As an employer, there are a number of tools that can be utilized in determining hazards, accident trends, and mechanisms of injury specific to your industry. These tools are all free and easy for an employer to use.
The following are tools that a safety committee, and or company management, can use to identify incident and accident trends in the workplace:
• Close Call, Hazard and Incident Reports
• Bureau of Labor and Statistics Reports
• OSHA 300 and 300A forms
Through the years we have discussed the importance of proper reporting procedures. Employers are required to provide their workforce a method for reporting close calls, hazards, and workplace injuries and illnesses. For more information, see an article in the Pallet Enterprise from 2014. Available at this web address: http://palletenterprise.com/view_article/4286/Safety-Check:-Handling-Employee-Safety-Concerns-and-Complaints-%E2%80%93-Close-Calls,-Hazards,-Injury-and-Illness-Reporting
Encouraging employees to report close calls and hazards to management can help prevent future hazardous situations. Many believe that an incident will happen three times prior to an actual accident occurring. It is certainly true that when you see a number of reports of close calls, hazards or incidents related to the same job task, you can bet that there will be an accident in the future if the root cause is not addressed.
What is the difference between an “Incident” and an “Accident?” Some make a distinction between accident and incident, and others use the terms interchangeably. Most safety professionals, including myself, use the terms in the following manner:
The term incident can be defined as an occurrence, condition, or situation arising in the course of work that resulted in or could have resulted in injuries, illnesses, damage to health, or fatalities.
The term “accident” is also commonly used, and can be defined as an unplanned event that interrupts the completion of an activity, and that may (or may not) include injury or property damage. They use the term incident to refer to an unexpected event that did not cause injury or damage that time but had the potential. “Close call” or “Near miss” are also terms for an event that could have caused harm but did not.
Employees have the right to report unhealthy and or hazardous working conditions, and are protected by federal law from retaliation. As a reader, you may also remember the past article
in Pallet Enterprise from 2017; Safety Incentives, Discrimination, and Whistleblower Protection. This article is available via the following web address: https://tinyurl.com/ybrodh8t
Your safety committee should always be looking at incident trends related to your workplace and pass this information along to management. Obviously, your workplace’s trends are the most accurate and specific to your hazards. This is why you must encourage employees to report unsafe conditions or practices. Unfortunately, many employees will hesitate to do that worrying about company reprisals or even blowback from other employees. But employees need to know the company prefers to know about hazards in advance. The sooner a hazard has been addressed, the less likely the hazard will result in an accident.
An employer recently contacted me regarding a rise in incident frequency. The incident rates had increased to five per month from the close call, hazard and incident reports gathered. The employer had also found an increase in workplace injuries and illnesses that mirrored the national statistics.
After reviewing the workplace’s incident trends, addressing the reported hazards, and having an all-employee meeting that further encouraged employee reporting, and the management reassuring its commitment to safety, the incident frequency fell to less than one per month. What was the main reason for the high frequency of incidents? Although the safety committee reviewed the reports, management failed to act on the committee’s recommendations, and the hazards were rarely addressed. Fortunately, there had been no serious injuries resulting from the high frequency rates. This employer addressed the trends in the nick of time.
Frequently an employer will have a number of accidents before management realizes what has gone wrong. Most employers are missing the fundamental policies and procedures for close call, hazard and incident reporting. This employer had the policies and procedures in-place, the employees were doing their part, the safety committee was doing theirs, but management was failing to fix problems and ensure compliance.
Another tool in determining incident trends within your industry is data from the Bureau of Labor and Statistics (BLS). The BLS provides annual reporting of statistics gathered from the nation’s workforce, including in-depth data of all reported injuries and illnesses in the workplaces of the United States.
The BLS provides statistics for most industries, including the pallet manufacturing sector. This information is listed under Wood Container and Pallet Manufacturing, with a North American Classification System (NAICS) code of 32192. The reports are commonly released toward the end of the following year, and are updated as studies are released.
The Total Case Incident Rate (TCIR) is defined as the number of work-related injuries per 100 full-time workers during a one-year period. OSHA uses the TCIR to monitor high-risk industries. Those industries that fall under the high-risk sectors will have a higher OSHA compliance inspection rate. Under the category of Wood Container and Pallet Manufacturing, the 2017 statistics show a TCIR rate of 8.3 per 100 full-time employees working a 40 hour work week.
The TCIR is a good way to determine how you rate against others in your sector. TCIR rates have fallen through the years, with an average of 3.1 throughout all sectors in 2017. A rate of 8.3 per 100 for the Wood Container and Pallet Manufacturing sector falls under the higher risk industry sectors.
You can calculate your TCIR by using the following formula:
(Number of OSHA Recordable injuries and illnesses X 200,000) / Employee total hours worked = Total Case Incident Rate
To break this formula down, employers multiply the number of OSHA Recordable injuries and illnesses occurring throughout the year by 200,000. This 200,000 represents 100 employees working 40 hours a week for 50 weeks during a calendar year. Then, this number is divided by the total number of hours a company’s employees worked. Your company’s federally required record keeping forms, OSHA 300 and 300A, have this information available for calculating. We will discuss OSHA record keeping in further detail in a moment.
Your worker compensation insurance rate is determined by the NAICS code assigned for your sector of industry. A sector with a high TCIR will have a higher worker compensation rate, and if your workplace is higher than average for your sector, this will result in higher modification factors for your worker compensation rates.
The BLS statistic reports can be found at the following web address:
https://www.bls.gov/iif/oshsum.htm#17Summary_News_Release
This page will provide in-depth data regarding the types of injuries and illnesses, mechanisms of injury or illness, body parts affected, age groups, employment lengths, days away from work, and days of restricted or modified work. It will take a person a while to manipulate their way through all of the data and tables, but the information is valuable in injury and illness prevention.
With the beginning of 2019, it’s time once again to complete your OSHA required injury and illness record keeping forms 300 and 300A for injuries and illness in 2018.
According to OSHA requirement you must record information about every work-related death and about every work-related injury or illness that involves loss of consciousness, restricted work activity or job transfer, days away from work, or medical treatment beyond first aid. You must also record significant work-related injuries and illnesses that are diagnosed by a physician or licensed health care professional. You must also record work-related injuries and illnesses that meet any of the specific recording criteria listed in 29 CFR Part 1904.8 through 1904.12.
OSHA also requires an investigation to be completed for each recordable injury or illness. If you do not have a formal investigation form, the OSHA form 301 is provided for this purpose. You must complete an Injury and Illness Incident Report (OSHA Form 301) or equivalent form for each injury or illness recorded on this form. The injury or illness must be recorded, unless it was proven by a medical professional, insurance investigation, or OSHA, that it never occurred, or did not occur at work.
Keep in mind, that the information on the OSHA 300 protected under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and cannot be shared with anyone, unless OSHA or your worker compensation insurance provider requires it. This is why OSHA requires that the 300A form be posted, and not the 300 Log.
The forms are quite simple to complete:
A = The number or letter assigned to the injury or illness
B = First initial, and last name of the employee
C = Job title of employee
D = Date the injury or illness occurred
E = Specifically where the event occurred
F = Brief description of injury or illness, and body part affected
G = Check if the injury or illness resulted in a death
H = Check if the injury or illness resulted in days away from work that were required by a physician.
I = Check if the employee was restricted by the physician for any tasks. Example: weight restrictions, hour limitations, restrictions of use of body part, or limited from certain physical tasks
J = Check if the injury or illness was recordable, but had no days away from work, job transfer, or limitations
K = Total number of work days that a physician restricted the worker from working
L = Total number of work days that required transfer, modifications, or limitations from their regular job task
M = Type of injury or illness
In the event that you’re unsure of the days away from work, job transfer, modification or limitations, the paperwork provided by the physician will have this information.
These key pieces of information are crucial to assess dangers and employee readiness to work. This is why you must require employees to bring written instructions regarding the injury or illness back to human resources, or management when returning from the medical visit. Never take the employee’s word for what the physician gave for instructions.
All instructions need to be in writing. The employee cannot return to work without a release from the physician, and without a statement of modification or limitations, the employer will not know what job tasks the employee can or cannot perform. In some cases, it may be necessary to provide a job description for the physician to review.
Once the section has been completed for each injury or illness, the categories are totaled at the bottom of the sheet, and this information is carried over to the 300A form.
The final section of the 300A that must be completed is the establishment information. This includes the company’s information, NAICS code 32192 for pallet manufacturing, total average annual employees, total labor hours, a company officer signature, date and contact number. The 300A must be posted in a location where employees can review it, from February 1 through April 30 of each year. Retain your 300, 300A, and investigation forms for a minimum of five years.
Editor’s Note: Jary Winstead is a safety consultant, author and trainer who serves a variety of industries including the forest products sector. He owns Work Safety Services LLC and can be reached at SAFEJARY@gmail.com.
