The latest injury and fatality statistics reported by the Missouri Department of Labor for calendar year 2018 include the following:
There were 102 total work-related fatalities during 2018. These fatalities were attributed to:
- 25 automobile crashes
- 16 construction industry
- 15 transportation and warehousing industries, combined
- 11 public administration industry
Men represented the majority of all fatalities and the 50 to 59-year old age bracket accounted for more than 30% of these fatalities. August was the leading month for work-related injuries (16) leading to death, and July followed closely with 13. Wednesday was the most fatal day of the week, representing 22 of the 102 fatalities, and 21 of the deaths occurred on Mondays.
Motor Vehicle Crashes
Motor vehicle accidents are (and historically have been) the leading cause of worker fatality. The common misconception is that these fatalities occur in the transportation industry. While this industry certainly suffers its fair share of MVA-related deaths, it does not have the corner on this market. In our mobile society, business executives fly all over the country, home healthcare workers drive to and from clients’ homes, courier services and consultants operate on the highways daily. These statistics include crash-related fatalities for all industries and emphasize the importance of hiring safe drivers and enforcing a distracted driving policy.
Non-Fatality Work-Related Injuries
A total of 101,877 reportable injuries were recorded in 2018. Of those, 8,358 were lost-time incidents. Manufacturing and the healthcare industries typically run shoulder-to-shoulder for both lost-time and overall number of reportable injuries, and 2018 was no exception. Manufacturing led the way for non-fatal lost-time injuries, followed by healthcare and social services. The opposite is true when the sheer number of recordable incidents are tallied, with healthcare and social services edging out the manufacturing sector. Strains and sprains (or muscle tears) were the loss leader, with lifting being the number one root cause of strain injuries.
By comparison, there were 118 fatalities, 99,743 recordable injuries, and 8,246 lost-time injuries in calendar year 2017. There were 2,134 more reportable injury incidents and 112 more lost-time injury incidents in calendar year 2018. Fatalities, however, decreased by 16 – BIG WIN!
Loss Leaders in the Construction, Transportation, and Warehousing Industries
With the exception of automobile crashes, the construction industry is the fatality leader, largely due to falls, struck-by, electrocutions, and caught-between injuries. Construction workers routinely work from heights that require fall prevention and/or protection. They are surrounded by high-voltage electrical hazards and frequently work in inclement weather – a contributing factor to both falls and electrocution injuries and fatalities. Housekeeping frequently contributes to fall claims in this industry. Struck-by claims are common and often involve tools falling from platform scaffolding onto workers below. Workers suffer caught between injuries as minor as catching a finger in a pinch point or being pinned (partially or completely) between moving equipment and stationary walls or steel beams.
Planes, trains, and automobiles all fall under the transportation industry. The transportation and warehousing industries report large numbers of slip and fall claims. Inclement weather plays a large role in the number of truck drivers who slip and fall while descending the cab of a truck . Frozen precipitation on steps account for a large number of sprains and broken bones each year. Grounds crews at the airport operate tugs and carts and climb ladders in all kinds of weather . Overreaching in a warehouse may result in back, shoulder, or neck strain. Improper storage practices often lead to struck-by incidents resulting from products falling from overhead. Many of these injuries are preventable by using the right equipment for the job and following safe work protocols . Truck mechanics commonly suffer minor burns, hand contusions and lacerations, and muscle strain injuries. Truck drivers and warehouse workers alike are subject to caught-between injuries that frequently occur during loading and unloading at the dock.
Public Administration Risks
The public administration industry includes emergency personnel (police, firefighters, ambulance workers, CDC, FEMA, correction officers, etc.), government, and defense personnel. These workers face a variety of high-risk situations in the course of performing their routine duties. These situations may range from a disgruntled consumer to a domestic violence or hostage situation, a biological, environmental, or medical emergency, an active shooter situation, or a terrorist threat. Not only do these workers face typical workplace exposures, but they confront the potential for workplace violence on a daily basis. Public Administration workers accounted for 9,228 injury accidents, 880 lost-time incidents, and 11 fatalities during the 2018 calendar year.
Granted, these are raw numbers and not a complete statistical analysis (which would include numerous other variables), but the bottom line remains the same: 16 more workers went home every day in 2018 than in 2017. Is there any better benchmark for workplace safety?
Have you posted your Form 300A? OSHA requires this summary of injuries to be posted from February through April of each calendar year for all injuries and/or illnesses reported in the prior calendar year (2018, in this case). This form must be posted, even if your organization had no reportable injuries or illnesses during the 2018 calendar year.
OSHA recently rescinded the requirement that businesses with 250 or more employees must submit Forms 300 and 301 electronically. The Final Rule can be viewed here and goes into effect on February 25, 2019. This rescission of the electronic filing requirement does not, however, remove the burden of reporting work-related injuries and illness from the employer.
Most businesses with 10 or more employees are required to report “serious” work-related injuries and/or illnesses to OSHA on Forms 300, 300A, and/or 301. Several businesses have been identified by OSHA as “low risk,” and have been exempted from this requirement. Among those exempted businesses are car dealers, numerous retail stores, florists, gas stations, pipeline transportation businesses, legal offices, and numerous other professional service businesses (including civic, medical, scientific, and educational services). Minor injuries requiring only first aid need not be reported. The following explanations and definitions can be very helpful in determining an employers’ recordkeeping and reporting needs.
How does OSHA define “first aid?”
OSHA defines first aid as any treatment limited to non-prescriptions medications such as over-the-counter pain relievers, ointments or creams, the use of standard bandages, gauze pads, or butterfly strips, elastic wraps, temporary slings or splints, and other minor treatments such as removal of a splinter or similar foreign item from the body or the removal of debris/foreign body from the eye with water/eyewash or a cotton swab. Cleaning of minor wounds (surface lacerations) and tetanus shots are considered first aid, whereas Hepatitis B, rabies vaccinations, and open wound cleaning are not. Most first aid is administered immediately after an incident or accident occurs, and may be the only treatment received by the worker. An injury of this type would rarely require ongoing medical treatment. An injury of this type would rarely require ongoing medical treatment. Minor burns or lacerations are often treatable under this definition of “first aid,” and require nothing more than the application of topical ointment, a Band Aid, and perhaps a dose of over-the-counter Tylenol or Ibuprofen.
What is a “serious” injury?
All fatalities, loss of consciousness, lost-time injuries, injuries requiring light duty restrictions, injuries requiring ongoing medical treatment, or broken bones or teeth are reportable. Work-related illnesses such as cancer and other irreversible and/or chronic diseases are also reportable. There are special requirements governing needlesticks, sharps injuries, hearing loss, TB, and other injuries more specific to the medical field. Many fall injuries qualify as “serious” under this definition, as they commonly require follow up medical care such as prescription drugs, chiropractic care, physical therapy, or surgical intervention.
FORMS 300, 300A, and 301
Form 301 – Injury and Illness Incident Report
Form 301 is the initial reporting form and is required to be completed within 7 calendar days of knowledge of an accident or injury. This form is a general incident report and is rather self-explanatory. It collects general information about the injured employee (name, address, physician information) and what the employee was doing, how the injury occurred, and the nature of the injury or illness. For example, a warehouse worker may suffer back strain due to improper lifting or may strain his or her neck reaching overhead to extract inventory. The injury would first be reported on Form 301, and the injured worker would detail what work was being performed at the time the injury occurred.
Form 300 – Log of Work-Related Injuries and Illnesses
Form 300 is a listing of injuries and illnesses for the employer’s place of business. This form collects information on injury severity, lost time, and light duty return-to-work data. The document also serves as a master log of workplace accidents and can be a valuable tool in identifying injury trends. This data is critical in developing revised work procedures and corrective action plans to reduce recurrences.
Form 300A – Summary of Work-Related Injuries and Illnesses
Form 300A is completed annually, at the end of the year, and is required regardless of whether or not any injuries occurred during the year. The form tallies an employer’s average number of employees over the course of the calendar year and the total number of reportable incidents for that same time period. This figure is determined by following the instructions on the back of the form.
29 CFR 1904
Recordkeeping and reporting is governed by 29 CFR 1904, which outlines exemptions, record retention, variance requests, electronic submissions, and reporting protocols. This standard houses critical information such as:
• How to determine if an injury or illness is work-related (29 CFR 1904.5)
• What determines whether or not an injury is a “new case” (29 CFR 1904.6)
• Requirements for needlesticks and sharps injuries (29 CFR 1904.8)
• Criteria for work-related hearing loss (29 CFR 1904.10)
• Reporting requirements for fatalities, loss of eye or limb, and hospitalization (29 CFR 1904.39)
○ [NOTE: Fatalities (which may occur as much as 30 days from the date of the accident) must be reported within 8 hours; amputations, hospitalizations, and loss of eye must be reported within 24 hours]
• Retention requirements (29 CFR 1904.44)
Knowing what to expect, and what is expected of you, will help you respond confidently when an accident occurs. Reports of serious injuries may be made via telephone or online, so it is best to familiarize yourself with 29 CFR 1904 and be prepared to respond accordingly.
Are you responsible for OSHA recordkeeping and reporting for your organization? Are you responsible for workforce safety or risk management? Email us or give us a call at (816) 349-0850 to see how we can help design a safety and risk management plan that meets your unique needs.
Active shooter situations typically occur without warning and are over within 15 minutes. That’s a short window of opportunity to shelter in place and/or respond defensively. Being trained and prepared for the worst can help you better determine how to respond when faced with a real threat.
Keeping calm is critical in this situation. It is imperative that you be able to quickly assess your environment. Identify exits and evacuation routes. Determine the location of the shooter(s) and assess how many others are in the building. Depending on your position in the building and the layout of the structure, you should get to the nearest room and secure the door from the inside.
Your best option is always to evacuate, if possible. If evacuation is not an option, shelter in the most secure location available to you. Lock doors and hide beneath desks or behind heavy doors or furnishings that offer some protection. Barricade doors and windows with heavy furniture if time allows. Assess your surroundings and identify items in the room that can be thrown at the shooter or used defensively. You should only attempt to take action against the shooter if you are in imminent danger and have no other choice.
When police arrive on site, their primary task is to identify and immobilize the shooter or shooters. They must quickly assess the situation upon arrival. This includes processing the physical layout of the scene, placement of victims and perpetrators, and responding to rapidly changing conditions in real-time. Upon arrival, every person they encounter is a potential threat. You should stay in place until the police have issued an all-clear or emergency responders are able to assist you. Never rush the police upon arrival.
Plan for worst case scenarios in advance. Identify evacuation routes and potential shelter areas. Provide your staff with professional training. No one can predict when such an event will take place. Train your managers about the warning signs of potential violence by an employee. Every preventative step you can take is a step in the right direction.
Most businesses dread the thought of an OSHA inspection. Much of this dread may stem from misconceptions and lack of preparedness. Do yourself a favor by knowing how to respond before a compliance officer arrives at your door.
10 Things You Need to Know About OSHA Inspections
1. OSHA inspections are not random. Most inspections are the result of one of the
A. In response to a fatality or catastrophe;
B. In response to an employee complaint;
C. A “targeted” inspection, which is part of the national emphasis program (NEP) or local emphasis program (LEP); or
D. A result of an imminent danger observed by a compliance officer (commonly a fall from height or trenching exposure).
2. With few exceptions, OSHA inspections are not scheduled or pre‐announced. An OSHA compliance officer may arrive at your business unannounced, and will advise you of the nature of the inspection.
3. You do not have the right to refuse an inspection, but you do have the right to refuse entry to your property. Because your business is private property, you may refuse entry to the property and require OSHA to obtain a warrant in order to conduct their inspection.
4. You should always verify the credentials of the OSHA compliance officer. Are they from the proper jurisdiction governing your business (federal or state)? It is your responsibility to know which division has jurisdiction over your business.
5. There are three parts to every inspection:
A. Opening Conference
B. Walkthrough Inspection
C. Closing Conference
6. Once on site, OSHA’s Compliance, Safety, & Health Officers (CSHOs) have “line of sight” authority. If a hazard or condition is observable, it is citable. You determine the access route or path to the inspection area, even if that means taking the CSHO outside the front door, around the outer perimeter of a building, and into another entrance door with more direct access to the identified inspection area. You may control much of what the officer sees by limiting their access through the facility.
7. OSHA representatives will want to speak with your employees. Your employees have the right to speak with these officers freely, privately, and without fear of consequence or retaliation. Employees have the right to speak with CSHOs without management present, but may request the presence of a peer, a union officer, or another non‐management person. Your employee is not required to participate in any discussion, but you may not influence their decision.
8. OSHA has the right to view and obtain copies of your injury reporting logs (300, 301, 301A) while on‐site.
9. OSHA does not have the right to view or obtain copies of personnel files, inspection reports, or other internal documentation during the inspection visit. These documents may become discoverable at a later time, but the compliance officer does not have open access to your files and documentation during the inspection visit.
10. Your company should have a designated person to interact with OSHA and to respond to investigations and citations. Your staff should know who to contact on site if an OSHA compliance officer arrives, and know how to respond to an inspection request.
10 Steps to Outline Your OSHA Inspection Policy
An OSHA inspection response policy is worth its weight in gold. OSHA makes people nervous. Having a policy in place alleviates the pressure on your customer‐facing front office personnel and helps them remain calm and professional in the presence of an OSHA compliance officer.
At a minimum, your policy should include the following:
1. An OSHA compliance officer (CSHO) will arrive on site and state the intended purpose/scope of the inspection.
2. You should request to see the compliance officer’s credentials.
3. Seat the CSHO in a clean area at the front of your facility.
4. Call the company‐designated OSHA representative for the company.
5. Your company‐designated OSHA representative should:
a. Take the CSHO into a conference room or private office near the front of the facility for the opening conference, or
b. Refuse entry to the facility and request the CSHO obtain and return with a warrant to conduct the inspection.
6. The company‐designated OSHA representative should determine the path of access to the inspection area based upon the scope of the inspection identified by the CSHO. This may entail taking the CSHO out the front door and around the exterior of the building to another entrance with more direct access to the inspection area in order to limit and control the CSHO’s line‐of‐sight.
7. The CSHO should never have unaccompanied access to your facility. Your company‐designated OSHA representative should lead the CSHO to the inspection area and should remain with the CSHO at all times (except when the CSHO is speaking with an employee). If possible, there should be two or three company representatives who accompany the CSHO during this inspection.
8. Your company‐designated representative should always document the inspection. If the CSHO takes a photo, you should take the same photo. If the CSHO takes measurements, you should take measurements. If the CSHO expresses concerns or asks questions, these items should be noted. Your documentation should mirror the compliance officer’s documentation as closely as possible.
9. Be cooperative. Answer questions that are asked, but do not volunteer any additional information.
10. Upon completion of the walkthrough inspection, your company designated OSHA representative should lead the CSHO back to the conference room to conduct the closing conference. Make notes of the officer’s observations and concerns.
After the Inspection
The OSHA compliance officer will return to the local field office to prepare the final inspection report. OSHA has six (6) months within which to issue any citations. Your company has 15 days in which to respond to these violations. Your response may detail your OSHA‐compliant training policies, employee training attendance records, or some other proof of abatement.
Violations may be abated and/or dismissed, may be appealed, or the case may be tried in court. You should understand your right to appeal, your right to request an informal hearing, and your right to request a reduction of fines. Settlement should always be explored before proceeding to trial.
It is your responsibility to know your rights. Be prepared for the unexpected by establishing an OSHA inspection procedure before it is needed.
Do you know how to respond to an impromptu OSHA inspection visit? Are you responsible for workforce safety or risk management? Email us or give us a call at (816) 349-0850 to see how we can help design a safety and risk management plan that meets your unique needs.
The High-Risk Division of Maintenance, Repair, and Overhaul (MRO)
Maintenance, Repair, and Overhaul (MRO) facilities perform every type of aircraft repair you can imagine – replacing interior seats and carpeting, rewiring electrical harnesses and gauges, and maintaining and repairing engines, wings, or landing gear – you name it, MRO facilities touch it. Multiple times.
Mechanical work is conducted both inside and outside the plane. Mechanics, painters, cleaners, and others are up and down ladders frequently throughout their day. They often perform work overhead or within very confined compartments. Mechanics are often required to contort their bodies into a number of tight spots to complete their work. Bending, squatting, stretching, pulling, pushing, lifting, and torquing on wrenches is the heart of a mechanic’s activity. These actions lead to a high number of reportable strain/sprain and laceration injuries each year.
Aircraft work may be conducted inside the hangar or outside on the tarmac. Struck by injuries are common due to low ceiling heights inside the aircraft. Outside the aircraft, many struck by injuries are attributed to personnel walking into a wing, striking the bottom of the engine compartment when working overhead, or even being struck by other moving equipment on the tarmac.
Additional high risks associated with MRO facilities are the frequent lifting and/or moving of heavy and awkwardly shaped or weighted parts, the use of both hand and power tools, exposure to jet fuel, chemicals, and paint fumes. Ventilation is a major concern, particularly if an MRO paints on-site.
The aviation industry, as a whole, suffers a high rate of slip, trip, and fall claims. While there are a number of contributing factors (air hoses and tools lying on the ground, the frequency of work on ladders, etc.), weather may be the most serious contributing factor. A large amount of mechanical work occurs outside. Much of that work is completed from a platform ladder. Rainy conditions, snow and ice, and falling temperatures can all change the physical condition of a platform, and the worker’s footing, in an instant. Inclement weather and ladders can be a deadly combination.
Water discharge from the aircraft while servicing a lavatory can pool at a worker’s feet and create a fall or electrocution hazard. There are so many unique exposures in this industry. While it is impossible to focus on every variable at all times – work at hand, maintaining a center of gravity and footing, confined spaces, moving equipment in the work area – it is critical to be aware of your surroundings, including weather conditions, at all times.
Rapidly changing weather conditions and fast-dropping temperatures can be a game-changer. The best-maintained facility cannot keep up with every shift in conditions, particularly when we are talking about black ice and fast-forming ice on platform surfaces. Awareness is critical and cannot be emphasized enough. Sudden movements can have disastrous consequences.
Unfortunately, this industry experiences both a high frequency and a high severity of injury claims. Electrical shock, falls from heights, eye injuries, hearing damage, strain/sprain, struck by falling objects, slips on ice – all are common claims in the aviation industry. Inclement weather serves only to heighten these exposures. Claims in this sector range from minor sprains and lacerations to brain injuries, paralysis, and even death.
Make safety the top priority at your MRO facility. Establish a formal safety program, create a formal safety committee with a designated leader, and conduct JSAs on all positions. As summer fades out to rainy autumn and icy winter, be sure to promote seasonal safety awareness early and often.
Does your company have formal safety policies in place? Are you responsible for workforce safety or risk management? Email us or give us a call at (816) 349-0850 to see how we can help design a safety and risk management plan that meets your unique needs.