Foulke’s Case Study on S&H Programs

This week, OSHA posted on its website a case study designed to show the benefits of implementing a comprehensive workplace safety and health program.  In announcing the case study, Assistant Secretary Edwin Foulke, Jr said the report “is a good example of what can happen when management and employees dedicate themselves to workplace safety and health.”  The news release’s quote from the company was equally positive “…safety is part of our culture, and we have had measurable results over the past 5 years.”  But, the Foulke-promoted report has a familiar blame the worker tone, even suggesting in one part that an employee’s broken wrist was not really work-related.

The case study involves Ritrama Universal Duramark of Minneapolis which is described as a “multi-national corporation that manufactures pressure-sensitive films and labels for the automotive, beverage, health, beauty and pharmaceutical industries.”  Back in October 1997, Ritrama was inspected by the State of Minnesota’s OSHA-program (MNOSHA) and received 10 citations.  Several were for guarding of belts, moving equipment parts and other hazards, and some for electrical and lock-out/tag-out dangers.  The company contested the citations and entered into a formal settlement agreement with MNOSHA.  The Ritrama report says the firm agreed to do the following:

  • develop a leadership-management program
  • involve employees in a safety and health program
  • appoint a safety director
  • form a safety committee, and
  • develop a recordkeeping program for injuries and illnesses

So far, so good.  The company reported a reduction in lost-time injury cases from 13 in 1996 to 1 in 2005, and 269  days of restricted duty for employees (because of an injury or illness) in 1995, compared to 0 in 2004 and 2005.  The results sound almost too good to be true, and I don’t have any data to indicate that they aren’t true.  My concerns comes from a few other things I read in the report.  Here are a few choice quotes (you can read the entire report here):

  • “The Safety Consultant [hired by Ritrama] found…most injuries were a direct result of the employees’ failure to follow established safety and health practices.
  • “…managers learned that requesting changes in employees’ behavior was not sufficient to cause it to happen; employees wanted to continue their past behavior.”
  • “The ‘spike’ in the graphs below [showing 180 lost-work days in 2002] was caused by an employee who…tripped, fell and broke his right wrist.  Surgery revealed that this employee had a pre-existing condition that resulted in multiple surgeries.” 

The most recent MNOSHA inspection at the facility (October 2005), the employer received two serious violations for hazards related to electrocution risk, with an $1,120 penalty.

In Mr. Foulke’s promotion of the case study, he notes that Ritrama is a “signatory of the Graphic Arts Coalition alliance” with OSHA.  (The original alliance agreement was signed in 2002, renewed in 2004 and again in 2006.)  

Comments

  1. #1 Jordan Barab
    July 20, 2007

    I think you left out one important phrase from the employer’s program:

    2001, the managers learned that requesting changes in employees’ behavior was not sufficient to cause it to happen; employees wanted to continue their past behavior. As a consequence, the managers developed a program of progressive disciplinary action for employees and for supervisors who were not enforcing the new safety and health program by issuing multiple warnings, then unpaid suspensions and ultimately terminations…. I was able to implement a generous rewards program of gift certificates, safety days off, letters of commendation and cash-on-the-spot awards

    Disciplinging employeesfor “safety lapses” or injuries or giving prizes for fewer reported injuries often leads to less reporting, but not necessarily fewer injuries.

    Reducing unsafe conditions is the key. And this is one good example in the report:

    The new automated boxing line produces in one shift with two people what had taken two shifts with three people and eliminates the need for employees to manipulate 20-40 pound boxes, and the air-assist roll handler eliminates the need for employees to manipulate the 75–125 boxes of rolls weighing between 25–60 pounds that go into each shipment.

    And then: “Ritrama has not had an employee with a stress or strain injury to the back, shoulder or neck area in several years.” The question here is how Ritrama would have responded to a back injury: disiciplining the employee? Did fear of discipline keep anyone from reporting a back injury?

  2. #2 Frank Mirer
    July 20, 2007

    Notice this is a state plan state, so the entire episode lacks any OSHA involvement.

    Also, Minnesota requires safety and health programs and safety and health committees as follows:

    5208.0010 APPLICABILITY.

    Every employer required by Minnesota Statutes, section
    182.676, to establish and administer a joint labor-management
    safety and health committee shall comply with the requirements
    of this part. If the size of the employer’s work force
    fluctuates, the employer is required to have a safety and health
    committee during the periods when more than 25 employees are
    employed.

  3. #3 Celeste Monforton
    July 20, 2007

    Yeehaw!! Somebody actually reads my blog posts. Cool. And coming from skilled bloggers like you both, I’m thrilled with your additions and corrections. One of the things I struggle with while wearing my blogging cap is, when commenting about a particular document, how much of the document should I offer readers as a direct quote. My strategy has been to give readers a little taste of what’s in the document, and hope that they go to the full item for themselves. With the Ritrama case study, I was hoping that someone else would look at the full case study and comment on the items that you both raise.

    The case study says that the firm employs about 19 people, so if I’m reading Frank’s comment above correctly, the firm was not required to have a S&H program or committee, but was required to do so as part of their settlement agreement. Is part of the story that the firm could have dropped their program and committee after some date established in their settlement, but decided that it had real benefits and decided to keep it?

    I also like the disclaimer at the bottom of the case study “the views expressed herein do not necessarily represent the official position or policy of the US Dept of Labor.”