Turn Year-End Safety Responsibilities Into Opportunities
It is that time again when we are overwhelmed with holiday cards, New Year’s resolutions, and government recordkeeping. Just as you can count on paying taxes in April, almost all employers with more than 10 employees must post injury and illness logs by February 1. Unlike income tax forms, the OSHA 300 logs (the form used to capture workplace injuries and illnesses) must be continually updated throughout the year. OSHA requires that employers complete a Form 301 Incident Report (or equivalent) and update the OSHA 300 Log within seven calendar days of receiving information that a recordable injury or illness has occurred.
The end of the year provides us an opportunity to review cases for accuracy before they are posted. Sometimes cases may be initially reported, but later determined to be caused by something other than the work environment so they should be crossed off (Tip: don’t delete or white-out cases… just draw a single line to strike them). Other cases may have incurred additional lost or restricted days since the form was last updated.
You can leave this time as just fulfilling some government burden or choose to make this process into something more productive.
- Ensure that your injuries are captured with enough detail to provide meaningful information. You may need quite a bit more data than you report on the 300 Log. An incident description stating “employee slipped and fell on concrete” isn’t as helpful as “employee slipped on ice-covered sidewalk while returning materials to shop.” The latter narrative is actually helpful in preventing further injuries.
- Use your organization’s incident data as a measure of past performance and identify opportunities for improvement. You may want to assemble three to five years worth of incidents and analyze them for trends. Look for frequent, minor cases and give them significant attention. Minor incidents are invariably a predictor of severe injury or illness. It’s good to fix problems before they cause a catastrophic injury.
- Dig deeper than your OSHA logs and analyze first aid cases, near misses and behavioral observations. We wouldn’t drive our car by only looking in the rear-view mirror, so why create safety programs solely by past injuries?
In 2011, make it a goal to continually evaluate and work to eliminate the underlying causes that lead to incidents.