Easy Steps for a Successful Accident Investigation

Some companies use the term “Circle of Prevention” when following the Plan, Do, Check, Act model for their safety and heath programs. As safety is really a continuing process of improvement, the OSHA standards should only be the beginning. They may help identify many of the general hazards of general business and construction, but you and your employees should be working together to identify on-the-job hazards unique to your industry and your work areas, using formal and informal safety audits and hazard analysis.

Whether through reading OSHA standards, consulting other guidelines or making your own observations, the circumstances of the hazards in your organization must be analyzed, the problem diagnosed, a plan of action developed, and then effective corrective action taken to minimize the risks.

But for whatever reason, somehow, even with your excellent safety and health program in place, an accident happens. Now what? After all the initial work is done including securing the scene and caring for the employee, you need to conduct a thorough accident investigation in order to help prevent similar accidents from happening in the future.

How your investigation is conducted will determine in large part how useful it will be.

When to start an Accident Investigation

You must act quickly as memories get fuzzy and initial perceptions may change, other employees start talking and with that the ‘water cooler’ effect takes over. Perceptions and eye witness accounts start being influenced by the storytelling. However, even though you want to get started right away do not get locked into a deadline for completing the investigation. If you are too rushed you may reach the wrong conclusions about the root causes.

Who should conduct the Investigation?

Most minor incidents and accidents can be investigated by the supervisor who is often the person most familiar with the operation. The supervisor is also in position to implement remedial measures as necessary. More serious and complicated incidents and accidents require more expertise. A team approach that includes the supervisor, safety professional or risk manager, management representative, perhaps a safety committee member and even a human resources representative will allow for a wide range of issues to be addressed. In addition, your insurance company will certainly be involved with any serious accident.

The purpose of the Investigation is Prevention not Blame.

It is crucial to the success an accident investigation to make sure you are getting full cooperation from witnesses or those involved in the accident. Remember, the people you are interviewing may be afraid that you will blame them and react defensively or even embellish the facts if they feel threatened. It is important to make sure they understand that you are simply trying to find the factors that led to the accident so future accidents can be avoided.

Review the facts.

  • Description of the accident
  • Witness Discrepancies
  • Condition of any equipment involved
  • Environmental factors
  • Personnel issues with injured employee(s) (training, competence, attitude, past performance, alcohol/drug use, etc.)
  • Routine or non-routine task

Consider all the possibilities

  • The immediate cause?
  • Contributing factors?
  • Underlying root causes?
  • Unpredictable factors?
  • Alternative theories?

Accident Investigation Reporting

Your report should summarize the facts of the accident and events leading up to it. Include any injuries suffered from the accident, the total of all property damages and any other costs of the accident, and if “human error” was involved, this should be included in the report; however, disciplinary recommendations should not be included as part of the investigation. It is however crucial to include information about the immediate and underlying causes and definitely report any dissenting opinions if the investigation was a team effort.

Management can’t do accident prevention in a vacuum, employees need to be involved. Without their understanding and cooperation, nothing management does will really work in the long run to stop the accidents and injuries.

Updated OSHA Videos Intended To Provide Respirator Training Resources

The Occupational Safety and Health Administration (OSHA) has recently posted a series of 17 videos to help workers learn about the proper use of respirators on the job.

These short videos are intended to provide information to workers in general industry and construction.  Topics include OSHA’s Respiratory Standard, respirator use, training, fit-testing and detecting counterfeit respirators. The videos are available with closed captioning for streaming or download from OSHA’s Web site.

OSHA’s Safety and Health topics page on Respiratory Protection also includes additional training materials, information about occupational respiratory hazards in different industries, and details of OSHA’s Respiratory Protection Standard (29 CFR 1910.134 and 29 CFR 1926.103).

Near Miss Safety Incidents Are Learning Opportunities

Have you ever been involved in an accident investigation where the contributing factors of the accident happened before but weren’t reported?   After one such serious accident involving work on live switchboards that resulted in explosions that caused extensive damage and one forced the closure of an elementary school for a day, the following was quoted in an ABC news report.

“They were very, very lucky indeed. There was a similar incident on the mainland where a person received severe burns to his face working on a live switchboard and that person has been in hospital for months and months and will probably never work again.”

If you were asked to define what a near miss is what would you say? A close call where no one was injured but may have resulted in property damage?

A near miss safety incident is undoubtedly a “do over” without an injury.   However near misses must still be reported and the unsafe situation corrected in a timely manner and they should be used as a learning experience.

Here are some real life examples of near misses.

  • A forklift tipped over while carrying a load that shifted on an uneven work surface.  The driver escaped without a scratch by staying buckled inside the cage.
  • A mechanic working under railcar had just stepped away when the car was struck by another railcar being positioned on an active work track.
  • A forklift ran over a welder’s foot which was protected by his steel toed boots when the driver backed up and did not see him walking behind his lift.

Reporting of a near miss and the subsequent investigation will more than likely reveal unsafe acts and conditions that will need to be corrected.  Near miss incidents that are severe in nature should receive as much attention and corrective action as an actual accident / injury.  But it is difficult to get everyone to report near misses.

Reasons Why Our People are Reluctant to Report

  • There is no system for near miss reporting.
  • Workers believe that their supervisors will hold such near miss reporting against them.
  • Generates additional work,  i.e., paperwork, subsequent investigation, etc.
  • Supervisors and/or workers have not been instructed how to report near misses.
  • Once reported nothing is done to address or correct what caused the near miss.
  • Upon reporting there is no follow-up
  • Near misses are so frequent that they become common place and part of the everyday work life
  • Employees may fear a possible job loss or be penalized if they are found to be a contributing factor of the near miss incident.
  • Workers have the mindset that being safe in the workplace also includes being lucky.

It is important to report and follow up on near misses because you can’t predict severity in accidents.  While zero accidents is a possibility, zero risk isn’t.  It is impossible to completely engineer out all of the risks so you must continue to work to identify those hidden risks and develop ways to minimize the exposure, and reporting and investigating near misses is a critical part of this process.

It is also important to look beyond employee behavior/actions, if this is found as a “root cause” or contributing factor.   Many people will stop there because they can’t answer the “Why Question”.  In reality though if one person feels encouraged to take a risk, usually others are as well.   It is important to look at your organization’s cultural aspects during an investigation/analysis.   When the culture supports the measurement and understands why they need to investigate near misses, an in depth analysis can be a very positive thing.

EPRCA Tier II Reports born from Tragedy

In the early morning of December 3, 1984, a Union Carbide plant near Bhopal, India released approximately forty tons of Methyl Isocyanate (MIC) into the air. The gas quickly spread over the ground and, in the end, killed upwards to 5,000 people and injured 50,000 more. The other place that Union Carbide manufactured MIC was at its Institute plant in West Virginia. Following the Bhopal release Union Carbide elected to shut down production of the deadly chemical at its West Virginia location until it could make $500 million worth of safety improvements.

New Safety Programs

Approximately four months after completion of the safety improvement program, 500 gallons of highly toxic aldchiloxin (and MIC) leaked from the plant. Although no one was killed, 134 people living around the plant were treated at local hospitals.

Both the Bhopal and West Virginia incidents highlighted the serious nature of modern-day chemical production — no matter what safety precautions are taken, no matter how well trained a plant’s employees may be, and no matter how prepared a plant may be to handle an emergency situation, accidents can still occur and people may die.

Congress Acts

With thousands of chemical accidents occurring in the United States within a five year period in the mid-1980s, Congress passed the Emergency Planning and Community Right-to-Know Act (EPCRA) in 1986, ushering in a new wave of regulations and reporting requirements designed to alert the surrounding communities of the dangers posed at chemical facilities in the U.S.

To implement EPCRA, Congress required each state to appoint a State Emergency Response Commission (SERC). The SERCs are required to divide their states into Emergency Planning Districts and to name a Local Emergency Planning Committee (LEPC) for each district.

The facilities covered by EPCRA requirements are now required to submit an Emergency and Hazardous Chemical Inventory Form to their LEPC, as well as their SERC, and their local fire department annually by March 1st.

The reports known as “Tier II Reports,” require basic facility identification information, employee contact information for both emergencies and non-emergencies, and information about chemicals stored or used at the facility.
Under the EPCRA, SERCs and LEPCs are charged with four primary responsibilities:

  1. Write emergency plans to protect the public from chemical accidents;
  2. Establish procedures to warn and, if necessary, evacuate the public in case of an emergency;
  3. Provide citizens and local governments with information about hazardous chemicals and accidental releases of chemicals in their communities; and
  4. Assist in the preparation of public reports on annual release of toxic chemicals into the air, water, and soil.

Tier II Reporting Information

What facilities are covered?

  • Any facility required under Occupational Safety and Health Administration (OSHA) regulations to maintain material safety data sheets (MSDSs) for hazardous chemicals stored or used in the work place. Facilities with chemicals in quantities that equal or exceed the following thresholds must report:
  • For Extremely Hazardous Substances (EHSs) , either 500 pounds or the Threshold Planning Quantity (TPQ), whichever is lower
  • For gasoline (all grades combined) at a retail gas station, the threshold level is 75,000 gallons (or approximately 283,900 liters), if the tank(s) was stored entirely underground and was in compliance at all times during the preceding calendar year with all applicable Underground Storage Tank (UST) requirements at 40 CFR part 280 or requirements of the State UST program approved by the Agency under 40 CFR part 281.
  • For diesel fuel (all grades combined) at a retail gas station, the threshold level is 100,000 gallons (or approximately 378,500 liters), if the tank(s) was stored entirely underground and the tank(s) was in compliance at all times during the preceding calendar year with all applicable Underground Storage Tank (UST) requirements at 40 CFR part 280 or requirements of the State UST program approved by the Agency under 40 CFR part 281.
  • For all other hazardous chemicals, 10,000 pounds.

Tier2 Submit Software

  • EPA has recently developed ‘Tier2 Submit,’ an online software program designed to help facilities prepare an electronic chemical inventory report. Although many states accept Tier2 Submit, some states such as Missouri do not.

Certification

  • The owner or operator or the officially designated representative of the owner or operator must certify that all information included in the Tier Two submission is true, accurate, and complete.

Penalties:

  • Any owner or operator who violates any Tier II reporting requirements shall be liable to the United States for civil penalty of up to $27,500 per day for each such violation.
  • Although each day a violation continues shall constitute a separate violation it has been EPA’s policy not to enforce the daily penalty on those companies making a good faith effort to come into compliance with the reporting requirements.

For more information on EPA Tier II reporting requirements visit their website.  Specific state requirements links can also be found there.

OSHA 2013 Budget Request Unchanged From 2012

The U.S. Department of Labor today outlined its part of the president’s fiscal year 2013 budget request to Congress, which according to DOL focuses on efficiently achieving the department’s goals while exercising fiscal restraint.    See Summary below:

For information on the president’s FY 2013 budget request for the Department of Labor, visit http://www.dol.gov/budget.

 

Recruit Safety Champions to Reduce Workplace Accidents

During a particular busy work shift you see a heavy object fall off a ledge or shelf and thud to the floor a foot or so away from a coworker. Whew…no harm, no foul.  Right?  Consider this Seventy-five percent of all accidents are preceded by one or more near misses, according to the National Safety Council.

There is a serious real-life danger in near misses that don’t result in damage to persons or property, because of the tendency to think of them like a Hollywood horror movie; scary for a few moments, but with no real harm done.  This is a dangerous attitude though; if you don’t notice and correct whatever condition or behavior that caused the close call, it’s very likely that there will be further close calls, some minor accidents, and finally-with just the right combination of circumstances, there may be a very serious or fatal accident.

What is a near miss?

“Near misses” can be defined as minor accidents or close calls that have the potential for property loss or injury.  A near miss will prevent a task from being completed as planned.   Most accidents can be predicted by close calls.  These are accidents that almost happened or possibly did happen but simply didn’t result in an injury this time around.

What is an accident?

An accident is an unplanned, unexpected event that interferes with or interrupts normal activity and potentially leads to personal injury or dollar loss, including equipment damage.  Accidents have two things in common. They all have outcomes and they all have contributory factors that cause the accident.

There are numerous negative outcomes of accidents including injury and possible death, damage to equipment and property, litigation costs and possible citations, lost productivity, and morale issues. However from that, positive outcome from accidents can include an accident investigation which identifies key issues that can lead to prevention of recurrence, changes to existing safety paradigms which can lead to changes to policies and procedures, and changes to equipment design.

The seven deadly sins (workplace accidents):

  1. Falls to the same or lower level;
  2. Contact with chemicals, electricity, heat or cold;
  3. Caught in, on, or between;
  4. Bodily reaction from voluntary or involuntary motion;
  5. Struck against a stationary, moving, or protruding object or a sharp or jagged edge;
  6. Struck by a moving, flying, or falling object; and
  7. Rubbed or abraded by fiction, pressure, or vibration.

Obviously every close call or accident is a call for action.  Sometimes its cause can be easily fixed.  In other cases, the whole system may need a major revision. But near misses and accidents should never be ignored.  Make your employees “accident aware” by informing them of what the organization is doing to prevent accidents.

As working safely often means looking out for each other, it is no wonder that  employee involvement is the key to reducing accidents.  There are several ways to accomplish this, including providing opportunities to give voice to the needs and concerns of your frontline employees.  Consider recruiting employees from across multiple areas of your company to be safety champions, and design multiple communication strategies for them including using internal blogs, group email, safety newsletters, e-learning and classroom training, as well as encouraging the development of live forums or town hall meetings to further training efforts and to share success stories and shared challenges.

Ways to Reduce Accidents

  • Obtain top level management support for accident prevention
  • Perform a hazard analysis for each job
  • Review the use of hazardous chemicals
  • Study and evaluate the layout of workstations
  • Analyze your worker’s duties for ergonomic risks
  • Review your worker’s behavior and pay attention to their attitudes
  • Recruit your front line supervisors for safety initiatives
  • Complete regular safety checks of all equipment
  • Inspect your facility for layout and environmental hazards
  • Review and keep your worker training program current
  • Always enforce safety rules
  • Make the changes necessary to reduce hazards

As your workers and supervisors cooperate with these programs, stay alert for hazards, and follow reporting instructions, they will be able to avoid most accidents in the workplace.

OSHA Logs Must Be Certified By An “Executive of the Company” Is that You?

“The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) recently cited the Lowe’s Home Centers Inc. regional distribution center in Rockford, Illinois with $182,000 in penalties for failure to document and report employee injuries and illnesses, as required by OSHA safety and health regulations.”

That got your attention didn’t it?

 

There should be no doubt about it, OSHA takes record keeping very seriously.   Remember, it’s not about the paperwork itself, its about the information on the paperwork.   OSHA doesn’t have an army of compliance officers to constantly check in on every employer so they must rely on the employers themselves to self-report on injuries and illnesses.

To OSHA the lack of proper paperwork demonstrates a lack of respect for safety and raises reasonable doubts as to the employers commitment to safety.   So do yourself and your employees a favor and keep up on your record keeping requirements.

According to OSHA 1904.32(b)(5) You must post a copy of the annual summary (OSHA 300-A Log) in each establishment in a conspicuous place or places where notices to employees are customarily posted.   You must ensure that the posted annual summary is not altered, defaced or covered by other material.   Everyone knows that…right?

Did you also know that the OSHA 300 Log must be certified as accurate by a company executive?   Did you know that most safety managers, supervisors, directors, and/or coordinators do NOT qualify as an executive?

According to the OSHA, The company executive who certifies the log must be one of the following persons:

  • An owner of the company (only if the company is a sole proprietorship or partnership);
  • An officer of the corporation;
  • The highest ranking company official working at the establishment; or
  • The immediate supervisor of the highest ranking company official working at the establishment.

If as a safety manager, director, or supervisor you meet one or more of these definitions, then I congratulate you on a career well done!   But for the rest of us, we need to make sure that a company executive certifies the OSHA 300 log.   The company executive must certify that they have examined the OSHA 300 Log and that they reasonably believe that the annual summary is correct and complete.
Employers must post the summary no later than February 1 of the year following the year covered by the records and keep the posting in place until April 30.When do I have to post the annual summary?

Who Must Maintain the OSHA 300 Log?

All employers with 11 or more employees in the selected industries, as determined by their SIC and/or NAICS classification (e.g., Agriculture, Oil and Gas, Manufacturing, Construction, Transportation, General Merchandise Stores, Hospitality, and Health Services), must keep injury and illness records.

Some employers are normally exempt for these recordkeeping requirements, such as Retail trade, Financial, Banking, Insurance and Real Estate sectors.

Employers who operate establishments that are required by the rule to keep injury and illness records are required to complete three forms: the OSHA 300 Log of Work-Related Injuries and Illnesses, the annual OSHA 300A Summary of Work-Related Injuries and Illnesses, and the OSHA 301 Injury and Illness Incident Report.

Employers are required to keep separate 300 Logs for each establishment that they operate that is expected to be in operation for one year or longer. The Log must include injuries and illnesses to employees on the employer’s payroll as well as injuries and illnesses of other employees the employer supervises on a day-to-day basis, such as temporary workers or contractor employees who are subject to daily supervision by the employer.

OSHA Slashes Number of Online Trainers and Encourages Enrollment at OTI Ed. Centers

The Occupational Safety and Health Administration (OSHA) announced earlier this month, its selection of only 10 OSHA authorized training providers out of the hundreds of applicants to deliver online courses as part of its Outreach Training Program.  Although more than 135,000 workers were trained online in 2011, which represents a five-fold increase from the number of online students trained in 2007, OSHA dramatically curtailed the overall number of online training providers available for prospective students to chose from.

Of the newly anointed 10 authorized providers, only two are non-profits or Universities, with the bulk of the providers being private for-profit companies.   Several high profile online providers who previously offered OSHA online Outreach courses were not selected by OSHA including, The University of South Florida, 360Training.com, Coastal Training Technologies, Summit Training Source, and Redvector.

Not all of the new providers that OSHA authorized even have currently available programs, according to OSHA.  Those organizations must still work on building an acceptable program in order to receive a full blessing from OSHA. So the overall number of online course providers may get smaller in the coming months.  In an email received from Mr. Don Guerra, OSHA Program Manager, OSHA continued to recommend that prospective students “compare program offerings and pricing from multiple providers” in order to determine which one best meets their training needs.  However given this latest round of cuts to available online providers, it is highly probable the cost for this online training will rise dramatically for prospective students and employers given the lack of competition in the marketplace.

OSHA also continues to encourage  students to consider taking classroom training instead of online courses.   Which of course, are being offered  and marketed by the OSHA Education Centers around the country in direct competition to private and public classroom training providers.   Although no direct link has been suggested between the slashing of online providers and the encouragement to go to the OSHA Ed. Centers; a clearer message could not have been received!

See the January 12, 2012 news release on new online Outreach Training Program selections.

New and Currently available programs 

Programs that will no longer be available after March 31, 2012 

 

Developing an Energy-Efficient Workplace Culture

Nobody knows your business’ energy using activities and processes better than your employees. Therefore establishing an energy saving culture is critical to support other waste saving initiatives such as an energy saving plan. By establishing an energy saving culture, you can create an environment for bright ideas, increased efficiency and reduced operating costs. Such was the focus of a report released early this month by the American Council for an Energy-Efficient Economy (ACEEE). Programs aimed at reducing building energy use through change in employees’ attitudes and behaviors, such as those instituted at the House of Representatives and the Empire State Building, can help build an energy-efficient office culture.

The report looked at multiple behavior case studies across the U.S. and Canada, including the “Tenant Energy Management Program” in the Empire State Building; “Conservation Action!” at BC Hydro, Canada; an energy behavior campaign undertaken at a provincial governmental building in Canada; and the “TLC-Care to Conserve” program at the University Health Network of the University of Toronto.

Four common intervention approaches were shared by the five energy behavior programs:

  1. Setting the tone with the support of upper management and its public pledge;
  2. Building a team with a project committee and peer champions on board;
  3. Utilizing communication tools such as e-mails, prompts, Web sites, public meetings, and posters to reach target audiences; and
  4. Engaging building occupants by means of feedback, benign peer pressure, and competition, as well as through performance-linked rewards.

The report suggests that the key benefits of energy behavior programs extend beyond the workplaces that undertake these programs. Often a change in participants’ thinking and behaviors follows, and after participation in the program they may become more active in their own energy-saving practices.

Things to Consider for Developing an Energy Savings Culture

  • Communication:  A critical element of motivating staff to contribute to an energy saving culture.  Communicate your energy saving vision, actions to be undertaken, roles, and above all else, the results that are achieved through a focus on reducing energy use.
  • Time and Effort:  Building an energy saving culture will take time and effort. Be realistic about the time required to change attitudes and behaviors, and pursue gradual rather than radical change.
  • Current Culture:  Understand your current culture by conducting observations of meetings, work areas and social areas.
  • Appoint a champion:  An employee who is passionate and respected – to lead the culture change process.
  • Metrics:  Develop a detailed action plan that includes actions, targets, responsibility and timeframes.
  • Accountability:  Assign roles and accountability to appropriate staff.
  • Motivations:  Motivate staff to put energy saving actions into place by demonstrating the value of the actions and the impact that they can have.
  • Monitoring and Reporting:  Publish reports on the implementation on action and achievements against goals and targets.

Online Learning Programs Succeed or Fail Before They Are Implemented.

Experts have opined on the development of the skills necessary to succeed in online learning for years, and although in today’s business environment it is easy to find an online course provider that’s both convenient and accessible; your workers may face significant challenges in developing the skills necessary for this type of learning.   Online training programs targeting adult learners in the workforce have grown dramatically over past few years.  Yet relatively few online learning providers offer what it really takes to have a successful online learning program.

In many recently published studies  and articles most students, when asked, agree that online discussions with fellow students and the instructor are central to the learning experience.  Instructors can encourage students to develop techniques to make the most of online discussions, which may add to a student’s learning experience and promote success in the online course.  The instructor can also encourage students to apply concepts from the online course, or as one student described it, “use it or lose it,” to develop an ability to retain and synthesize course objectives.   Another key for successful online learning is the importance of making a connection with fellow students.   Students who develop a meaningful connection with their co-workers and peers receive and provide support to one another.   The online connections also promote a sense of being a learner among other learners.

Staying motivated in the course is a challenge for students taking stand alone online courses.   It is important to develop a personal motivation strategy to make the online learning experience successful; one that can keep them from losing interest or burning out.   However many students simply do have the skill set necessary to develop this kind of strategy, let alone being able to implement it in a meaningful way.

Students in a recent study published by Educause Quarterly agreed that taking the following practical steps helped them succeed in their online courses:

Tips for Successful Online Learning

  1. Develop a time-management strategy.
  2. Make the most of online discussions.
  3. Use it or lose it.
  4. Make questions useful to your learning.
  5. Stay motivated.
  6. Communicate the instruction techniques that work.
  7. Make connections with fellow students.

Learning Environment

Many companies rush into online learning as a way to save money, and while it is true that on the balance it is less expensive, great care and planning should be taken in order to make sure it is a successful program.

An ideal study environment is just that – ideal.   Some students need absolute silence while others can’t seem to concentrate without noise in the background.   No matter what the preference, a well-lit place that is free from distractions is recommended.   Note that students make much better use of thirty minutes of disruption-free study than an hour’s worth of commotion-filled learning.

Keep your online learning sessions short!  For most learners a one to two hour session is ideal.

Don’t assume that all of your employees have the same level of computer savvy as you do.  Provide required training on course orientation and computer basics; how to log in, what to expect when logging in, basic screen layouts, how to get additional resources, etc.   Make sure everyone knows how to ask for help!

Implementing a great online learning program starts with great planning.  Correctly implementing an online learning program will greatly improve its success and its survival ability during tough economic times, and lead to greater overall satisfaction and increase the learning opportunities for your company.

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