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Summary of Year One of OSHA's Severe Injury Reporting Program

April 1, 2016

 

David Michaels, the Assistant Secretary of Labor for Occupational Safety and Health, recently published a report on the results of the first year of OSHA’s Severe Injury Reporting Program.  Beginning on January 1, 2015, employers were required to report any work-related amputation, in-patient hospitalization or loss of an eye within 24 hours. 

 

OSHA received more than 10,000 reports of incidents meeting these criteria during 2015.  Of the reports submitted, about 75% were for hospitalizations and about 25% were for amputations.  OSHA’s response to these reports varied by the type of report. 

 

For most of the reports of hospitalization, OSHA did not send an investigator to the facility but asked employers to investigate the incidents and propose remedies to prevent future injuries.  OSHA calls this process a Rapid Response Investigation (RRI) and is considered to be a collaborative, problem-solving approach in which the facility and an OSHA Area Office expert.

 

For most of the reports of amputations, OSHA conducted an inspection by a compliance officer.  Many of these investigations resulted in citations being issued to the facility at which they occurred. 

 

OSHA believes that close to 50% of incidents that should be reported under the Severe Injury Reporting Program are still not being reported.  Some employers are trying to hide their incidents, but many are small and medium sized businesses that are simply unaware of the new requirement.

 

Based upon the experiences of Baron’s clients and the recent OSHA report, we believe that all facilities reporting an amputation should anticipate that a compliance officer will visit within 2-10 days of the report being submitted.  It is substantially less likely that a facility experiencing a hospitalization will receive such a visit. 

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