Does your corporate injury reporting add value?
(その傷害報告書は付加価値をもたらしていますか)


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2012年よりビューローベリタスとパートナーシップを結ぶEnhesa(エンヘサ)社が執筆する、「海外における法規制」に関する記事を連載しています。
Enhesaは、ベルギーのブリュッセル及びアメリカのワシントンDCに本社を置くグローバルコンサルティング会社であり、企業のEHS (環境、労働安全衛生) 及び製品の遵法を支援しています。


One of the oldest metrics used in the EHS field is corporate injury and accident reporting. It is one of the few times when EHS data will often contribute directly to Corporate Annual Reports. But is your reporting system state of the art or a relic from the past? Whatever the number may be, you are either adding value or showing corporate weakness. In this article we explored the current climate, challenges faced, as well as key best practices.
(EHS (環境・労働安全衛生) 分野で用いられている最も歴史ある基準の1つに、企業の傷害・事故報告書が挙げられます。EHSデータが企業年次報告書に対してダイレクトに貢献することが頻繁にあるわけではありません。しかし、御社の報告システムは最新のものでしょうか、それとも過去の遺物と化しているでしょうか。傷害・事故発生件数に関わらず、その報告書は付加価値をもたらす、もしくは企業の弱点を示すのです。本稿では、企業の傷害・事故報告書に関して、最新の動向、課題、そして主なベストプラクティスを取り上げます。)

1.Why report accident statistics?
Based on a survey carried out by Enhesa in 2014, amongst Corporate EHS Managers, more than 90 percent collect corporate injury and accident data. For more than 80 percent, data is collected and summarized on a monthly basis. Only a few countries require company headquarters to compile accident and injury data (e.g. France). The push to do so clearly comes from the investment community which perceives health and safety performance as a key element of a company’s good governance. A good health and safety track record is a positive lagging indicator of overall management performance. A poor track record suggests that business processes are not properly managed and is therefore a significant indicator for potential high risk exposure.

2.How to report?
Most corporate annual reports and especially most corporate sustainability reports will contain a section or some data on corporate accidents and incidents. Enhesa did a survey in 2014 amongst multinational companies to get a sense of how they go about meeting this challenge.
Most leading companies are compiling accident and incident data following the Sustainability Reporting Guidelines of the Global Reporting Initiative. Many companies are still following the G3 edition of the guidelines from 2006, but the migration to the G4 edition of the guidelines from 2013 is ongoing.
The G4 Guidelines provision LA6 requires reporting on the type of injury and rates of injury (Injury Rate - IR), occupational disease rate (ODR), lost days and absenteeism (Absentee Rate - AR), and total number of work-related fatalities by region and by gender. It requires companies to do this for employees and supervised workers, as well as for independent contractors working on-site. It seems pretty straight forward, but the problem arises with almost every word used in the previous sentences. Each country seems to use a different definition of the various concepts, which often results in comparing apples to oranges. It is for this reason that the G4 Guidelines require companies to report on the system of rules applied in recording and reporting accident statistics.
Due to the chaos in requirements at the national level, most companies will take the accident and illness reporting requirements from the country in which their headquarters are based. 65 percent of respondents follow the national standard with no deviations, while 25 percent follow the national standard with some adaptations.
Most companies use an online system to collect the occupational accident and injury data (91%), with only a small portion that still uses a form to collect data (9%). The 91 percent who use an online system is further split into 58 percent who built their own data collection system and 31 percent who purchased a system. The latter group seems to be gaining in popularity.
What needs to be reported at the corporate level by injury type is summarized in table 1.

What needs to be reported at the corporate level by activity type is summarized in table 2.

When asked whether the corporate reporting system would be reviewed in the coming years, 75 percent answered yes. Many companies still struggle to provide meaningful data at the corporate level. Since the data is published, it is a good indication of the level of corporate integration and management control.
A well-integrated company with strong management control will have no difficulty in providing global statistics that are coherent and meaningful; however failure to do so is an indication of weakness.

3.What the law requires from you
As a corporate manager, when you ask the facility manager to report accident and incident data, he will most likely use a system that requires different concepts and thresholds. We looked into the regulatory variations that may cause confusion in the data collection process.

Which workers are covered?
In the US, one must report on all employees on the payroll as well as temps or contractors if you supervise their activities on a day-to-day basis. In Argentina, for example, reporting must be done for all accidents to workers in your establishment, independent of who pays or supervises them. In the United Kingdom, the reporting also covers members of the public who get injured at your facility and require medical treatment.

What is “at work”?
The definition of “at work” is very different as it applies across the globe. For some countries the obligation is literally limited to “at work” and excludes sanitary, smoke or lunch breaks. Other countries will put the threshold at the time-clock where you register your worktime, or as you get into the facility gate and park your car. For many countries, “at work” begins when you leave the doorstep of your home and includes the commute to and from home (e.g. Argentina and Belgium).

What is an injury or accident or illness?
Starting from the worst, it usually covers incidents resulting in death, days away from work, and those triggering medical treatment. Depending on the country, it may also be expanded to include, for example, needle-sticks/sharp injuries or cases involving occupational hearing loss. While most countries will include road accidents, some countries will exclude these because they get accounted for and reported under road safety regulations. Some countries will limit the reporting requirements to work-related causes and exclude, for example, natural causes such as a stroke.

What is recordable versus reportable?
While many countries make no distinction and require all recordable injuries and accidents to be compiled into a periodic report, some countries do make a distinction and only require some of the recordable accidents to be reported.

How to count?
Under the US OSHA reporting requirements, one begins counting days away on the day after the injury occurred or the illness began. Most countries will include the day of the injury.

Where does the reported information go?
The information is used to determine the work accident insurance premiums to be paid by the company. In many countries it will also be used by inspection agencies to prioritize whom to inspect. Enforcement agencies and courts will use the data to determine whether the accident is an exception or part of a systemic shortcoming. Increasingly, name and shame policies are used during fatal accidents to maintain or increase pressure on companies to improve their safety policies and programs.

While most countries will compile the data and make the overall results public. A new trend is to make the company data public to allow employees, neighbors, suppliers, customers and others to assess and determine the risks when dealing with that company. Denmark took the initiative to attribute green-orange-red smileys to define safety performance and make it even easier to communicate.

It is worth noting that US OSHA is considering a provision to require some enterprises with multiple establishments to collect compile and submit some of the accident and injury data. This provision would apply to enterprises with a minimum threshold number of establishments (such as five or more) that are required to keep records. Access to this information will allow US-OSHA to use its resources more effectively by enabling the Agency to identify the workplaces where workers are at greatest risk, in general and/or from specific hazards, and to target its compliance assistance and enforcement efforts accordingly. The Computerized Accident Incident Reporting System operated by the US Department of Energy is an example of how things could be set up.

US-OSHA plans to post the injury and illness data online. The Agency believes that public access to timely, establishment-specific injury and illness data will improve workplace safety and health. Specifically, the online posting of establishment-specific injury and illness information will encourage employers to improve and/or maintain workplace safety/health to support their reputations as good places to work or do business with.
 

Enhesa社 Thierry Dumortier
 

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Enhesaは、ベルギーのブリュッセル及びアメリカのワシントンDCに本社を置くグローバルコンサルティング会社であり、企業のEHS (環境、労働安全衛生) 及び製品の遵法を支援しています。日本にもサテライトオフィスを開設しており、日本時間に日本語での対応が可能です。Enhesaは世界200カ国・地域における現地EHS法令の改正動向月次配信、EHS遵法監査ツールの提供と第三者監査、製品規制調査等を提供し、日本企業の国内及びグローバル市場における事業展開・事業運営、輸出に関する法令遵守を支援しています。


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