2 Near misses, unsafe behaviors, unsafe conditions, slips, trips, mistakes take place every day Sometimes these hazardous conditions result in somebody getting injuredBut 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 theoryHerbert William Heinrich is an American industrial safety pioneer from the 193080 years ago, Heinrich published the accident triangleEHS Mission StatementUnder 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 CFRMIT EHSMIT EHS core function is the same as OSHAUnder the Occupational Safety and Health Act of 1970, OSHA's role is to assure safe and healthful working conditions for working men and womenPoint out 190419101926
5 Joe MacLeod & Suzanne Adams OSHA Injury ReportingJoe MacLeod & Suzanne AdamsThis presentation represents a portion of the EHS management system and is represented by this diagramEveryone in this room plays a vital role in this management system
6 OSHA CFR 1904Requires employers to establish a procedure for employees to report injuries and illnessesAll 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 healthRequires specific information to be reported.Regulatory requirement black and whiteCommon sense? We all are in place to eliminate hazards and prevent injuryEmployers are prohibited from discriminating against employees who do reportDPS notification for injuries resulting in hoisting (elevator) malfunctionMIT OSHA citation 2 years ago on recordkeeping
7 Basic accident and employee information used for nationwide trending / demographics, statistics BLS survey suzanne will mentionOSHA Form 301
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 RateDays lost *Days restricted 1344400 reported injury/illnesses, 196 recorded
12 OSHA recordable injuries / illnesses Number of programs in place to drive these numbers downHR return to work programDOF 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 standardsTriage process continues to fine tune and identify the MIT workforce per OSHA guidelines
14 MIT Incidence Rate of Cases with Days Away from Work 0.93These numbers will fall as we tighten up our management of injuriesReturn to work programsModified duty / light work programs
15 Roles and Responsibilities EmployeeSupervisorDLC CoordinatorEHS Lead ContactsMedical ProviderHR Worker’s CompensationOSHA RecordkeepingThe players in the management system
16 Employee Notify supervisor Seek treatment Provide medical documentation to supervisorCommunicate work statusProvide information on potential hazard/s in the workplaceOrientationSafety committeesUnion representativesShop stewards
17 Supervisor First line of defense in the management system Ensure employee can get helpAddress hazardSubmit supervisor report of injuryInvestigate hazard and complete follow-up investigation questions*Follow the incident through until “return to work without restrictions”First line of defense in the management systemAddress hazards: Clean spills, contact cust-coach, cordon off area, contact EHS / coordinatorSuzanne is there to “remind” supervisors if they forget to trackDOF recently reviewed this responsibility and is in the process of re-training supervisors on their responsibilitiesSupervisors 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, guardingHow to prevent re-occurrence?Training, SOP (create / modify), install shieldingOther relevant information?Basis for all accident investigation is Who, What, Where, When, howSupervisors 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 placeOur goal as EHS professionals should be 0 accidents / injuriesDOF 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 addressedFacilitate completion of supervisor’s reportEnsure action items are completed (maintenance,training, procedure updates)Investigate trends repetitive strain, lifting, frequent fliers, facility knowledgePrivacy issues – 3/400 reported cases were privateSome injuries require EHS investigationsENGAGE MANAGEMENT SYSTEM-COORDINATORS MANAGE EHS ACTIVITIES IN DLC COORDINATORS MANAGE SUPERVISORS ENSURE INVESTIGATIONS ARE COMPLETE AND DLC ARE HAZARD FREEAny Questions?...Note the first bullet
20 Medical ProviderAll 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 emergenciesEmployee seeks treatment before reporting the injury to the supervisor (outside medical provider)Evaluates injury / work capability & makes recommendationsProvides documents for lost time/restrictions/return to work status for employee and supervisorMIT medical policy for work related injuries/initial evaluation
21 HR Worker’s Compensation Managed in Human ResourcesStrictly employee basedCollects all medical paperworkKeeps track of lost time and medical treatment billingRefer 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 StatusDetermine if work relatedRecordable vs. Not recordableOSHA Log (OSHA 300)Summary (OSHA 300A)Reporting to the BLS388 reports submitted196 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?YESNO (9 Exceptions)An event or exposure in the work environment either caused or contributed to the resulting conditionAn event or exposure in the work environment significantly aggravated a pre-existing injury or illnessPresent as a member of the general publicVoluntary participation in wellness program, medical, fitness or recreational activityPersonal tasks outside assigned working hoursPersonal groomingEating, drinking or preparing food or drink for personal consumption9 Exceptions but here are some common onesReports not recorded about 15% are not work related.
26 Recordable?Mention triage process – Determining work related?
27 General Recording Criteria Triggers for Recording DeathLoss of ConsciousnessDays away from workRestricted work or transferred to another jobNeedle sticks (some)Medical Treatment beyond first aidSutures/gluePhysical TherapyPrescription MedicationRemoving foreign body from eye w/ more than flushing/cottonRigid splintBroken bones and fracturesNeedle sticks-contamination by another person’s blood or other potentially infectious materialReports not recorded 80% are not because it was a first aid only.
28 NotificationEmployers 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.
30 Why are employers required to keep records of work-related injuries and illnesses? Injury and illness statisticsInspectorsMIT Safety and Health programsAnalysis of the dataThe 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 effortsAnalysis of data-is a widely recognized method for discovering workplace safety and health problems and for tracking progress in solving those problems