The Uncertainty of Premium Data

Categories of analysis serve important functions in regulatory risk assessments. But these categories create uncertainty if we do not have an adequate framework for understanding what purposes they serve and how they were created. 

The following examples show how imprecise classifications can affect the health and safety of workers. All three accidents were classified as a major injury in a mine. In the first accident, a 33-year-old development worker slipped in water and fractured his left fibula. In the second accident, a 33-year-old faceman fell while he was cleaning the top of the powered support. In the third, a 35-year-old faceworker fractured his left ankle when he lost his balance while changing his trousers at the end of a shift. 

Such classifications may be useful in defining the level of injury. (All three suffered the same level of injury.) The categories can help us determine the frequency of accidents or lost work-time in a mine. But these categories provide little information about the cause or causes of the accident. If we wish to protect the health and safety of workers, we need more information than the data provide. To determine a solution, we need to understand the events and conditions that produced the accident. 

MSHA s 1988 Coal Accident Analysis and Problem Identification Instruction Guide shows how a system of classification designed to collect premium data can become an artificial template that structures not only the activity of the inspection but also the conclusions that inspectors can draw from their data. The Instruction Guide provides a set of checklists, tally sheets, and planned inquiry sheets to help inspectors categorize accidents. The classification system in the Physical Barrier Analysis Matrix (Fig. 3.1) seems to support the conclusion that physical barriers are either not possible or practical in most of the cases reported on the form—a conclusion that might exempt management from responsibility for protecting workers. Because data from such an analysis directly affects policy and procedures, classification systems can have 

The Physical Barrier Analysis Matrix. This document seems constructed to. support the conclusion that physical barriers are not possible or practical in most of the cases reported on the form. Source U.S. Department of Labor, Mine Safety and Health Administration (1988a, p. 63). 

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