Solving Accident Investigation Problems: Thorough Accident Investigations Can Be One of the Most Valuable Exercises That Companies Undertake, Yet Too Few Have Policies and Programs in Place to Carry Them Out
Hartshorn, Dan, Occupational Hazards
Many employers have not established comprehensive accident investigation policies. Even among those who have, many never actually follow through with in-depth investigations.
An effective investigation program should fulfill legal requirements, discover the significant factors that contributed to each accident and protect the employer from legal problems. You should re-evaluate your accident investigation practices if any of the following situations are allowed to occur:
* Accident investigations are not done for all accidents. This deprives the employer of potentially critical information necessary for the prevention of future accidents.
* Employees do not believe that investigations will detect fraudulent claims for workers' compensation. If the employer makes it too easy for employees to lie, some will take advantage of the opportunity.
* Accident investigations only identify what happened; the underlying causes of the accident are not identified. If the root causes of an accident are not identified, only superficial solutions can be considered.
* OSHA-required accident investigations are not done. Most employers have a legal responsibility to do at least some form of accident investigation.
* The appropriate confidentiality of investigations is not maintained. The release of some confidential accident information may suggest employer fault that can result in lawsuits against the employer.
Employers subject to OSHA recordkeeping requirements have to conduct accident investigations for all OSHA recordable injuries. The new regulations, which became effective last January, even specify the type of questions that must be asked when doing an investigation. Not all employers are subject to this new regulation. Employers with 10 or fewer employees and certain industries are exempted. The federal recordkeeping regulations and downloadable forms are available at the following Web site: www.osha-slc.gov/record keeping.
Some states have additional laws that relate to accident investigations. For example, in California, accident investigations are a required part of every employer's "Injury And Illness Prevention Program" (General Industry Safety Order 3203 (a)(5)).
Types of Investigations
An accident investigation policy should be clear, comprehensive, reasonable and followed. The meaning of the term "accident" needs to be clearly defined. What is undoubtedly an accident to a loss control professional may not seem like an accident to others. For example, if a worker drops a hammer from a scaffold and it doesn't cause an injury or any property damage, many people would think that an accident has not occurred. However, the employee will lose some time retrieving the hammer so an adverse event (an accident) has occurred. We can define an "accident" as: "any unplanned event that causes injury, illness, property damage or harmful disruption of the work process."
There are different types of accident investigations. An "incident report" should answer the four basic "W" questions of who, what, where and when. With a minimum of training, the immediate supervisor can relatively easily and quickly complete an incident report. An incident report may later be used as part of the information collected for a more in-depth accident analysis. The OSHA Form 301 is an example of an incident report.
Doing an "accident analysis" involves more time and skill than an incident report because it attempts to answer the more difficult question of why the accident occurred. The why is the all-important fifth "W" question. (A "Sample Accident Analysis Form" is provided on www.occupationalhazards.com).
Some accidents are so serious that a " professional accident investigation" is needed. An employer should only allow a professional investigator to do an investigation if the seriousness or circumstances of the accident create the potential for litigation. …