COR certification, WCB rates and injury rates

When Cottonwood Place Developments invited contractors to bid on Cottonwood Place, its tender documents required each bidder to hold a valid Certificate of Recognition (COR) and to submit its injury frequency for the past three years. Two of the seven firms that asked for the documents could not meet the COR requirement and dropped out. Tallgrass has held COR since 2009. Its safety numbers are part of how it wins work, and they are also one of the ways it finds out whether its program is working.

This lesson looks at how safety programs are certified and measured, what the numbers mean and do not mean, and how Tallgrass uses the same measures when it chooses its subcontractors.

The Certificate of Recognition

COR is a national safety program certification for construction employers, endorsed by the Canadian Federation of Construction Safety Associations, with each province's safety association acting as the certifying body. In Manitoba, COR for construction is granted by WorkSafely, the safety arm of the Manitoba Heavy Construction Association, and it is part of SAFE Work Certified, the provincial certification standard run by SAFE Work Manitoba, the WCB's prevention arm. A COR shows that an employer's health and safety management system has been audited against a recognized standard and met it.

The Manitoba program runs on a four-year cycle. In the first year, an external auditor certified by WorkSafely audits the employer's system through document review, interviews with workers and supervisors, and site observations. In the second and third years, a trained internal auditor employed by the company carries out a maintenance audit, which WorkSafely reviews. In the fourth year, an external auditor carries out a recertification audit. To pass, an employer must score at least 80 percent overall and at least 50 percent in every element, and it must submit a corrective action plan for findings within 14 days. Employers must keep at least one full-time employee with valid internal auditor certification. Small employers with fewer than 10 workers can certify through SECOR, a simpler version with the same audit cycle.

COR audits look at elements such as management commitment and policy, hazard assessment, safe work practices and procedures, company rules, personal protective equipment, preventive maintenance, training and communication, inspections, investigations, emergency preparedness, statistics and records, and legislation. The interviews matter: an auditor who finds a perfect manual but workers who cannot describe the company's hazard assessment process will score the element low.

What COR is worth

In Manitoba, employers with COR or SECOR can receive a rebate on their WCB assessment premium, currently 15 percent, and small employers can receive up to $3,000 through the WCB's prevention rebate. Many public and large private owners require COR or SECOR to bid, and general contractors often require it of their subcontractors. COR is also recognized in other provinces through reciprocity agreements among the safety associations, so a Manitoba contractor can bid in Saskatchewan or Alberta. But the real value is the discipline of the audit cycle: every year, someone looks hard at whether the system works and the company has to fix what is found.

WCB rates and experience rating

The WCB of Manitoba sets an assessment rate for each industry rate group based on the group's claim costs, and then adjusts each employer's rate up or down based on its own claim experience compared with its group. An employer with fewer and less costly claims than its peers pays less; one with more pays more. Owners sometimes ask for an employer's rate history, and a rising rate can be an early sign of trouble. Like any measure based on claims, it reflects what has already gone wrong, not what is being done now to prevent harm.

Injury rates

Injury rates let companies of different sizes compare their records. The most common in Canadian construction is the lost time injury frequency, the number of lost time claims per 200,000 hours worked, which is roughly 100 workers working a full year. Many companies also track a total recordable injury frequency, counting medical aid and modified work cases as well as lost time. Some owners and associations use claims per 100 workers instead. Whichever is used, the method must be stated, because different methods give very different numbers.

Owen calculates Tallgrass's rates for Cottonwood Place each month and compares them with the company's three-year average.

# Injury rates for the Tallgrass workforce on Cottonwood Place, year to date.
hours = 186_400          # hours worked by Tallgrass employees
recordable = 3           # medical aid + modified work + lost time cases
lost_time = 1            # cases with days away from work
restricted = 1           # cases with restricted work or transfer
base = 200_000
trif = recordable * base / hours
ltif = lost_time * base / hours
dart = (lost_time + restricted) * base / hours
print(f"total recordable rate: {trif:.2f}")
print(f"lost time rate:        {ltif:.2f}")
print(f"days away/restricted:  {dart:.2f}")
print(f"rule of thumb: one case adds {base / hours:.2f} to each rate at this size")

total recordable rate: 3.22
lost time rate:        1.07
days away/restricted:  2.15
rule of thumb: one case adds 1.07 to each rate at this size

The last line of the output is the reason Owen is careful with these numbers. For a workforce of this size, a single injury moves the total recordable rate by more than 1. A low rate over a few months says little about whether serious injuries are being prevented; it may just be luck.

Leading and lagging indicators

Injury rates, WCB rates and experience rating are lagging indicators: they measure harm after it has happened. Good programs also track leading indicators, which measure the activities that prevent harm. On Cottonwood Place, Owen's monthly report put both on the same page.

A rising count of near-miss reports is usually good news in the first months of a project: it means workers trust that reporting leads to fixes rather than blame. A sudden drop with no change in conditions is a warning sign that people have stopped reporting.

When numbers are managed instead of hazards

Any number that is used to award contracts or bonuses will be managed. Some companies have been found to discourage injury reporting, to pressure injured workers to return to light duty the same day to avoid a lost time case, or to treat injuries with first aid when medical care was needed. Those practices harm workers and break the law in both countries. Tallgrass bases supervisors' safety bonuses on leading indicators, such as inspections and deficiency closure, and never on injury counts, and it audits its injury records against first aid logs and the site's daily reports.

Reading a safety record properly

When Owen reviews a subcontractor's numbers, he asks four questions before he draws any conclusion. First, how many hours are behind the rate? A firm with 40,000 hours a year can go from a perfect record to a poor one with a single injury, so he looks at three years together rather than one. Second, how serious were the injuries? Three minor recordable cases are a different story from one amputation, even if the rate looks better. Third, what kind of work produced them? A drywall firm's injuries should be compared with drywall firms, not with electricians. And fourth, what has changed since? A firm that had a bad year, investigated it honestly and changed its practices may be a better choice than one with a clean record and no system for learning.

He also looks at the enforcement history in the same way. An improvement order for a missing fire extinguisher tag is not the same as a stop work order for workers in an unshored trench. A firm that lists its orders openly, with what it did about each, earns more confidence than one that claims to have none when the Branch's records say otherwise.

Serious injury and fatality potential

Many companies now look beyond total injury counts to events with serious injury or fatality potential: incidents and near misses that could reasonably have killed or permanently disabled someone, whatever the actual outcome. Research in several industries has found that total injury rates can fall for years while serious injuries and deaths stay flat, because the causes of minor injuries, such as cuts and strains, are often different from the causes of fatal ones, such as falls from height, struck-by incidents and contact with energy. A dropped wrench that misses a worker by a metre is a near miss with serious injury potential; a paper cut is not.

On Cottonwood Place, every event with serious injury or fatality potential, whether or not anyone was hurt, was investigated with the same depth as a lost time injury and reported to Tallgrass's vice president of operations within 24 hours. In the first year there were nine such events: three involving dropped objects from upper floors, two involving the crane, two involving excavation edges, and two involving openings, one of them the level 5 fall. That list, not the total recordable rate, drove the priorities in the site plan's revisions.

Owen also shares the site's indicators with the workers themselves. Each month, the site board shows the inspections completed, the deficiencies closed, the near misses reported and what was done about the three most important ones. When workers can see that a near miss they reported led to a new cover, a new rule or a changed sequence, they report more. When the numbers are kept in the office, the people best placed to improve them never see them. The board also shows the number of days since the last event with serious injury potential, but Owen is careful never to present it as a target to be protected, because a counter that workers feel responsible for keeping alive can become one more reason not to report.