Safety Check: Handling Employee Safety Concerns and Complaints ? Close Calls, Hazards, Injury and Illness Reporting

                Every workplace must have a means for employees to report a close call, workplace hazard, and injury or illness. It’s not just a good idea, it’s the law in the United States and many other countries!

                Under the Occupational Safety and Health Administration OSHA Act of 1970, employees have the right to a safe workplace. This law requires employers to provide employees with working conditions that are free of known dangers.

                Through the years I have found that many workplaces do not have a written policy or documentation for basic safety reporting. The close call, hazard and injury or illness report is a fundamental part of your proactive injury and illness prevention program. And it must be a written policy or else it does not exist in the eyes of OSHA.

                Simply having a safety suggestion box, as is common in many small businesses, is not enough.

                Your best eyes and ears for injury and illness prevention are your employees. When employees are permitted to voice their concerns without ramifications, they will become your best proactive injury and illness prevention component. Supervisors and safety committee members are often hindered by too much responsibility and can’t be everywhere at once. They’re also often afraid to bring up concerns because of cost factors. Employees, when permitted to report safety concerns freely, won’t have those fears.

                A proactive safety program must start from the top, and when owners and management don’t take close call, hazard, injury and illness reports by employees seriously, fail to follow up, or fail to respond to the employees concerns, it will result in negative circumstances to your safety program and employee morale. It may also result in an unplanned visit from an OSHA compliance officer, potential fines and higher workplace insurance rates. One of the best ways to initiate a surprise OSHA inspection is to ignore safety complaints from workers.

                It is best that your safety program administrator and the safety committee receive a copy for immediate review of any situation identified by workers or managers. Those personnel can meet with the employee, and make recommendations to management on how best to address the concern.

                OSHA recommends that employees report their concerns to their employer first, but when the employee feels that their reports are not being taken seriously or the employer fails to do anything about it, they can report it directly to OSHA.

                OSHA standards state, “Workers may file a complaint to have OSHA inspect their workplace if they believe that their employer is not following OSHA standards or that there are serious hazards.”

                Federal laws protect employees from any possible reprisals from employers under the whistleblower statues. It is a violation of the OSHA Act for an employer to fire, demote, transfer or discriminate in any way against a worker for filing a complaint or using other OSHA rights. It is commonly believed among safety experts that an incident will happen three times before and injury or illness occurs. If this theory is even 50% correct, a close call, hazard, injury and illness reporting policy can prevent 50% of your accidents. And every incident you have will cost you money and lost productivity.

                Let’s define the meaning of close call, hazard, injury and illnesses in respect to reporting procedures:

                • Close Calls are any event that happens in the workplace that could have caused an injury or illness. For example, this includes when an employee slips on the wet surface of the entry flooring, but does not fall or get injured.

                • Hazards are any practice, task, procedure, machine, equipment, tool, other worker, or safety concern that an employee feels is a workplace hazard that may result in an injury or illness. A basic example would be when snow is tracked in by personnel when entering the building. After heating, it becomes water pooled on the concrete floor, resulting in a slip hazard. OSHA defines a hazard as anything that creates the potential for harm. In practical terms, a hazard often is associated with a condition or activity that, if left uncontrolled, can result in an injury or illness.

                • Injury is any event in the workplace that has resulted in a physical injury that may or may not require medical treatment. For example, a worker slips on a wet concrete floor, falls and bruises his/her elbow, but may or may not want to seek medical treatment.

                • Illness is any event in the workplace that results in an acute or chronic condition or disorder. OSHA Standard 29 CFR 1960.2(l) defines an injury and illnesses as an abnormal condition or disorder. Injuries include cases such as, but not limited to, a cut, fracture, sprain or amputation. Illness includes both acute and chronic illnesses, such as, but not limited to, a skin disease, respiratory disorder, or poisoning.

 

Required Documentation

                Documentation is a necessity for a proactive workplace safety program. It is the basis for directing company procedures and is critical if you need to defend company practices to OSHA or state officials. If you don’t document it, there is no use in doing it. When an OSHA compliance asks for proof, your word is not going to suffice. So, document, document, document.

                The close call, hazard, injury and illness report serves numerous purposes, examples include, but are not limited to: provides documentation for safety committee review and areas needing focus, makes all employees part of your injury and illness prevention program, and reduces workplace injuries and illnesses. After employees have received hazard awareness training, they can all identify hazardous conditions, report them, and the concern can be addressed previous to an accident or injury taking place.

                Documentation provides visibility for your entire organization because management may not see the hazard or incident in person. It is a crucial tool for use in investigating workplace injuries and illnesses while providing management with ideas for proactive safety training and improvements.

                Documentation also gives management a tool to track and identify workplace trends, such as common hazards, problem activities, plants with higher incident rates, etc. Proper reporting assists in the prevention of false worker compensation claims. This makes it difficult for a false claim to be accepted, if there was never any reporting of an injury or illness by the employee.

                Employers should documents incidents that do not require initial medical treatment. Many times employees are injured, or become ill, but do not have the need to seek immediate medical attention. Then, at a later point, if the condition merits medical attention, you have documentation of the actual incident. You want to make sure that your procedures are in compliance with OSHA standards.

                In the end, it pays to have appropriate documentation in place. This process can help reduce costs associated with workplace injuries and illnesses, such as OSHA citations, equipment damage, time loss, and worker compensation insurance rates.

               

Written Policy and Procedure

                Generally, it is required that your policy call for all reports to be made in writing and given to a supervisor immediately. There are times when immediate reporting is not possible, such as remote work locations, but these reports must be made no later than the end of their work shift.

                The policy needs to be in writing, employees must receive documented training on the procedures, and the procedures must be posted throughout the workplace.

                The following is an example written policy and procedure: In the event of a workplace close call, hazard, injury or illness, the steps listed below are required to properly document the event or hazard. Note: In cases of severe injury or medical emergency medical assistance is paramount, call 911, or seek medical assistance immediately.

                1. Complete a workplace close call, hazard, injury and illness report for all close calls, identified hazards, and for any events whether they require medical attention, or they do not. For events not requiring medical attention complete steps 1 and 2. For all events requiring medical attention, you will need to complete all steps.

                2. Report the incident to your supervisor immediately. 

                3. Notify the office and management of the event prior to the end of your shift.

                4. The following is an example list of facilities and numbers that can be used when the injury or illness requires medical attention. These are provided for informational purposes only, the law allows employees to go to a facility of their choice.

Facility name                 Phone

____________           _____________

____________           _____________

____________           _____________

                5. Notify the medical facility that this is a work-related injury or illness.

                6. Request a work release to inform your employer of your return to work status. (Essential).

                7. Contact the office to update them on your injury status and your return to work status.

                8. Complete an incident report, an 801, and other insurance provider required forms.

                9. Assist management in a workplace injury or illness investigation.

                10. For assistance or information regarding these procedures

contact:_______________________

 

Close Call, Hazard, Injury and Illness Reporting Form

                The reporting form doesn’t need to be long, nor confusing. It should consist of the following information:

                • Name of person that experienced the close call, found the hazard, or became injured or ill due to a workplace related event.

                • Date and time

                • Where it occurred

                • Type of injury or illness and what body parts were affected

                • Type of hazard or what they felt caused the incident

                • Witnesses

                • A place for a signature

                The form and policy information provided is an example only and may not be complete for every workplace situation. You can obtain free information from your state or the federal OSHA website, from your worker compensation insurance carrier, or from your local OSHA office.

                The following web site link provides a few OSHA example forms:  http://goo.gl/qy2vfh

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Jary Winstead,

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Pallet Enterprise November 2024