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February 29, 2016
Incident Tracker, analysis tool simplifies incident investigations
By Ana Ellington, Legal Editor

BLR’s Incident Tracker is a timesaving tool to track your company’s incidents, including near misses. But it can also simplify your incident investigation efforts--especially if the Occupational Safety and Health Administration (OSHA) requests that you conduct a Rapid Response Investigation, or RRI, following a report to the Agency of a fatality or severe injury.

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All incidents should be investigated, but an accident investigation should definitely be conducted after a fatality or severe injury.

Since OSHA’s new reporting requirements (29 CFR 1904.39) went into effect in January 2015, the Agency has been inundated with workplace incidents reports. In response to the influx of reports, the Agency issued an internal enforcement memorandum to help the field offices manage these reports and to decide which establishments to inspect and from which to request an RRI.

The likelihood of an employer having to report to OSHA a covered severe injury is much higher under the new rule. Specifically, the revised standard requires employers to report all work-related inpatient hospitalizations, amputations, or losses of an eye within 24 hours of the incident. The requirement to report any work-related fatality within 8 hours has not changed. However, the broad definitions for inpatient hospitalization and amputation, which now includes fingertip amputations with or without bone loss, most likely are causing the increase in workplace incidents reports. According to OSHA, the Agency is averaging about 250 new reports each week--taking up a great deal of resources. For this reason, OSHA has directed its local area offices to review and follow up on reports and determine if an on-site inspection is needed or if the Agency should send the reporting employer an RRI request.

What is an RRI
If an RRI is deemed best, OSHA will send you a letter requesting that you conduct an investigation and report back to OSHA within 5 working days. The Agency’s written letter requires that you provide it with the results of an investigation into the incident, documenting findings and corrective actions taken to protect workers. The goal of the investigation is to identify the direct or contributing causes (known as surface causes) and the underlying causes (or root causes) of the incident. According to OSHA, you can usually trace surface causes to inadequate or weak safety systems, such as policies, programs, plans, processes, procedures, or practices. These are the root causes--which always preexist surface causes.

Root cause
How do you find the root cause(s) of an accident? By repeatedly asking the question “Why” (four or five whys is a good rule of thumb), you can peel away the layers of symptoms that can lead to the root cause of an incident.
For example:

A worker is struck in the eye by a flying object.

  • Why? The machine had no guards (surface cause).
  • Why? The guards were removed (surface cause).
  • Why? To work faster (surface cause).
  • Why? Less-than-adequate training, procedures, and/or policies (root causes).

Use our incident analysis tool to help complete a root cause analysis of an incident. This form can also be used to respond to OSHA’s RRI request.

Putting it together
You can use the Incident Tracker to help you complete the incident analysis tool when conducting an investigation of a fatality, inpatient hospitalization, amputation, or loss of an eye event necessary to satisfy OSHA’s RRI request.

From the Incidents tab on the dashboard of the Incident Tracker, you can select the incident to be investigated.

The Incident Details pop-up box has all the information needed to complete the portions of the analysis tool concerning employee information as well as detailed information of the incident.

You can also add corrective actions to incident reports from the incident details pop-up box.

The corrective action section will help complete the corrective action taken of the analysis tool, also required for an RRI.

OSHA will analyze reports
When completing the RRI report for OSHA, state the known facts and not opinion or speculation. Understand that root causes identified in an employer’s report can amount to an admission of a violation, such as failure to conduct required training or to repair a faulty safety device. Be careful because your responses can be used against you by OSHA. As such, simply respond with conclusions to your investigation and corrective actions that have been taken to ensure that no future incidents will occur.

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