OSHA Injury Reporting

Heinrich accident triangle

EHS mission: to assure safe and healthful working conditions for the MIT community.

OSHA CFR MIT EHS

OSHA Injury ReportingJoe 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

7OSHA Form 301

8OSHA Form 300

9

2010 MIT Numbers

Recordable 196Incident Rate 1.9LT Incident Rate 0.93Days lost 1522*Days restricted 1344

OSHA recordable injuries / illnesses

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 impactOSHA recordability.Some cases may be OSHA recordable and compensable.Some cases may be compensable, but not OSHArecordable.

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

Is the injured person an MIT:

Faculty and Staff*+Support and Service Staff*+Post Doc. Affiliate*+Post Doc. Assoc.*+Research Asst./ Affiliate*+Technical Asst./ Assoc.*+Research Teaching Assistant*+Instructor*+

Determining Covered Employees (per 1904.31) Decision TreeJune 22, 2009

Is the injured person a:

MIT Temp.+Grad StudentVisiting StudentVisiting ScientistPost. Doc./Research FellowUnder-GradUROP/Summer Help*ContractorConsultantEmployee from Temp. Agency

The incident is OSHA Recordable

The incident is NOT OSHA Recordable

Is the person receiving an

*MIT* Stipend or on the MIT

Payroll?

No

Yes

No

*Employee work injuries eligible for MIT Workers’ Comp. Coverage+ Employees hours/totals are included in the OSHA 300A Summary & BLS Annual Survey

No

Yes

Yes

Is the person paid from any source

and is supervised on a day-to-day

basis by MIT employee?

Yes

No

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

Recordable?Did the employee experience an

injury or illness?

Is the injury

or illness a new case?

Is the injury or

illness work-related?

Does the injury or illness meet the general recording criteria

or the application to specific cases?

Update the previously

recorded injury or illness

entry if necessary.

NO

YES

YES

YES

YES

Record the

injury or illness

Do not record the

injury or illness

NO

NO

NO

General Recording CriteriaTriggers 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/gluePhysical TherapyPrescription MedicationRemoving foreign body from eye w/ more than flushing/cotton Rigid splintBroken 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.

Questions or Comments?