What's the best way to achieve and maintain a low total recordable incident rate (TRIR)? The obvious answer is by preventing work-related injuries and illnesses from happening at all. But despite a contractor's best efforts to instill a heightened awareness among its workers, incidents still occur.
The effect that an incident can have on a contractor's TRIR can loom large, particularly in a competitive environment where safety program effectiveness can make or break a firm's candidacy for new project opportunities. The advantages a contractor can offer—price, quality, availability—can be undercut by a TRIR that owners or construction managers deem too high for comfort.
Some contractors have attempted to artificially lower their TRIRs by unethical means—deliberately misclassifying incidents or simply not recording them at all.
"Because recordables are specifically defined by law, a contractor is obligated to report them," says Teresa Magnus, principal of the Birmingham, Ala.-based construction advisory firm Magnus & Co. A far better—and legal—approach, she says, is injury management, a strategy that avoids turning incidents into recordables wherever possible without compromising care for the affected workers. Magnus says applying a sound injury management approach to recordables is not unlike paying taxes. "Avoidance is permissible as long as it's done legally," she says. "Evasion is not."
For example, a jobsite injury is not considered "recordable" if it can be treated with first aid. Cleaning a skin wound like a minor cut or abrasion and covering it with a bandage may be enough to allow the employee to safely return to work. Similarly, heat or cold therapy and massage can prevent a muscle injury from worsening.
In such cases, the contractor has no regulatory obligation to add the incident to its recordables.
As with other elements of a safety program, preparation is essential to injury management. That includes identifying where injured workers should be taken for treatment. Because most hospital emergency rooms don't treat injuries with first aid, Magnus recommends establishing relationships with physicians and 24-hour industrial hygiene (IH) clinics well versed in OSHA rules and definitions.
"An emergency room will almost always treat certain eye injuries with tweezers, making them recordable," Magnus says. "An informed doctor or clinic will understand that flushing the eye may be just as effective."
Magnus adds that IH clinics and physicians are usually easily found in industrial areas, though referrals from owners and other contractors may be helpful. In areas with less construction activity, the firm's safety director may need to contact the facilities directly and interview their physicians.
Another potentially cost-effective injury management tactic, particularly at more remote jobsites, is for the contractor to establish its own nursing station staffed with people trained in first aid.
"It's also a good idea to hire site safety supervisors who are former military medics," Magnus adds. "They're experienced in treating injuries with first aid in the field and getting the employee back to work. And it's a good opportunity to hire veterans as well."
As with every other aspect of safety, good communication is critical to injury management. Magnus says every person in the company needs to be trained on the appropriate chain of command for safety incidents.
"Every incident has to be reported to the project supervisors and company safety leadership whether or not it turns out to be recordable," she says.
Similarly, the contractor's safety director must retain control of the treatment by staying in touch with the employee to ensure that injury management treatment has been successful.
"Once the employee leaves the site, the safety professional should check in with the individual to ensure that his or her condition is improving," Magnus says. "If the condition worsens, and the employee wants to seek additional care, the safety professional must remain involved to manage the care."
In addition, the employee should have a good contact number for the safety professional, who should be on call 24 hours a day.
"If the employee seeks treatment after hours, first aid should still be the first course of action," Magnus says. "Should more extensive care be required, the incident could eventually become recordable."
Magnus also notes that any subcontractor can make injury management part of its safety program, even on projects where owner- or contractor-controlled insurance is involved.