Reporting Work-Related Injuries And Illnesses

Are you aware that OSHA requires that you establish a procedure for the reporting of work-related injuries and illnesses? 29 CFR 1904 Recording and Reporting Occupational Injuries and Illness states that you must set up a way for employees to report work-related injuries and illnesses promptly, and you must tell each employee how to report work-related injuries and illnesses to you. You can’t just simply tell employees they have to report injuries.

One way to meet this requirement and to also gain other benefits is to develop a written Accident Reporting, Recording and Investigation procedure. In such a procedure you want to establish a well-defined prompt reporting requirement and specific directions on how reporting is to be accomplished for all work-related injuries and illnesses. If you have such a procedure or you have a need to develop one, you may want to take your written program one step further and require that “Near Miss” incidents, property damage accidents, motor vehicle accidents and environmental emergencies be included in the written program.

The written program requirements, as they apply to the employees reporting work-related injuries and illnesses, should be reviewed with all employees periodically and also be included in the orientation of new hires. This type of review would meet the requirements of the regulation. The regulation does not require that you document the reporting procedure review with employees, but documentation is always helpful when and if questions arise.

But looking beyond just meeting the requirements of the regulation, there are other benefits to be gained by having such a written program. It will help ensure that all accidents and incidents are reported promptly so they can be investigated in a timely manner; immediate temporary controls can be put in place, as required; prompt medical attention can be provided, if necessary; workers’ compensation claims will be filed timely; OSHA recordkeeping and reporting requirements can be met; other local, state and federal agencies can be notified, as required; and it will help eliminate late reports of injuries and illnesses that are sometimes suspect.

Written Program Content
Below are some of the content items that you may want to consider including in a written Accident Reporting, Recording and Investigation Program.

  • Detailed description on how and to whom employees are to report accident/incident. This should cover all possible scenarios.
  • What type of accidents/incidents are covered in the program.
  • Specific time requirements established for employees to report accident/incident.
  • Identify responsibilities of managers, supervisors, safety personnel and employees.
  • What are the internal management notification requirements. (Chain of Command)
  • Who takes the lead in investigating accident/incident.
  • When must the investigation begin.
  • ho participates in the investigation.
  • How much time is allowed to complete the investigation.
  • Who reviews and approves the investigation.
  • How corrective actions from the investigation are tracked until completed.
  • What is the distribution of completed accident/incident investigations.
  • Who initiates workers’ compensation claims and how and when the responsible party is informed.
  • Who manages the OSHA 300 Series Recordkeeping Requirements and how and when the responsible party is informed of recordable injuries or illnesses.
  • Who is responsible for notifying OSHA within eight hours for workplace fatal heart attacks, fatalities or the hospitalization of three or more employees from a single incident.
  • Who notifies employee’s family if a serious injury occurs and the injured employee is unable to communicate with the family.
  • Who is responsible for maintaining communication with family beyond initial notification and providing assistance to family members.

Some companies may require a more comprehensive program than the suggested content items offered above, while others a less comprehensive program may be appropriate. The important point is to have a program that meets your specific needs so important function responsibilities are understood and tasks are accomplished in a timely manner.

Gases and Welding Distributors Association
Meet the Author
GAWDA OSHA & EPA Consultant Thomas W. Eynon is senior associate at B&R Compliance Associates LLC, based in Merritt, North Carolina. Members can reach him at (252) 745-7391 and at tom.eynon@brcompliance.com.