Turns out OSHA made some additional changes to procedures surrounding injury reports.
These changes involve what happens after a company reports an injury or fatality.
An OSHA memo explains what businesses can expect. The process starts with a two-page questionnaire about the incident which companies are required to fill out. The answers to the questionnaire will be used to determine whether the facility is inspected.
Any one of the following situations triggers an OSHA inspection:
- a fatality
- at least two hospitalizations
- any injury of a worker 17 or younger
- similar events at the work site involving multiple injuries that occurred in the past year
- employer history of repeat, willful, failure-to-abate or egregious violations
- employer previously designated a severe violator
- employer covered by national or local emphasis program, or
- any imminent danger.
“Yes” answers to any two questions from the following list could trigger an inspection:
- Were temporary workers or “other vulnerable populations” injured?
- Does the employer participate in a cooperative safety program such as the Voluntary Protection Program or an alliance?
- Are employees still exposed to hazards that led to the injury?
- Was the incident the result of failure of a safety program such as lockout/tagout or process safety management?
- Were employees exposed to a serious hazard such as falls, combustible dust or heat?
- Is there a pending whistleblower complaint or inspection?
- Does the employer have a history of OSHA inspections?
- Did another government agency make a referral?
- Were health issues such as chemical exposure and heat stress involved?
If OSHA decides to conduct an inspection, it will usually happen within five business days.
Companies that aren’t inspected will instead be the subject of a Rapid Response Investigation (RRI).
An OSHA Area Office will call the company to conduct the RRI within one day of the injury report. The call will cover:
- a review of the incident with the employer (what happened, why it happened, what systems are in place to prevent this type of incident)
- an explanation of what the employer must do to complete the RRI, and
- consultation and compliance assistance regarding safety and health issues and abatement that are available.
To complete the RRI, the employer must respond within five business days to confirm abatement steps that have been taken. The employer can ask for an extension for “complicated events.”
As you’d probably guess, if the company doesn’t respond adequately to OSHA, the agency may conduct an inspection.