How to Lift Your WHS Reporting and Compliance

WHS reporting is essential for safety. It also contributes to tendering success, the investigative attention authorities apply to you, your retention of good workers, the culture of your site and a variety of other outcomes. Reporting matters! Not reporting, or under-reporting, matters even more!

In our previous article, “WHS Reports and the Challenge of Underreporting”:

• We looked at nature, importance and prevalence of underreporting,
• We found out that it really does matter, 
• We identified who is responsible for the problem, and 
• We let you know of some of the ways we can help. 

In this article, we’re going to build on this foundation and take our solutions to a higher level. We will consider:

• Why WHS underreporting happens,
• How to improve WHS reporting, and
• Some big-picture reporting solutions.

Why Does WHS Underreporting Happen?

Why would a worker (or supervisor) see a hazard or incident, or suffer an injury, and not report it? 

Combining the findings of two studies, one Canadian and one American, we were able to compile the following list. It is not intended to be conclusive.

The first three items came from interviews with young Canadian workers, and therefore reflect realities wrestled with by the youthful and/or inexperienced. The remaining items were compiled using a broader spectrum of experienced and aged construction workers.  

Motivators for work health and safety non-reporting included:

• Powerlessness: Believing their voice does not matter.
• Wait and See: Delaying in the hope that someone else will either report or fix the issue.
• Seeking Peer-Support: So the report can be lodged along with someone else.
• It’s Only Small: Perceiving the issue as minor or not worth the hassle
• Normalising: Viewing pain or problems as an unavoidable part of the job.
• Keep It At Home: Believing home treatment of an injury would suffice.  
• Uncertainty: Feeling unsure of blame or cause.
• Approval Seeking: by NOT reporting in a do-not-report culture.
• Reputation Management: Avoiding a reputation as a complainer’ or trouble maker.
• Job Insecurity: Fearing a loss of work immediately or in the future.
• Expense Concerns: Inability to afford time off or related medical expenses.
• Statistics Manipulation: Improving WHS statistics for their team, project or employer.

Is There a Workable Solution?

Those two studies mentioned emphasise the critical role of supervision. The US study challenges leaders to create a “climate of open communication with a focus on problem-solving and learning.” Using other descriptors, the author also called it a climate of “positive error management.” 

Since the demotivators of reporting are real, and changing our environment seems like a worthwhile goal, how can we make that happen?

Ways You Can Improve Your WHS Reporting

By employing some simple and practical steps, the research indicates you can radically improve your reporting outcomes. We’re going to focus on achieving the big-picture priorities that were highlighted in the US study just mentioned. 

In other words, we’ll acknowledge that:

• Supervisor actions are important.
• It helps to know who is responsible for what.
• Open communication is significant - if not critical.
• A focus on problem-solving and learning can be a powerful motivator.
• The pain and consequence of poor reporting should be unapologetically explained.

Let’s unpack these principles and identify some practical steps and strategies. Let’s recognise the circumstances under which WHS reporting improves.

1. WHS Reporting Improves When  |  We Adjust Our Leadership Style

We’ve acknowledged that leadership and supervision styles matter. Stated differently, if workers are not led, they will not change. Steps we can take include:

1. Pursue a no-excuses approach. Excuses like 'not wanting to dob on mates', or being uncomfortable with forms, simply aren't acceptable. 
2. Model this no-excuses approach. Leadership excuses need to be addressed. When leaders stop using excuses, workers are less likely to use them too.
3. Talk up the benefits of safety and team contribution, especially when workers lodge a report. Ensure it is a positive experience.
4. Speak with workers regularly, and not always about safety. This creates a more personal relationship and encourages confidence and a sense of emotional security. 

2. WHS Reporting Improves When  |  We Know Who is Responsible for What

In our previous article, we looked at some New South Wales’ legislation regarding ‘persons’ at the workplace. We learnt that:

• A net of all-encompassing liability has been thrown across every worker. Workers must “report injuries and unsafe and unhealthy situations to (their) supervisor or to (their) health and safety representative (HSR).”
• By using the word “workers” rather than “employees”, the responsibilities of workers  and even visitors become significant. 
• The penalties for NOT notifying incidents range from a maximum of $50,000 for a body corporate to $10,000 for an individual. 

What should you do?

1. Ensure workers know their responsibilities. PCBUs, site supervisors and OHS Representatives should ensure the legal obligations of workers are known. Helpful resources are available at Safework NSW (or your jurisdiction equivalent) to this end.
2. Schedule and act on reminders so that workers do not forget these realities. 

3. WHS Reporting Improves When  |  A Climate of Open Communications Exists

Create a climate of open communication, try the following suggestions:

1. Ensure workers know you need the information. It’s important.
2. Let them know that spelling and handwriting are not a concern.
3. Encourage workers to ask for help if needed. Make it acceptable for others to complete incident and injury reporting under instruction. In other words, if a worker has low literacy or a non-English speaking background, that’s okay.
4. Tell workers to go higher if necessary. Suppose their immediate supervisor is a block or hindrance. In that case, they should go up a level - and they must be protected in the process.
5. Supervise the supervisors. Ensure accountability and standards flow all the way to the top. 

4. WHS Reporting Improves When  |  We Frame Reporting as Problem-Solving and Learning

Reporting WHS concerns and events is not ‘dobbing’ or ‘irrelevant’. It is the way problems are solved and avoided, and it is the way we learn (together) to make the worksite a safer place. It matters!

To create this climate, consider the following strategies:

1. Respond to near misses as learning experiences, not punishable actions. The tone needs to move from fear and doubt to openness, encouragement and reward.
2. Remove punitive or retributive consequences wherever possible.
3. Act on reports quickly.
4. Report back to the reporter with the corrections and responses made. Let them feel the full gravitas of the error or risk they just helped remove.
5. Publicly and significantly celebrate reports that lead to life-changing or life-saving adjustments. What is celebrated is often repeated. 
6. Remind workers OFTEN, through word and action, that you want to know about problems before someone gets hurt.

5. WHS Reporting Improves When  |   Emotional Pain is Involved

Help your workers understand the legal and flesh and bone consequences for failing to report hazards. Financial penalties are harsh, but having to attend a mates funeral and comfort their grieving family will obviously be worse!  

Your training on hazards, procedures, and WHS reporting are good opportunities to drive this home. Questions like the ones that follow can be very powerful, especially if discussed amongst peers who are informed of the things we have just spoken of: 

1. Is an excuse of feeling powerlessness, wanting to wait-and-see, over-valuing peer support, fearing peer-pressure or wanting to avoid the hassle worth up to a $10,000 fine?
2. Is a ‘tough-guy’ stoicism or a home-care preference worth a later-amplifying injury, or the very real risk that silence led to others being hurt?
3. Is being unsure of blame or cause, or fearing loss of work worth the life or financial cost?
4. Is the approval of mates or supervisors really worth someone’s life, or making a contribution to a culture of silence?
5. Are a teams’ work, health and safety reporting results really worth anything if they are not accurate?

The Improving Reporting Wrap-Up

We've seen that WHS reporting improves when leaders and workers understand the importance of reporting, non-compliance excuses become unacceptable, and workplace leaders actually lead. 

We've also seen that reporting is aided by a climate of open communication, problem-solving and learning. We've learnt that we can create such an environment by:

1. Adjusting our leadership style
2. Knowing who is responsible for what,
3. Opening up and clarifying existing communication channels, 
4. Framing reporting as a problem-solving and learning activity, and
5. Raising worker awareness of the legal, productivity loss and flesh and bone realities of WHS non-reporting.

Unsure where to start? 

We encourage you to consider these two pivotal questions:

• Do our procedures and policies encourage timely and accurate reporting?
• Do our procedures and policies encourage positive change in these areas?

If you're not sure of your answer, or you're reasonably confident the answer is no, we encourage a low-cost and straightforward exercise. The following very affordable resources will help you gauge where you're at, and can improve a range of reporting outcomes for you. 

For less than $130 (total), you can purchase both resources and use them to incorporate and implement the strategies we have just discussed. 

The products are:

• Incident and Injury Management Policy, and 
• Incident and Injury Management Procedures. 

The policy document will help you handle incident and injury management within specific timeframes and in pertinent ways. Using this clearly stated, and legislatively compliant policy will help shape the perceptions and practices of your people, as well as your outcomes. The second item, the Incident and Injury Management Procedures, will show you how to inform and train your workers how to respond and who to report to if there is an incident or injury.