EHS mission: to assure safe and healthful working conditions for the MIT community. OSHA CFR MIT EHS
OSHA Injury Reporting Joe MacLeod & Suzanne Adams
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
Incidence Rates of Recordable Injuries and Illnesses
MIT Incidence Rate of Cases with Days Away from Work
Roles and Responsibilities Employee Supervisor DLC Coordinator EHS Lead Contacts Medical Provider HR Worker’s Compensation OSHA Recordkeeping
Employee Notify supervisor Seek treatment Provide medical documentation to supervisor Communicate work status Provide information on potential hazard/s in the workplace
Supervisor 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”
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?
DLC Coordinators/EHS Lead Contacts Investigate trends repetitive strain, lifting, frequent fliers, facility knowledge Notified immediately via e-mail 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)
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
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
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.
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
Work-Related? YES 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 NO (9 Exceptions) 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
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
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.
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.