1. OSHA Injury Reporting

2. Near misses, unsafe behaviors, unsafe conditions, slips, trips, mistakes take place every day
Sometimes these hazardous conditions result in somebody getting injured
But we have been trained as EHS professionals that these injuries are just the tip of the iceburg. Manny factors are taking place behind the scenes (under water) that manifest into an injury occurring.

3. Heinrich accident triangle
This isn’t a new theory
Herbert William Heinrich is an American industrial safety pioneer from the 1930
80 years ago, Heinrich published the accident triangle
EHS Mission Statement
Under the Occupational Safety and Health Act of 1970, OSHA's role is to assure safe and healthful working conditions for working men and women

4. EHS mission: to assure safe and healthful working conditions for the MIT community.
OSHA CFR
MIT EHS
MIT EHS core function is the same as OSHA
Under the Occupational Safety and Health Act of 1970, OSHA's role is to assure safe and healthful working conditions for working men and women
Point out 1904
1910
1926

5. Joe MacLeod & Suzanne Adams
OSHA Injury Reporting
Joe MacLeod & Suzanne Adams
This presentation represents a portion of the EHS management system and is represented by this diagram
Everyone in this room plays a vital role in this management system

6. OSHA CFR 1904
Requires employers to establish a procedure for employees to report injuries and illnesses
All employees on your payroll; labor, executive, hourly, salary, part-time, seasonal, or migrant workers.
Employees who are not on your payroll if you supervise these employees on a day-to-day basis.
Employee representatives have access to those parts of the OSHA 301 form relevant to workplace safety and health
Requires specific information to be reported.
Regulatory requirement black and white
Common sense? We all are in place to eliminate hazards and prevent injury
Employers are prohibited from discriminating against employees who do report
DPS notification for injuries resulting in hoisting (elevator) malfunction
MIT OSHA citation 2 years ago on recordkeeping

7. Basic accident and employee information used for nationwide trending / demographics, statistics
BLS survey suzanne will mention
OSHA Form 301

8. OSHA Form 300

9. Summarize your organizations findings on this form
OSHA 300A

10. MIT manages this recordkeeping requirement through SAP
And all of the useful toy and tools associated with SAP, SAP gui, and of course brioquerry

11. 2010 MIT Numbers Recordable 196 Incident Rate 1.9
LT Incident Rate
Days lost *
Days restricted 1344
400 reported injury/illnesses, 196 recorded

12. OSHA recordable injuries / illnesses
Number of programs in place to drive these numbers down
HR return to work program
DOF return to work / light duty program

13. Incidence Rates of Recordable Injuries and Illnesses
Numbers continue to get more and more accurate as we triage every accident report submitted to determine if it meets OSHA recordability standards
Triage process continues to fine tune and identify the MIT workforce per OSHA guidelines

14. MIT Incidence Rate of Cases with Days Away from Work
0.93
These numbers will fall as we tighten up our management of injuries
Return to work programs
Modified duty / light work programs

15. Roles and Responsibilities
Employee
Supervisor
DLC Coordinator
EHS Lead Contacts
Medical Provider
HR Worker’s Compensation
OSHA Recordkeeping
The players in the management system

16. Employee Notify supervisor Seek treatment
Provide medical documentation to supervisor
Communicate work status
Provide information on potential hazard/s in the workplace
Orientation
Safety committees
Union representatives
Shop stewards

17. Supervisor First line of defense in the management system
Ensure employee can get help
Address hazard
Submit supervisor report of injury
Investigate hazard and complete follow-up investigation questions*
Follow the incident through until “return to work without restrictions”
First line of defense in the management system
Address hazards: Clean spills, contact cust-coach, cordon off area, contact EHS / coordinator
Suzanne is there to “remind” supervisors if they forget to track
DOF recently reviewed this responsibility and is in the process of re-training supervisors on their responsibilities
Supervisors must maintain an open line of communication with the injured party
*(DLC coordinators help with this)

18. Supervisor Follow-up questions
What caused the accident?
Improvements to behavior (PPE, JHA,)
Conditions (defective equip., housekeeping, guarding
How to prevent re-occurrence?
Training, SOP (create / modify), install shielding
Other relevant information?
Basis for all accident investigation is Who, What, Where, When, how
Supervisors are encouraged to utilize others within the management system (EHS, Coordinators, Lead contacts)
After a few days of thinking about incident, then submit the follow up questionnaire (5-day report).
Goal is to identify root causes and put controls into place
Our goal as EHS professionals should be 0 accidents / injuries
DOF has incorporated this into their incident reporting procedures

19. DLC Coordinators/EHS Lead Contacts
Notified immediately via when on line report is submitted (Privacy cases)
Provide technical assistance to supervisor investigation*
Ensure hazard is addressed
Facilitate completion of supervisor’s report
Ensure action items are completed (maintenance,
training, procedure updates)
Investigate trends repetitive strain, lifting, frequent fliers, facility knowledge
Privacy issues – 3/400 reported cases were private
Some injuries require EHS investigations
ENGAGE MANAGEMENT SYSTEM-COORDINATORS MANAGE EHS ACTIVITIES IN DLC COORDINATORS MANAGE SUPERVISORS ENSURE INVESTIGATIONS ARE COMPLETE AND DLC ARE HAZARD FREE
Any Questions?...Note the first bullet

20. Medical Provider
All employees should go to MIT Medical for their first visit if they are physically able to (with supervisor assistance)
- Cases with ambulance, off hours and emergencies
Employee seeks treatment before reporting the injury to the supervisor (outside medical provider)
Evaluates injury / work capability & makes recommendations
Provides documents for lost time/restrictions/return to work status for employee and supervisor
MIT medical policy for work related injuries/initial evaluation

21. HR Worker’s Compensation
Managed in Human Resources
Strictly employee based
Collects all medical paperwork
Keeps track of lost time and medical treatment billing
Refer to the handout for specifics

22. WARNING: DO NOT MIX OSHA RECORDABILITY AND WORKERS’ COMPENSATION
Workers’ Compensation determinations do NOT impact OSHA recordability. Some cases may be OSHA recordable and compensable. Some cases may be compensable, but not OSHA recordable. Some cases may be OSHA recordable, but not compensable. OSHA stops counting at 180 WC can go on for years.

23. OSHA Recordkeeper Triage the Supervisor Reports of Injury
Injury and Illness Report (OSHA 301)
Employee Status
Determine if work related
Recordable vs. Not recordable
OSHA Log (OSHA 300)
Summary (OSHA 300A)
Reporting to the BLS
388 reports submitted
196 made it onto the OSHA log so about half

24. All employees on payroll and supervised on a day to day basis…like Next Source
Stipends-Grad students

25. Work-Related?
YES
NO (9 Exceptions)
An event or exposure in the work environment either caused or contributed to the resulting condition
An event or exposure in the work environment significantly aggravated a pre-existing injury or illness
Present as a member of the general public
Voluntary participation in wellness program, medical, fitness or recreational activity
Personal tasks outside assigned working hours
Personal grooming
Eating, drinking or preparing food or drink for personal consumption
9 Exceptions but here are some common ones
Reports not recorded about 15% are not work related.

26. Recordable?
Mention triage process – Determining work related?

27. General Recording Criteria Triggers for Recording
Death
Loss of Consciousness
Days away from work
Restricted work or transferred to another job
Needle sticks (some)
Medical Treatment beyond first aid
Sutures/glue
Physical Therapy
Prescription Medication
Removing foreign body from eye w/ more than flushing/cotton
Rigid splint
Broken bones and fractures
Needle sticks-contamination by another person’s blood or other potentially infectious material
Reports not recorded 80% are not because it was a first aid only.

28. Notification
Employers must record each case on the OSHA 300 Log and the Form 301 Incident Report within seven (7) calendar days after being notified that an injury or illness occurred.
Employers must use calendar days (including holidays and weekends) instead of scheduled work days, for recording days away from work [1904.7]. Employers may cap days away from work at 180 days.

29. Questions or Comments?

30. Why are employers required to keep records of work-related injuries and illnesses?
Injury and illness statistics
Inspectors
MIT Safety and Health programs
Analysis of the data
The records provide the base data for the BLS Annual Survey of Occupational Injuries and Illnesses.
Statistics-used by OSHA to help direct its programs and measure its own performance.
Inspectors- use the data during inspections to help direct their efforts to the hazards that are hurting workers.
EHS where to direct efforts
Analysis of data-is a widely recognized method for discovering workplace safety and health problems and for tracking progress in solving those problems