Comparability – data presentation

Further to concerns raised in the previous section over the choice of OHS indicators and metrics by which OHS performance is communicated, there are presentation issues regarding the extent to which OHS disclosures adopted appropriate units of measurement, employed appropriate levels of data (dis)aggregation and maintained individuals’ rights to privacy. Each of these issues is briefly explored below.

Units of measurement: The survey responses highlighted preferences for particular units of measurement to be applied to different categories of OHS performance data. Concern as to whether OHS data should be disclosed as absolute numbers, rates (such as frequency rates or percentages) or both was apparent in relation to OHS outcomes. For OHS failure costs, there was very strong support for the disclosure of both the number and magnitude of OHS fines and penalties given multiple fines can be an important indicator of poor OHS management (M12). The number of fines, therefore, differentiates single from repeated infringements, while the total cost reflects the seriousness of the incident and the financial impact on the organisation. Stakeholder preferences for OHS outcomes were generally for each category of outcome data to be presented as both an absolute number and a rate (as illustrated below), although 83% wanted to see fatalities presented as an absolute (total) number of work-related deaths, supported where appropriate by further information regarding the number of deaths by region. Similarly, many respondents sought both number and rate information for categories of injury and illness outcomes although slight preferences were evident for the disclosure of the total numbers of permanent and temporary disabilities and for frequency rates of lost time and recordable injury. Supporting the disclosure of severity using actual totals one respondent suggested:

Rates dilute the perception of importance … Most reports include a total number of employees. Show how many people were killed or injured and let stakeholders make decisions about relativities off the page (U14).

Stakeholder preferences for presentation of OHS outcome KPI data 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Fatality Total injury Total illness Severity measures (based on disability)

Response measures (based on lost time)

% of r e s p onde nt s Rate only

Both number and rate Number only

Figure 5-14: Stakeholder attitudes to the presentation of OHS outcome KPIs

The preference for the presentation of outcome KPIs as both a number and a rate was not so consistently reflected in relation to process KPIs. For example, respondents revealed a strong demand for audit non-conformances to be expressed as both a number and percentage, but preferred to obtain risk information as a number (then both number and rate) and information about absenteeism and committees as a rate (then both rate and number). These results are depicted in Figure 5-15 below.

Stakeholder preferences for presentation of OHS activity PPI data

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Near miss Hazardous exposures Absenteeism Training offered Training completed Audits completed Audit non- conformances New OHS risks Total OHS risks Risks controlled Committees % of r e s p on de n ts Rate only Both number & rate Number only

Figure 5-15: Stakeholder attitudes to presenting OHS process KPIs

Prior year data: To enable effective comparisons of performance over time, support was also found for companies to provide appropriate prior year data. As revealed in Figure 5-16, 100% of the respondents from four of the seven stakeholder groups agreed with the statement “Prior year data should be shown so current and past results can be compared”. Strong support was also evident from the remaining stakeholder groups as illustrated below. Only one respondent, an OHS manager, (M14) indicated prior year comparative data should not be provided to stakeholders.

While he represented a very small proportion of the sample, M14’s resistance to this aspect of disclosure reinforced the views of 85% of surveyed stakeholders that an OHS reporting framework needs to be supported by regulation or standards.

Stakeholder demand for prior year data

0% 20% 40% 60% 80% 100%

Employee Regulators Managers Unions Shareholders Owners Academics

Agree Undecided Disagree

Figure 5-16: Demand for the provision of prior year comparative OHS data

Aggregation: As noted above, over 93% of respondents agreed that firms should periodically disclose a measure of the total occurrences of work-related fatalities, injuries and illnesses to permit stakeholders to make effective overall assessments of OHS performance (M28). They also sought various supplementary subtotals including measures of permanent disability (with medical discharge), permanent disability (with return to work) and long- and short-term temporary disability. Although 84% of respondents demanded the separate presentation of total injury and total illness outcome data, only 20% of respondents were strongly opposed to aggregating illness and injury data in the various supplementary severity or response indicators. Approximately 74% also sought supplementary disclosures that revealed employee versus sub-contractor outcomes separately and 84% sought both total fatal and non- fatal outcomes and a breakdown by region (for national organisations) or country (for multi-national organisations).

Privacy: Employees, unions and managers also expressed concern that OHS outcome information must not be presented in sufficient detail so as to compromise the privacy of either those individuals who have sustained an injury or illness, or of the families of those killed at work (E22, U29, M16, M33). Most were concerned about sensitivity, respect and maintaining the confidentiality of individuals’ names and personal details relating to injuries or fatalities, although one manager (M33) expressed concern over the confidentiality of individuals’ wage details which could be revealed by disclosing self-insurance compensation data.