Don’t Fear the Injury Data

lightbulbFor 45 years, the Department of Labor has required employers to record the injuries and illnesses that workers suffer in their workplaces. But a new rule from the department is generating controversy because it requires employers to electronically submit some of that data to OSHA, with the intention that it will be made public.

Well, my message to the business community is this: Don’t fear transparency. Embrace it. A focus on safety − even in the glare of public scrutiny − will not only help your workers, it will also improve your bottom line.

I know, because I’ve lived it.

In October 1987, I took the helm as CEO of Alcoa, the aluminum manufacturing giant based in Pittsburgh. I surprised more than a few people when, in my opening remarks, I insisted that our primary focus going forward was to be on worker safety. Not profit margins. Not product lines. Not output. Safety for workers was number one and my goal was zero lost workdays from on-the-job injuries.

Alcoa already was a relatively safe company, sitting below the average for its industry at 1.86 lost work days per 100 workers. The safety director was very proud of that record, and even he was startled by the idea that zero was the goal. There’s always a litany of reasons why you can’t get there. But I knew we had to try, and I reinforced that idea in every meeting I had − with division presidents, workers and supervisors, and even shareholders.

After I’d been there a few months, there was an incident at an extrusion plant in Arizona. An 18-year-old worker, only three weeks on the job, jumped over a protective barrier to clear a jam on a machine. A circulating boom came around and hit him in the head, killing him instantly. He left behind a wife who was six months pregnant.

I got the whole executive crowd together, down to plant supervisor level, and we spent a day reviewing what happened. It was a grueling process, and when it was over, I got up and said, “We killed him. The supervisors were there, but we killed him. I killed him, because I didn’t go a good enough job of communicating the principal that people will never be hurt at work.”

That’s when we started seeing real change. During my 13 years at Alcoa, we saw the lost workday rate drop from 1.86 to .20. No one would have thought it possible when I started. And guess what? During that time, Alcoa’s market value jumped from $3 billion to $27.53 billion, while net income increased from $200 million to $1.484 billion.

Bottom lines and safety transparency are definitely compatible, and sustainable.

Long after I left Alcoa, the corporation continues to make safety a priority, and to brag about it to the world. A page on the corporate website documents its real time injury and illnesses rates and Alcoa’s continuing efforts to keep workers safe.

Zero work-related injuries and illnesses have been long-standing goals for Alcoa. But when zero first became the target, it seemed unreachable. "Accidents are inevitable" was often the response. They're not. We can attain zero. It is possible, and, in many locations, it is already here thanks to dedicated effort and a firm commitment to our core values, one of which is to work safely, promote wellness, and protect the environment.

On Monday of this week, I checked the page. Alcoa’s global rate for lost days due to injury was .076.  That’s pretty good for where we started, but I still wish it was zero.

Paul O’Neill is a former secretary of the treasury and former CEO of ALCOA.

  1. National Apprenticeship Week: More Apprenticeships, More Opportunity
  2. Job Creators that Hire Veterans
  3. America’s Workforce: Empowering All
  4. Apprenticeship Program Launches Career in Community Healthcare
  5. September Is National Preparedness Month: Is Your Workplace Ready For Severe Weather?


Excellent article. People still cannot seem to understand safety injuries equal monetary loss in more than just lost work days. Pride in a safe work place is priceless as is the cost of the life of a loved one. Many times it is not just loss of life but injuries that last a life time, impact family, friends, medical communities and the emotional impact on the injured workers and those around them. Make zero the goal for everyone, lets stop counting up the days waiting for the failures to come but rather have positive reinforcement against other work locations and organizations. By using the natural competitive personalities towards a positive zero goal allowing workers to rally around cooperative programs and reward a safe workplace. I recommend leadership reading the study on "How positive and negative feedback motivate goal pursuit" (Fishbach, Eyal & Finkelstein, 2010) and other topics surrounding influencing employees on achieving goals.

Obviously M. Clarke, you have no idea of the new rule and the PRIVATE data that can be shared with the world. A company's injury information is already shared with their employees, and industry-wide data is already used among safety professionals for the "competitive personalities." Company-specific data being released by company name is irrelevant to how companies integrate safety. This is a snow-job that you have little knowledge of.

SDVeteran - the data isn't private, or PRIVATE. It is information that is already required, by statute, to be created and maintained. It is also already required to be made available to not only employees, but also their representatives, and not just in its summary form, but in its entirety (300, 300A, 301).

Although I have my concerns with the new rule, (like the fact that they are going to use software to clean employee information from it and that ambulance chasers and union organizers will most definitely use the database way more than employees), it does not change the fact that public scrutiny of records DOES modify Corporate behavior.

The question becomes whether that modified behavior is manifest as improvement of conditions or lying on the forms.

And before you ask - I also have been doing this for 20+ years...

You know what Paul, you are grossly misleading your readers… how dare you. You don’t mention one word about injury data of private companies being available to the world, nor that a government database will be housing personal injury data on workers. Now I respect you making safety a value and doing what you did at Alcoa, and I’ll bet your safety people all day long used industry data to compare Alcoa’s incident rates and other injury/illness data. And that’s great! But what you so carefully avoid in your article, press release for Obama, or whatever you call your article/blog/advertisement is a fraud.

Think logically about this new rule for a moment. Injury data from the OSHA 300 log is going to be electronically available to the world and listed by individual company. That’s right, Paul, the world. That means when you have an injury at a private company in the US, that information will be sent to a government database. Then, those results of that individual company (not the individual person) will be available for the world to see. Now of course the government is telling us that this data is un-hackable, and that only the outcomes of the injuries (not the person) will be available.

Second, did you even read the Executive Order titled: “Executive Order — Using Behavioral Science Insights to Better Serve the American People.” You will definitely imagine government control from 1984 - the book and movie! Check out the newest blog by your DOL head where he refers people to read that Executive Order to better understand why this new OSHA rule is “good for America.”

It’s true that currently that ALL workplaces have to report and “record” work-related injuries. I hope that people reading your post don’t let your subtle misdirection keep them from the truth.

As a 25 year safety professional, data for many companies is currently sent to the Bureau of Labor Statistics (BLS) and then that information is categorized in many different ways and available to the world. It is used widely by safety and health professionals (just as I’m sure your safety and health staff did) to help an organization handle exposures and protect its workforce!

Now the Obama administration as a subtle, but very dangerous next step, states: “OSHA’s final rule will modernize the current system by taking establishment-specific (company) injury information…once it is cleaned of personally identifiable information.” Notice that the government is going to leave the company information available – they won’t be scrubbing that information! Paul, maybe Alcoa being publically traded wants its injury data online, but what about the hundreds of thousands of private companies. Do you think they want injury date listed by company, or for that matter that they want the government to have employee information about injuries on some central database somewhere?

Lastly, in some companies a number of factors can cause injuries, and that is PRIVATE (repeat, PRIVATE) information between the company and its employees… not THE WORLD. You see Paul every employer already has to provide injury data to its employees – from Feb. 1 and April 30, every year. The information must include total number and cause of job-related injuries and illnesses that occurred in previous year. Names of individuals are of course deleted. It’s called the posting of your OSHA 300 log and it already is posted at companies between the months listed. But the Obama administration has another motive, and it’s absolutely wrong for America, its Citizens, and Companies! Paul you should be absolutely ashamed of yourself for supporting this new OSHA order.

Not all companies have to report. Per OSHA, only "all establishments with 250 or more employees in industries covered by the recordkeeping regulation must electronically submit to OSHA injury and illness information from OSHA Forms 300, 300A, and 301. Establishments with 20-249 employees in certain industries* must electronically submit information from OSHA Form 300A only." That lets smaller companies off the hook for reporting.


I do not understand your logic at all and it does not make sense. What's wrong with sharing the injury data with the world? The public is going scrutinize you? Afraid of losing your private data on how many employees are injured? Think about it, SUPPOSE you have 99 out 100 people get injured at your company, should not your company get publicly criticized or scrutinized? the work environment should be improved? What you are saying is similar to I should never tell the police my name when the police pulls me over because my name is private information-PRIVATE DATA, as you said. If you have nothing to hide, why can't you tell the police your name?

SDVeteran; companies are required to post the OSHA Form 300A, not the OSHA Form 300. Employees and their representatives have the right to view the OSHA Form 300 in its entirety; however, employers are not required to post the 300 log. In addition, employees and their representatives have limited rights to view the OSHA Form 301. Since you've worked in safety for 25 years, you should know the details. Being that you don't know the details may be an indicator of why you don't support an effort aimed at gathering data to target risk.

Paul Burnett, I think you misunderstand what report and record means. You are assuming the world of OSHA. I am talking about the reporting and recording of all injuries in workers' compensation - which requires ALL employers to report and record. and yes, for OSHA purposes, 20 or more employees (in some industries) will be required. But that's not the point - whether it's for small, midsized, or large companies. The point is that this is PRIVATE information between companies and its employees (OSHA 300 log posting), and not for the world.

SDVeteran, I could not disagree more. If you sue your competitor in court, that is a public record as are all court cases, unless sealed on rare occasion. It does not matter that your company is public, it matters that you have filed a public lawsuit. If you hit a pedestrian while driving your car as a private individual, you will be prosecuted in a public court and this information is made public along with all the involved names. If a company injures its workers, it should be public information. I want to know if a company I am doing business with is injuring its workers. Privacy has its limits.

SDVeteran, I disagree with you. As a safety professional I'm not afraid of having my company data reviewed and scrutinized. At the end of the day my focus as a safety professional is to do my best to assist our employees in staying safe. If having our data scrutinized and reviewed assists me in doing this I'm happy. I don't care if a "snowjob' "executive order" or an "Obama subtitle" helps me do this. I believe in using all the tools I can.
We are a large, publicly held company and we have people that address security and employee privacy everyday. That isn't my job. We also belong to a number of industry associations and employ lobbyists whom I'm sure expressed their views and our positions on the subject. That said as a safety professional I plan to use this as another tool to help me keep people safe.

Safetyguy, you work at a publicly held company! You miss the point of this regulation. As a safety professional, you are very aware of both the National Safety Council and BLS and providing industry-specific data. And I suspect you use that data. As for you not afraid of having your company data reviewed, I can appreciate your feeling ownership of your company, but it's not a fair comparison to the small to midsized company with private (not-public) information that now will be made public. If you fail to understand the real purpose of this new regulation, then you lack a fundamental understanding of the workings of politics. You might have a lack of understanding of layoffs and increased claims, plaintiff attorneys, workers' compensation, and a number of factors that influence loss reporting. The regulation does nothing to make-aware to viewers what a particular incident rate is what it is. This regulation does nothing to improve safety in America. I commend you for the work you do to protect your workforce, but you are misguided about the purpose of this regulation.

We are a Metal Service Center (NAICS 423510) with 8 locations in 6 states and 230 employees total.

Are we to electronically submit our 2016 Form(s) 300 by location or just one aggregate Form for the entire company?

Also, some of our locations have less than 20 employees. Will we need to electronically submit our 2016 Form(s) 300 for those locations or omit them?


Scott, please give OSHA a call at 1-800-321-6742. More information is also available at

Add new comment

5 + 2 =




Don't miss a post!

Sign up to be notified when we publish a new post:

Connect with us

Connect with the Secretary

Connect en español