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Unlocking the power of OSHA records
By Randy Boss, CRM, MWCA, SHRM-SCP


Effective January 1, 2024, OSHA's new and expanded electronic recordkeeping rule will undoubtedly subject employers to more inspections, regulatory scrutiny, and increased enforcement citations as well as public exposure. Leveraging AI, OSHA can efficiently analyze volumes of data to identify trends and detect deficiencies in specific companies and industries far more effectively than an individual compliance officer during a single inspection.

As employers undertake the daunting task of ensuring the unerring accuracy of their OSHA recordkeeping forms to comply with the new rule, there is an opportunity to use the process to craft a more targeted approach to identify and address specific hazards in the workplace. Not only will this enhance worker safety, prioritize employee well-being, and lower insurance costs, but it will allow time to undertake corrective action before OSHA reviews the data, reducing the possibility of citations.

Here are ten steps employers can take to leverage the power of OSHA records:


Thoroughly analyzing OSHA records. Doing this is crucial to uncover patterns, trends, and recurring incidents. It's the "canary in the coal mine" warning of trouble or danger. By carefully reviewing these records, organizations can identify common root causes and areas of concern, providing a foundation for effective safety improvements.

I was working with an employer whose employees experienced several cut fingers from box cutters, the worst being cut tendons that resulted in several thousand dollars in medical costs and lost time. To reduce these types of injuries, we instituted the use of a safety box cutter that protects the employee from an exposed blade and eliminates this hazard. The result was no more cuts, fewer OSHA infractions, and a lower experience modification rating (EMR), leading to lower workers comp costs.


Identifying high-risk areas. The insights gained from OSHA records help organizations identify high-risk areas, tasks, and establishments that require immediate attention. Focusing on these areas through targeted safety measures allows for proactive risk mitigation and accident prevention.

One of these high-risk areas is falls related to working at great heights, particularly in construction. A sprained ankle with a couple of thousand dollars in medical bills and a few days off after falling 10 feet without fall protection indicates that something more serious, like a lifetime in a wheelchair or death, could be next.


Developing preventive measures. Utilizing OSHA records to do this may involve updating safety protocols, providing additional training, improving equipment or processes, and enhancing safety signage or warnings. By addressing potential hazards proactively, organizations can significantly reduce the risk of incidents.

Working with a manufacturer, we noticed several eye injuries resulting from using a grinding wheel. Although employees used safety glasses, metal debris still got in their eyes. A change to better-fitting eye protection eliminated these eye injuries.


Training and education. Reviewing OSHA records can serve as a valuable tool for identifying areas where additional training or education is needed. Develop comprehensive training programs that address these areas, thus ensuring that employees have the necessary knowledge and skills to perform their tasks safely.

While reviewing the OSHA records of an employer, we discovered several back injuries due to improper lifting techniques. We added training on how to lift correctly, which significantly reduced back injuries and improved overall productivity by keeping employees on the job where they are needed. The employer valued this because it's been challenging to find qualified employees.


Fostering a safety culture. Encourage open communication, promote the reporting of near misses or safety concerns, and actively involve employees in safety initiatives. By creating a shared responsibility for workplace safety, organizations empower employees to actively maintain a safe work environment.

It's been my experience that getting employees to report near misses and close calls consistently is challenging. H.W. Heinrich developed Heinrich's Accident Triangle Theory in the early 1930s. He suggested that 88% of all accidents happen due to human decisions to carry out an unsafe act.

Frank E. Bird developed the theory further in 1996 by analyzing 1.7 million accident reports from about 300 companies. He came up with an amended triangle, which showed a relationship between one serious injury accident and 10 minor injury accidents. It further showed 30 damage-causing accidents to 600 accidents as near misses.

According to this theory, every OSHA recordable had several near misses. When an employer has recordable injuries but no reported close calls or near misses, employers need to improve "near miss" and "close call" reporting.


Regular safety audits. These and inspections are essential in assessing compliance with safety protocols and identifying any gaps or potential hazards. Use the insights gained from OSHA records to guide the audit process and prioritize areas for evaluation. Implement corrective actions based on the findings to improve safety standards continually. According to the National Safety Council, a regular safety audit objectively reviews a company's policies, practices, and operations regarding regulatory compliance.

While doing a safety audit at a construction site recently, we noticed a cement rebar without safety caps. A simple fall to the same level could lead to impalement on the uncapped rebar. OSHA standards require that "All protruding reinforcing steel, onto and into which employees could fall, shall be guarded to eliminate the hazard of impalement." The key words are "to eliminate the hazard of impalement."

When employees work above rebar or other sharp protrusions, exposure to impalement is always a consideration. When I explained to the employer the potential injury to not only their employees but also other subcontractors and anyone else on the jobsite, they immediately put safety caps on the cement rebar.


Establishing Key Performance Indicators (KPIs). These indicators may include near-miss reporting rates, safety training completion rates, or the effectiveness of implemented safety measures. Continuously monitor and evaluate these KPIs to track progress, identify areas for improvement, and maintain a focus on ongoing safety enhancements. Tracking Incident Rate, DART Rate, Severity Rate, and Lost Time Rate year after year and against businesses in the same North American Industry Classification System (NAICS) code indicates how well a safety management program performs.


Learning from incidents. OSHA records provide valuable lessons from past incidents. Conduct thorough incident investigations to determine root causes and contributing factors. Utilize this information to implement corrective actions and prevent similar incidents.

Organizations can continuously improve safety protocols and prevent future incidents by learning from past mistakes. OSHA strongly encourages employers to investigate all incidents in which a worker was hurt as well as close calls or near misses in which a worker might have been hurt if the circumstances had been slightly different.

A few years ago, a warehouse employee fell, breaking her shoulder. She was rushed to the hospital, had surgery, and was sent home. A claim was submitted to workers comp, the incident was recorded on the OSHA log stating that she tripped, and that's all. Unfortunately, she died from a blood clot two days after her surgery. This is why doing a root cause analysis is essential.

Ask questions like:

From this root cause analysis, the floor markings were installed, separating forklift and foot traffic, significantly reducing this hazard and the possibility that this accident could happen again.


Regularly reviewing and updating safety policies. Keep safety policies and procedures up to date based on the insights gained from OSHA records. Review and refine safety protocols to align with best practices and regulatory requirements. Encourage feedback from employees and stakeholders to ensure that policies remain relevant and effective.

Over the past several years, I've had the honor of chairing the safety committee of the Associated Builders and Contractors in West Michigan. I've helped several contractors complete the Safety Training Evaluation Process application (STEP), which scores their safety and creates a roadmap to world-class safety processes.

The experience has taught me that things change a lot from one year to the next, like:

Business conditions change so it's critical to at least annually review and update safety policies.


Providing feedback and recognition. Acknowledge and recognize employees' contributions to maintaining a safe work environment. Provide feedback on safety performance, highlight exemplary behavior, and encourage a positive safety mindset throughout the organization. By fostering a culture of safety and recognizing employee efforts, organizations reinforce the importance of workplace safety.

If there is a lack of trust, effective communication, and psychological safety, it is unlikely that sharing feedback with your employees will result in significant improvement. More importantly, with these essential elements, workers may be able to provide you with the feedback necessary to advocate for organizational-level system safety.


Randy Boss is a Certified Risk Manager at Ottawa Kent in Jenison, MI. He is a Master WorkComp Advisor (MWCA).