reportable categories are properly and uniformly recorded or used at the national level for setting any meaningful reporting standards, targets and requirements for employers. They are seldom used for driving any national injury prevention initiatives or strategies unless the injury actually results in a workers compensation claim. Large numbers of those injuries are associated with a potential for more significant outcome and an increased focus in this area would represent a more proactive, upstream approach in measuring safety performance. Instead, most Australian regulatory jurisdictions focus primarily on lost time injuries (LTI’s), fatalities and data from known and reported injury compensations claims. On the other hand, most organisations do use MTI’s and RWI as part of their overall lagging safety performance indicators. When reported and correctly classified, they form part of the Total Recordable Injury Frequency Rates (TRIFR) which is often used as a primary, and sadly in some cases, the only organisational lag indicator of safety performance.
To a large extent, employers in Australia are left to define their own methods of measuring their safety performance and associated leading and lagging performance indicators. Lagging indicators have traditionally been heavily based on personal injuries and their frequency rates. In terms of those, most organisations use combination of LTIFR, TRIFR or in some cases All Injury Frequency Rates (AIFR). In most cases the primary measure is LTIFR, which draws most attention by senior decision makers and is usually a mandatory reporting element going to boards of company directors. TRIFR and AIFR are also sometimes used at the board level as a secondary performance lag indicator, although to a far lesser extent. In any case, the concept is to implement organisational systems able to record personal injuries, track their trends and use this data as part of the overall organisational proactive strategies in injury prevention. That is the theory; however the practice is often different.
Once an injury occurs in the workplace and an initial medical care is administered to the injured employee, two distinct processes usually occur almost simultaneously, an accident investigation process and the injury management process. Whilst the accident investigation process concerns itself with causation factors involved in an event and the identification of controls for further prevention, the injury management and rehabilitation process focuses on providing the best possible early care to injured employees, their rehabilitation and reintegration into the workforce as soon as practically possible.
In larger organisations, almost immediately following the injury, another interesting sub process occurs which often captures the immediate attention of senior managers on various levels. This is a process of injury classification. For those who work as Occupational Health and Safety (OHS) professionals as well as various functional managers, classifying workplace injuries is often very stressful and frustrating experience. Usual group dynamic rapidly changes and the process raises many difficult questions such as:
- Was the particular injury medically treated or just a simple first aid?
- Is it work related or not?
- What does OSHA guideline and Australian standard say and how do they compare?
- Is it a lost time injury or a restricted work case?
- Was a time lost from a rostered shift or not?
- Is the mechanism of injury consistent with the outcome and did the workplace task contribute to injury?
- Etc.
The questions seem endless. Most organisations have internal procedures and guidelines to assist the facilitation of this process as it is seen as a very important factor impacting organisational statistics and creating lot of attention and scrutiny. Organisational efforts in classifying an injury can often be equal to one applied to investigation or the rehabilitation processes. In some organisations, resolution of the issues involved in the injury classification process often take days to finalise and this involves meetings between heads of various departments, checking of available guidelines, discussions, follow up appointments and medical re examination of the employee. Alternative medical opinions are often sought as are internal and external precedents in an attempt to reduce severity of the injury, its classification and ultimately avoid and silence ‘negative’ feedback from a system, which is designed to provide precisely such feedback and prompt attention and corrective actions.
This can be compared to an alarm in the control room of a chemical plant indicating severe process deviations. Would we simply silence the alarm, fail to communicate it to anyone and make no record of it? Certainly not, as this can obviously have serious consequences yet this is precisely the mechanics involved in undermining and manipulating classification of workplace injuries. The real danger of silencing the warning system in this way is that when we prevent it from operating as intended, we enact organisational culture which knows far less of itself than is necessary to ensure effective management of risks, success, and organisational survival.
Time and energy spent on the classification process is often staggering and the ‘creativity’ involved nothing short of ingenious. This is ironic as in many cases this process ends up being nothing more than an attempt to exert the desired results by manipulating critical information. Despite their differences and motivation behind them, all of those processes are essentially counterproductive and highly damaging for the organisation. What is really surprising is that despite their obvious negative effects, they are still being widely practiced across a variety of industries. This raises two critical questions. Do we have an issue with manager’s knowledge and abilities to recognise damages created by those practices or do we have intentional actions as some kind of compromise between priorities? It seems likely to be a combination of both.
Manipulative Practices
The methods used to distort the warning system are many. It is not uncommon in some organisations to have a practice where someone delivers a couple of procedures to an injured person’s home and consider this as an active duty therefore eliminating a need to classify such injury as a lost time. In many cases an employee is brought back to work with little if any capacity to perform any duties and this is done for no meaningful reason other than to prevent a recordable injury, especially where there is a long standing LTI record at stake or a department bonus involved.
Obtaining an alternative medical opinion known as ‘doctor shopping’ is another popular strategy. In some cases, returns to work programs are developed and utilised contrary to medical certificates. This can prolong recovery of the injured person and delay rehabilitation to pre-existing duties. Some organisations have taken a completely different angle to recordable injuries and have simply opted to discard whole categories of recordable injuries such as RWI’s. This practice ensures that only those restricted work cases which have resulted in administration of specific medical interventions get accepted as recordable, thus driving a range of personal injuries resulting in restricted duties out of TRIF calculation. Medically treated injures are treated in a similar fashion.
Of particular concern are some practices involving actual delays of proper medical assessments and treatments. This is done in an apparent attempt to ‘manage’ injuries in house and reduce or avoid the risk of receiving first medical certificates with partial or full disability. Admittedly, in some cases there is simply no need for a person to be assessed by a general practitioner as the injury is well within the scope of local paramedics. The real issue is with cases which do require proper medical examination and where this is denied or delayed due to internal written or unwritten expectations and protocols. In other words, pressures are applied to site based treating health professionals and in some cases this is a clear management expectation and unwritten, but accepted, way of managing recordable injuries. The ethical norm of ‘erring on the side of caution’ which is so deeply entrenched in all health professionals through their training is compromised which causes extreme discomfort, dissatisfaction and stress through cognitive dissonance in the workplace.
There are cases where a general practitioner is consulted over the phone but the action taken is not always in line with the advice received. This is a quite unique situation in the medical arena where a nurse or a paramedic is actively encouraged by non-medical personnel to act contrary to the advice received by a medical person of higher training and qualifications. Much can be said about the ethical dilemmas, legal ramifications and potential of further harm to the injured person. It may be difficult to believe however, sadly, this does occur.
In some organisations, cases of occupational illnesses resulting in restricted duties are simply excluded from the overall organisational TRIFR which drives this number down considerably giving the illusion of better performance. As true organisational safety culture, practices and performance remain unchanged, the incidents and injuries continue to raise overall TRIFR, which creates a need for other strategies, similar in nature which further degrades the safety performance and opportunities for improvement.
When this happens, an injury recording and classification system becomes nothing more than a vehicle for distortion of statistical data causing significant organisational damage. Once the lines become blurred and precedence is set, the rest is, in the main, a process of desensitisation and normalisation of these practices. This is the true meaning of using the term culture as being ‘the way we do things around here’, a solid set of practices rather than collective set of beliefs and values advertised and publicly professed from the senior levels. Manipulations of injury statistics are a symptom of a cultural problem rather than a cause. They are indicative of deep underlying issues based around decision making processes, organisational priorities and what is really considered and projected as important from the most senior organisational levels.
Over Focus on TRIFR
It is interesting to note practices in some organisations around the promotion of senior personnel based on a TRIFR as a key performance indicator. The impact these promotion practices have on an open and honest information flow to the top decision makers cannot be underestimated. People can be the greatest barrier to effective communications, especially when their key interests are at stake. Another important factor involved in the incorrect classification of recordable injuries is a state of silent acknowledgement, which is present in some organisations. This is a conscious acceptance of the failure to manage risks to the advertised acceptable levels combined with a strong need to stay competitive and compare favourably to other organisations. This acceptance is often unspoken and even denied, yet easily observable through actions of individuals and organisational practices.
The limited importance, intention and purpose of TRIFR as one of the key lag performance indicators used in measuring overall organisational safety performance is generally well known. It is simply a measure of harm (above a defined point) to employees as a result of various organisational system failures. It is a reactive measure, not predictive of the future performance and with limited ability to provide specifics in terms of system failures and issues. It is really one of the last alarms for the organisation indicating occasions, where all control has been lost and, there is a need for evaluation and change of the applied risk controls.
One of the most damaging effects of this behaviour is a simple chain reaction. As the severity of injuries is undermined, the need for a comprehensive root causes analysis investigation is often driven down; the underlying causes are not uncovered and addressed appropriately. The issues now lay dormant, waiting to combine with other workplace factors and surface again, often with unpredictable consequences far more severe than an original injury itself.
Where TRIFR becomes important is in consideration of the overall strategic business planning and resourcing for safety. In absence of better measures, it becomes a focal point of attention for senior decision makers and one of the key factors potentially influencing the allocation of funds towards health and safety strategies.
TRIFR and LTIFR have been with us for a long time. The practices discussed in this article do not suggest lack of understanding on what those statistical measures are meant to achieve, rather they represent a set of intentional, although impulsive, actions aimed at avoidance of negative perceptions and creating an illusion of better performance.
In a way, the whole problem with injury statistics and recording starts with the fundamental misunderstanding of how safety works as an integral part of the successful execution of work. When risk management controls are working and the work is getting executed safely, nothing happens. Safety state is largely unnoticed unless we are tuned in, aware of how it works and are looking and listening. This absence of negative events is a ‘safe state’; however absence of something does not usually attract much attention to itself. This means that when everything goes well, the minds of people are focused on something else more pressing at the time. On the other side of that, an adverse event is visible. It has an outcome, captures everyone’s attention and has a much stronger emotional impact than a safe state.
This is simply the way humans are wired, hence the everlasting tendency to predominantly focus on reactive performance indicators when it comes to safety. As companies are run by humans this tangible versus intangible effect creates a tendency to focus on, and record negative events, grade them by severity and evaluate them over time. As negative events draw negative emotions, when combined with scrutiny and conflicting messages it is not difficult to see how adverse recording practices are born.
As ‘safe state’ is not so attention grabbing, its recording is difficult to measure for some organisations and tends to fall by the wayside. To measure a ‘safe state’ some organisations use matrix style tools to track ‘safe days’ focus mostly on a range of proactive lead indicators and use reactive indicators only as alarms and indicators of failure and loss of control. More advanced organisations go further. They lean towards recordable injury when in doubt, pay special attention to ensure accurate recording injuries and track their trends over a long period of time. Such organisations spend lots of time and effort carefully studying each recordable injury and causative processes. They map similarities between those occurrences and seek common denominators specifically in work practices, systems and processes and human performance. These are just some of the methods effective organisations use to guard and defend against the fatalities and other catastrophic events.
On the balance of probabilities, it is likely that the fatal accidents some organisations have experienced have not only been preventable but have probably had preceding specific warning events with causative factors which have not been adequately addressed. One has to wonder to what extent practices examined in this paper are directly involved in the mechanics of these events. It is plausible that there is some relationship. Alongside reluctance to measure process and hardware failures, this would explain to some extent a very low TRIFR some organisations had at the time they experienced catastrophic events,. This is not to be confused as a confirmation of accuracy of an old accident triangle model. Although the mechanics of events which are causing fatalities in organisations can be, and often are very different of those causing incidents and injuries of lesser severity, inappropriate classification practices can be one of the key ingredients. They suppress the existence of and subsequent correction of systemic issues and combine with other factors in the causation of fatalities in the workplaces.
Common Reasons for Inappropriate Injury Classifications
From an analytical perspective, inappropriate practices involved in classification of recordable injuries raise an interesting set of questions which need to be answered.
What makes safety different from other business processes? How can any organisation see the benefits in managing the outcomes rather than working proactively, minimising harm and losses and achieving increasing reliability and effectiveness trough sound risk management principles? What are the deep underlying root causes of such organisational behaviours and what is so powerful that drives people towards creating a culture of self-delusion which can potentially lead to disastrous consequences?
Firstly, businesses have a clear need to compare themselves favourably against the competition and other industries. For some, this is a matter of prestige however for others this can be a critical business need, even survival. In today’s competitive world, contracts are won or lost on safety performance and this in itself can be a very powerful motivator towards undermining severity and work relatedness of injuries. In some organisations inappropriate classification practices occur with a clear intent to embellish their safety performance.
Businesses are not run by risk management or OHS professionals. They are mostly run by professionals who come from technical and production orientated backgrounds such as engineers, metallurgists, geologists and accountants. Those professions are mostly based and governed by numbers, especially in planning and tracking of performance. This consequentially drives a need to quantify safety performance in numbers in line with all other business functions, hence the tendency to measure failures in the form of recordable injuries. Of course, safety is not a number driven function and its true performance cannot be tracked fully by numbers however it remains the main approach for many organisations. Regardless of its shortcomings, TRIFR is a major factor in competing for contracts and winning new business which can drive specific organisational behaviours focused on improving their TRIFR. Apart from the genuine effort to improve safety performance, this can also result in a specific set of messages and interpretations of priorities being passed down the stratum levels resulting in inappropriate classifications of workplace injuries.
When it comes to recordable injuries and safety performance, starting point for most businesses is firmly on a solid ethical ground with high aspirations and high moral intent. Over time, many businesses find it difficult to provide adequate resources for safety and often spend available resources on strategies which are not sound or suitable for their organisation. As they struggle to achieve genuine excellence in safety with little improvements they begin to form a general acceptance of their safety performance as a normal state of affairs. As they are judged by recordable injuries, which can carry a financial impact and a legitimate good performance is hard to achieve, a specific perception emerges in minds of some people. Two business goals can be seen to be non-compatible. The scale is tipped in favour of what is perceived as the ‘large business picture’ which drives inappropriate classifications of recordable injuries. This is one of the main reasons why those occur in some organisations with silent acknowledgement from senior decision makers. The fact that such practices are so widespread helps decision makers in justifying their decisions by providing an emotional justification for the actions taken.
Large organisation really need to self reflect on this subject. Just like with many other systems and processes, being a leader and an employer for many contractor organisations sets standards, expectations and best practices. It is a simple mechanism. On the individual business unit level, the most senior decision maker in the company sets the tone of what is important in his department by his practices and behaviours which in turn drives behaviours and practices of his reports who cascade this down the organisations stratum, effectively creating specific expectations and practices. This is a true description of the organisational culture. This same mechanics applies further upstream and it exist on regulator – industry level but also on organisational – contractor level. The behaviour of the client heavily influences behaviour of contractor firms. Many contractors including some large organisations set their management systems to suit their large clients and often default to client practices in injury classification, even if these are not aligned with their own injury classification system, values or beliefs. They do this in an effort to minimise the impact on client TRIFR, maintain their relations with the client and continuity of work. Even if a deviation from the established systems is not approved or condoned by contractor’s corporate structures, the site management often confirms with the client classification practices and creates a different, ‘under the radar’ sub process.
Another important enabling factor for questionable and inconsistent classification practices is a clear lack of accurate guidelines on injury classification in Australia. If the clear process was in place with specific descriptions and classifications, most organisations would be under pressure to classify their injuries accurately and have good performance indicators in place. The reality is that just like in some other health and safety areas, industries are left to their own devices. They are expected to self-regulate and self-measure in this area. Due to almost complete absence of a process and a target set by government authorities, it is not surprising to see poor measures and inappropriate practices.
As organisations tend to use recordable injuries as their overall performance indicator, they also use them to measure performance of their middle and senior management. This creates an interesting organisational dynamic, especially at senior management levels in some large organisations. In author experience, of particular interest are behaviours associated with competitive processes where two or more senior managers are competing for promotion and where recordable injuries frequency rate plays an important part as a key performance indicator. Competing managers often apply microscopic attention to each recordable injury in their respective domain. They apply severe scrutiny, pressure and demand from their direct reports detailed and in some cases very extensive justifications for any injury being considered as recordable. These sometimes aggressive and suggestive approaches have a profound impact on their direct reports, in terms of setting the priorities and passing a clear message of what is really important to manager.
The opinion of most people is that pleasing the boss is a smart thing to do, and this is a significant driver of human behaviour in the workplace. This effect flows downwards to a next level, and the next one down, further amplifying residual effects of the message. As a result, collective response from direct reports is a reluctance to ensure accuracy of recordable injury data and deliver bad news as this can be career damaging. This is a classic case of failure on behalf of senior leadership to set the expectations in the organisation. Organisational culture starts at the most senior level. The behaviours and practices condoned by the senior leadership team drive behaviours and practices through all levels of the organisation, effectively creating a specific organisational identity.
Is There a Better Way?
A lot can be at stake for managers, not only a potential promotion but also an annual bonus, pay rise and company shares. In some cases survival in the organisation is a primary goal. However if we look at the problem from the standpoint of some senior managers, it is far easier and faster for someone to ‘tweak’ a figure than to seriously engage and apply efforts in management of health and safety. If this kind of practice was to be done with some other organisational process, other indicators would be able to show the anomaly and it would not be tolerated. With recordable injuries there is usually not much in place to provide secondary checks of data accuracy, there are rarely any redundancies in the system, although it’s worth noting that some organisations have specific auditing processes in this area.
Most organisations have dedicated budgets for some injury related costs; however they do not usually have detailed systems for tracking specific business losses specifically associated with the occurrence of recordable injuries. It is unfortunate that the monetary costs of injuries is treated this way as it is a much better reactive safety performance indicator than any recordable injury frequency or duration rates currently used in the industries. Injury management and rehabilitation costs including various secondary losses such as time lost managing the injury, time off work for injured employee, retraining, replacement of injured personnel and other similar factors are far more capable of defining true impacts of workplace injuries on the organisational performance and profitability. Any costs associated with injuries are losses straight of the bottom line yet there is still lot reluctance to use it as a lag indicator. Maybe this is the case of decision makers simply being afraid of what they may find out, or perhaps it is just a case of ignorance on behalf of some advisors.
Worker compensation insurance is mandatory in all Australian jurisdictions and it is seen by most businesses as unavoidable operating cost. Although conceptually everyone will agree that this cost can and should be driven down, in practice this cost tends to be accepted and many opportunities to reduce it are left unexplored. Unless there is a drastic increase in these costs and premiums, these costs are simply normalised. There are many reasons for this, including previously mentioned human tendency to focus on tangible and certain and ignore intangible and uncertain. This is why many decision makers find it difficult to commit resources in the upstream injury prevention strategies, even when all evidence points towards much more costly consequences if resources are not directed at the problem proactively. As per the old saying, there is never enough money or time available to do it right but enough time and money to do it again.
There are simple and more effective strategies which can be implemented to better measure business losses arising from injuries. They are systems aimed at measuring hidden costs associated with workplace injuries. Most financial mechanisms needed for effective implementation are often present and operating as part of the organisational systems. The new, additional measure could simply be called Injury Cost Index (ICI) and could include inputs such as:
- Individual break down of the injury costs (injury management and rehabilitation, insurance premiums)
- Labour replacement costs
- Injury Management and, investigation costs
- Administration costs
- Training and overtime
- Loss of productivity (interrupted schedules) and many others
Quantifying, collation and reporting of these inputs may not be an easy task and it may require careful selection of automated systems, training and procedures; however any expenses incurred will most likely be far superseded by potential benefits.
Conclusion
The reality is that good safety performance and reliability is very difficult to achieve and sustain. It requires constant attention to something which is largely intangible.
Proper resourcing, mature systems, well developed operational discipline and above all else an organisational commitment and appetite to succeed are paramount. Successful management of health and safety requires substantial organisational effort as a whole. Understanding of how safety works is paramount as is respect for monitoring and preventative systems and correct risk management advice, which is not always available. Above all, just like in any other operational setting and environment, if the operational discipline and organisational culture is not in place to prevent silencing of critical warning systems, no strategy will ever truly work. This will continue to create culture of mistrust, injury related business losses which are relatively easily preventable and will enable existence and tolerance of systemic conditions capable of creating significant personal and organisational damage.
We have ability to change inappropriate injury classifications by examining our own behaviours and changing the key underpinning factors involved in creation of such practices. The change is within our power and sphere of influence, we just need to change our thinking and reach within ourselves. The answers are there.
References
Australia, S. W. (2013). Worker Fatalities Retrieved 27/07/2014, 2014, from http://www.safeworkaustralia.gov.au/sites/swa/statistics/work-related-fatalities/pages/worker-fatalities;http://www.safeworkaustralia.gov.au/sites/SWA/Statistics/Documents/2011-12-time-series-incidence-rates.pdf
Voltaire. Voltaire (François-Marie Arouet), 1694 – 1778 Retrieved 27/07/2014, 2014, from http://www.qotd.org/search/search.html?aid=2238&page=14
OSHA, OSHA (2005) Record Keeping Handbook, US Department of Labour Retrieved 27/01/2015 from https://www.osha.gov/Publications/recordkeeping/OSHA_3245_REVISED.pdf
Worksafe Australia (1990) workplace Injury and Disease Recording Standard Retrieved 20/01/2015 from http://www.safeworkaustralia.gov.au/sites/swa/about/publications/ Documents/264/WorkplaceInjury_Disease RecordingStandard_Workplace_1990_PDF.pdf
ABOUT THE AUTHOR
Goran is a HSE Professional from Western Australia with multi industry experience, currently operating in the power generation industry as a Regional HSE Manager.
His career in the Western Australian mining industry began in 1989 where Goran performed a multitude of operational and leadership roles, culminating in a full time engagement as a safety professional in 2005. Goran’s specialties include Safety Culture, Leadership and Operational Discipline interventions and catastrophic risk profiling and management.
Goran holds a Master’s Degree in OHS from Edith Cowen University in Western Australia. He also holds a number of vocational educational accreditations and is currently undertaking further studies in the area of Management and Leadership.
Goran has held a number of senior HSE management positions in Western Australian Mining where he has managed multidisciplinary teams as well as lead and assisted in development and implementation of HSE management systems. He also developed a number programs aimed at leadership development, improvement of safety culture and operational discipline in several organisations.
He is currently developing his consultancy business focused on safety leadership and upskilling of front line leadership in OHS. He enjoys development and execution of training as well as occasional writing. He lives with his wife and children in Perth, Western Australia and enjoys bushwalking.
Contact Goran: majaci@bigpond.com
Goran Prvulovic
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