OSHA Injury Reporting
Heinrich accident triangle
EHS mission: to assure safe and healthful
working conditions for the MIT community.
OSHA CFR
MIT EHS
OSHA Injury Reporting
Joe MacLeod & Suzanne Adams
OSHA CFR 1904
• Requires employers to establish • Employee representatives
have access to those
a procedure for employees to
parts of the OSHA 301
report injuries and illnesses
form relevant to
• All employees on your payroll;
workplace safety and
labor, executive, hourly, salary,
health
part-time, seasonal, or migrant
• Requires specific
workers.
information to be
• Employees who are not on your
reported.
payroll if you supervise these
• Regulatory requirement
employees on a day-to-day
black and white
basis.
OSHA Form 301
7
OSHA Form 300
8
9
2010 MIT Numbers
Recordable
Incident Rate
LT Incident Rate
Days lost
Days restricted
196
1.9
0.93
1522*
1344
OSHA recordable injuries / illnesses
Incidence Rates of Recordable Injuries and Illnesses
MIT Incidence Rate of Cases with Days Away from Work
Roles and Responsibilities
•
•
•
•
•
•
Employee
Supervisor
DLC Coordinator
EHS Lead Contacts
Medical Provider
HR Worker’s
Compensation
• OSHA Recordkeeping
Employee
• Notify supervisor
• Seek treatment
• Provide medical documentation to supervisor
• Communicate work status
• Provide information on potential hazard/s in
the workplace
Supervisor
• Ensure employee can get
help
• Address hazard
• Submit supervisor report
of injury
• Investigate hazard and
complete follow-up
investigation questions*
• Follow the incident
through until “return to
work without
restrictions”
Supervisor Follow-up questions
• What caused the accident?
– Improvements to behavior (PPE, JHA,)
– Conditions (defective equip., housekeeping,
guarding
• How to prevent re-occurrence?
– Training, SOP (create / modify), install shielding
• Other relevant information?
DLC Coordinators/EHS Lead Contacts
• Notified immediately via e-mail • Investigate trends
when on line report is
repetitive strain, lifting,
submitted (Privacy cases)
frequent fliers, facility
knowledge
• Provide technical assistance to
supervisor investigation*
• Ensure hazard is addressed
• Facilitate completion of
supervisor’s report
• Ensure action items are
completed (maintenance,
training, procedure updates)
Medical Provider
• All employees should go to MIT Medical for their first visit if
they are physically able to (with supervisor assistance)
- Cases with ambulance, off hours and emergencies
•Employee seeks treatment before reporting the injury to the
supervisor (outside medical provider)
• Evaluates injury / work capability & makes recommendations
•Provides documents for lost time/restrictions/return to work
status for employee and supervisor
HR Worker’s Compensation
• Managed in Human Resources
• Strictly employee based
• Collects all medical paperwork
• Keeps track of lost time and medical treatment
billing
•Refer to the handout for specifics
WARNING: DO NOT MIX
OSHA RECORDABILITY AND WORKERS’
COMPENSATION
Workers’ Compensation determinations do NOT impact
OSHA recordability.
Some cases may be OSHA recordable and compensable.
Some cases may be compensable, but not OSHA
recordable.
Some cases may be OSHA recordable, but not
compensable.
OSHA stops counting at 180 WC can go on for years.
OSHA Recordkeeper
• Triage the Supervisor Reports of Injury
• Injury and Illness Report (OSHA 301)
– Employee Status
– Determine if work related
– Recordable vs. Not recordable
• OSHA Log (OSHA 300)
• Summary (OSHA 300A)
• Reporting to the BLS
Determining Covered Employees (per 1904.31) Decision Tree
June 22, 2009
Is the injured person an MIT:
Faculty and Staff*+
Support and Service Staff*+
Post Doc. Affiliate*+
Post Doc. Assoc.*+
Research Asst./ Affiliate*+
Technical Asst./ Assoc.*+
Research Teaching Assistant*+
Instructor*+
Yes
No
Is the injured person a:
MIT Temp.+
Grad Student
Visiting Student
Visiting Scientist
Post. Doc./Research Fellow
Under-Grad
UROP/Summer Help*
Contractor
Consultant
Employee from Temp. Agency
No
Yes
Is the person
receiving an
*MIT* Stipend or
on the MIT
Payroll?
Yes
No
The incident is NOT
OSHA Recordable
No
Is the person paid
from any source
and is supervised
on a day-to-day
basis by MIT
employee?
*Employee work injuries eligible for MIT Workers’ Comp. Coverage
+ Employees hours/totals are included in the OSHA 300A Summary & BLS Annual Survey
Yes
The incident is
OSHA Recordable
Work-Related?
YES
• An event or exposure in
the work environment
either caused or
contributed to the
resulting condition
• An event or exposure in
the work environment
significantly aggravated
a pre-existing injury or
illness
NO (9 Exceptions)
•
•
•
•
•
Present as a member of
the general public
Voluntary participation in
wellness program, medical,
fitness or recreational
activity
Personal tasks outside
assigned working hours
Personal grooming
Eating, drinking or
preparing food or drink for
personal consumption
Recordable?
NO
D id the e mploye e e xpe rie nc e a n
injury or illne s s ?
YES
NO
Is the injury or
illne s s w ork-re la te d?
YES
NO
Is the injury
or illne s s a ne w c a s e ?
U pda te the pre vious ly
re c orde d injury or illne s s
e ntry if ne c e s s a ry.
YES
NO
D o not re c ord the
injury or illne s s
D oe s the injury or illne s s me e t
the ge ne ra l re c ording c rite ria
or the a pplic a tion to s pe c ific c a s e s ?
YES
R e c ord the
injury or illne s s
General Recording Criteria
Triggers for Recording






Death
Loss of Consciousness
Days away from work
Restricted work or transferred to
another job
Needle sticks (some)
Medical Treatment beyond first aid
Sutures/glue
Physical Therapy
Prescription Medication
Removing foreign body from eye w/ more than flushing/cotton
Rigid splint
Broken bones and fractures
Notification
• Employers must record each case on the OSHA
300 Log and the Form 301 Incident Report
within seven (7) calendar days after being
notified that an injury or illness occurred.
• Employers must use calendar days (including
holidays and weekends) instead of scheduled
work days, for recording days away from work
[1904.7]. Employers may cap days away from
work at 180 days.
Questions or Comments?