Carrying forward the emphasis on workplace safety that has been a focus of recent AAMA Western Region events, JoAnn Deckert of the National Safety Council (NSC) informed members on OSHA incident reporting requirements and strategies for fulfilling the obligations.

The types of incidents involved would be those featuring personnel injuries or illnesses; damage to property, equipment or product; and “near miss” occurrences. Deckert surveyed the many barriers to incident reporting, ranging from the procedural to the psychological, and considered some solutions to overcoming those barriers.

Reports are to include not just what happened but why and how to eliminate the causal factors through the process of corrective action. The “why” aspect requires determining the root cause, which requires analysis of the contributing factors involving people, equipment and the work environment. Once the root cause is determined, a corrective action should be planned to eliminate that cause. The ultimate solution, likely to be among several considered, should be that judged to be the best option in terms of cost-effectiveness, effect on productivity, implementation time, the extent of supervision needed and acceptance by personnel.

Deckert reviewed the mechanics of OSHA injury and illness record-keeping requirements, incumbent upon any employer with 10 or more employees. All employers are required to notify OSHA when an employee is killed on the job or suffers a work-related hospitalization, amputation or loss of an eye; a fatality must be reported within eight hours and a hospitalization reported within 24 hours. She pointed out that minor injuries requiring first aid only (e.g., a cut not requiring stitches) do not need to be recorded and that OSHA recordkeeping requirements are not the same as worker’s compensation requirements.

The essential forms for OSHA-required recordkeeping, which must be kept on file for a minimum of five years, are:

• Form 300, Log of Work-Related Injuries and Illnesses, a sequential description of incidents as they occur
• Form 301, Injury and Illness Incident Report, asks for more detail about individual incidents
• Form 300A, Summary of Work-Related Injuries and Illnesses, lists the number of incidents falling within four different seriousness categories, the number of days away from normal work that resulted and the number of injuries within each of several defined types, such as respiratory conditions, poisonings or hearing loss.

Forms may be accessed online at https://www.osha.gov/report.html.

Incidents that must be recorded (within seven days of occurrence) are those involving death, loss of consciousness, loss of a work day, restricted work time or reduced work assignment, medical treatment (other than first aid) or an illness or injury diagnosed by a physician.

Deckert also explained new rules for electronic submission of the required records, which debuted in 2017 and is applicable to establishments with 250 or more employees. This is intended to accelerate categorization of incidents across industry segments to aid in prioritizing preventive measures. The electronic submission deadline for 2017 and 1018 is July 1; for 2019, it is March 2. The secure website through which data is to be reported was scheduled to go live this past February.

Meanwhile, employers must inform employees of their right to report work-related injuries/illnesses free from retaliation and the procedure for reporting such incidents, (which must be reasonable and non-discouraging.