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Why You Shouldn’t Rely on TRIR Alone

January 7, 2025October 26th, 2026
By Jay Finegan, J.D.
Jay Finegan, J.D.
Compliance Services Leader

Jay Finegan is a member of Dakota's Compliance Services team, where he is responsible for assisting clients with the implementation…

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    Once the gold standard of environment, health, and safety (EHS) metrics, the Total Recordable Incident Rate (TRIR) is now essentially meaningless—when considered alone, that is. The safety performance of an organization is far too complex to be condensed into a simple formula, and EHS managers must respect and appropriately respond to that complexity. While total recordable incident rate is often used to reflect a company’s past safety performance, it does not capture the full picture. An excellent report on this topic, “The Statistical Invalidity of TRIR as a Measure of Safety Performance,” addressed the complexity of safety directly: “[S]afety is a chaotic system due to the interfaces between people, culture, policies, regulations, equipment and other external factors (e.g. economy, weather, natural events, etc.)” The November 2020 report, released by the Construction Safety Research Alliance (CSRA) and authored by Dr. Matthew Hallowell, Mike Quashne, Dr. Rico Salas, Dr. Matt Jones, Brad MacLean, and Ellen Quinn, also revealed four key takeaways from a statistical analysis of 17 years of data and 3.2 trillion work hours:

    • “There is no discernible association between TRIR and fatalities;
    • The occurrence of recordable injuries is almost entirely random;
    • TRIR is not precise and should not be communicated to multiple decimal points of precision; and
    • In nearly every practical circumstance, it is statistically invalid to use TRIR to compare companies, business units, projects, or teams.” Although TRIR is intended to provide direct insight into safety outcomes, its statistical limitations undermine this purpose.

    With this in mind, let’s take a closer look at total recordable incident rate, how it has become increasingly less valuable as a solitary metric, and what EHS managers should be doing to more accurately measure safety success.

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    What is the total recordable incident rate (TRIR), and why is it used?

    Don’t get us wrong, while the total recordable incident rate should no longer be considered the end-all-be-all of safety measurement, the metric itself isn’t going anywhere. TRIR stands for total recordable incident rate: the number of OSHA-recordable work-related injuries and illnesses per 100 full-time workers over a one-year period. OSHA also refers to the same calculation as the total case incident rate (TCIR). Among other reasons, the case counts and hours worked behind your incident rates come straight from the injury and illness records that drive your annual OSHA reporting, so TRIR is likely to remain part of this compliance obligation. Under 29 CFR 1904.41, many establishments, depending on their size and industry, must electronically submit their Form 300A injury and illness summary to OSHA each year, and establishments with 100 or more employees in designated high-hazard industries must also submit Form 300 and 301 data. Essentially, two values are needed to compute this metric: the number of recordable incidents (including both injuries and illnesses) and the total number of hours worked. Here is the formula used to calculate TRIR: TRIR = (Number of OSHA-recordable injuries and illnesses × 200,000) ÷ Total hours worked by all employees

    Under OSHA 29 CFR 1904.7, a work-related injury or illness is recordable if it results in any of the following:

    • Death;
    • Days away from work;
    • Restricted work or transfer to another job;
    • Medical treatment beyond first aid;
    • Loss of consciousness; or
    • A significant injury or illness diagnosed by a physician or other licensed health care professional.

    Cases that require only first aid are not recordable. Specific cases such as needlestick injuries and hearing loss have additional criteria in 1904.8 through 1904.11. To calculate TRIR, multiply the number of recordable cases by 200,000, then divide by the total number of hours worked by all employees during the same period.

    The 200,000 figure represents 100 full-time employees working 40 hours a week for 50 weeks a year, so the result is the number of recordable cases per 100 full-time employees over a one-year period. The total number of hours worked should exclude non-working time such as vacations and sick leave; accurate reporting is essential for reliable data. You can check out more tips on discerning recordables from first aid in this article on OSHA recordable incidents vs. first aid.

    How to calculate TRIR: an example

    For example, if your company had four recordable injuries and illnesses over the past year and a total of 200,000 hours worked, your TRIR would be (4 × 200,000) ÷ 200,000 = 4.0. If the same four cases occurred over 400,000 hours worked, your TRIR would be 2.0. Companies often compare the result with the average rate for their industry to benchmark safety performance.

    What is a good TRIR?

    There is no single good TRIR. A rate only means something relative to your industry, so compare yours with the incidence rates for total recordable cases that the Bureau of Labor Statistics publishes each year by industry (NAICS code) from its Survey of Occupational Injuries and Illnesses. A rate below your industry average is generally viewed favorably, but as the research above shows, small differences between companies or sites are rarely statistically meaningful.

    Because the 200,000-hour base normalizes for hours worked, TRIR puts injury rates on the same scale whether a facility has 10 workers or 10,000. High-risk industries pay particular attention to TRIR due to the elevated potential for workplace injuries and illnesses. A company’s TRIR is an important metric tracked in safety reports and is influenced by the effectiveness of the company’s EHS programs. TRIR is used to identify trends and guide continuous safety improvement, and it can influence regulatory attention, insurance premiums, and business opportunities. So, while these data alone may not be very helpful for individual organizations looking to improve safety performance or limit recordable incidents, TRIRs can be illustrative for public health and safety agencies. The ability to quickly compare incident rates can help prompt the creation of new health and safety guidance and/or regulation as well as direct more effective or targeted enforcement efforts. However, many organizations continue to over-rely on TRIR in important discussions of workplace safety.

    Who uses TRIR to assess safety performance, and why is this a problem?

    Perhaps because of its tenure as a prominent safety metric, TRIR continues to be a prime metric of performance for many organizations, and its influence can be seen from the jobsite all the way up through the C-suite’s board room. In fact, TRIR is one of the primary, if not the primary, safety metric considered by executives because it is the type of hard data that can easily inform decisions. It can be clearly reported and used as a benchmark; it can be used to evaluate managers or potential contractors; it could affect insurance premiums; it’s a simple number to present to investors, customers, or others in the general public concerned about workplace safety. A high TRIR can be a barrier to attracting talent and securing business partnerships, because it may signal safety concerns or a weak safety culture. When using TRIR to evaluate contractors, companies often require contractors to meet specific safety standards, such as a TRIR below a set threshold, to ensure alignment with the company’s safety expectations and reduce risk. A lower TRIR is generally viewed as a sign of strong safety practices, while a high TRIR raises safety concerns and can negatively affect insurance premiums and reputation. So, what’s the problem? One problem with this is that the severity of incidents is not considered within the context of an organization’s TRIR. “[A] four-stich cut to the finger is counted in the same way as a fatality,” notes CSRA’s report, “and a near miss with the potential to be fatal is not in the TRIR metric at all.” Another problem noted by the study is that it could potentially take many, many worker-hours of exposure before TRIR even becomes statistically meaningful. The short time frame that TRIR is typically reported (i.e., annually), combined with the hopefully infrequent and also quite likely random occurrence of a recordable injury, further makes TRIR an unstable—and therefore unreliable—statistic. Additionally, relying solely on TRIR may not help prevent future incidents, as it does not address underlying safety issues or provide insight into proactive measures needed to improve overall safety performance. And, finally, the simple fact remains that TRIR is a lagging indicator, and while these metrics aren’t necessarily “falling out of favor,” it is recognized now that lagging and leading indicators must both be considered as complementary parts of successful EHS metric analysis. Without additional data to support it, TRIR is useless.

    TRIR data must make friends with your other metrics

    To make the metric meaningful, TRIR must live hand-in-hand with such common leading metrics as:

    • Frequency and completion rates of employee health and safety training;
    • Near-miss reports;
    • Inspection completion rates; and
    • EHS and safety audits.

    A comprehensive safety program is essential for reducing incident rates and fostering a strong safety culture. Integrating these leading metrics into your overall safety program helps drive improvements and employee engagement. Other metrics that are more lagging in nature should also be used to support TRIR. For example, serious injury and fatality (SIF) rates can be used to close the previously-mentioned severity blind spots in traditional TRIRs, and comparing SIF to TRIR will provide a better indication of the severity of your recordable (and non-recordable) incidents. These approaches support continuous safety improvement and should be integrated into the overall safety program. To navigate the complexities of EHS metrics, a parametric analysis approach is recommended. While that term may sound like it complicates things even further, it is a built-in part of Dakota Software’s Incident and Accident Management solutions, which are used to capture relevant safety data, track incidents, and provide exploration tools for qualitative analysis. Through our parametric filtering, EHS managers can recognize trends and subtle correlations between data fields that might have otherwise gone unnoticed. Incident review processes and the ability to identify trends in TRIR data are crucial for preventing future incidents and strengthening the company’s safety culture. To learn more about how our EHS compliance software can help with this and other health and safety initiatives, contact us to schedule a demo.

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