Incident Investigation, Reporting, and Recordkeeping
Investigation fundamentals
An incident is any unplanned event; a near miss is one that caused no harm but could have. First response: care for the injured, secure and preserve the scene, identify witnesses, and gather physical and documentary evidence before it is disturbed. Interview witnesses promptly, separately, and with open-ended questions. Determine multiple causal factors: the immediate cause, contributing conditions, and root or system causes. Methods include 5 Whys, fishbone diagrams, events and causal factor charts, and fault tree analysis. Human error is a symptom to explain, not a conclusion.
OSHA recordkeeping (29 CFR 1904)
A case is recordable if it is work-related and results in death, days away from work, restricted work or transfer, medical treatment beyond first aid, loss of consciousness, or a significant injury diagnosed by a physician or other licensed health care professional. Record on the 300 Log within seven calendar days; keep the 301 incident report; post the 300A summary February 1 through April 30; retain records five years. Report to OSHA a fatality within 8 hours; an in-patient hospitalization, amputation, or loss of an eye within 24 hours.
Traps
- Confusing reportability (a phone call to OSHA) with recordability (an entry on the 300 Log).
- Putting near misses on the 300 Log; they belong in the investigation system.
- Miscounting days away (count calendar days, starting the day after the incident).
- Confusing first aid with medical treatment. First aid includes nonprescription medication, tetanus shots, bandages and butterfly strips, hot/cold therapy, and drinking fluids for heat stress. Stitches, prescription drugs, and casting are medical treatment.
Rule of thumb: if a licensed health care professional ordered it and it exceeds the first-aid list, it is medical treatment and therefore recordable.