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Effective Reporting Policies

Previously, we talked about the importance of accident reporting- not only in assisting with safety compliance but also in preventing future accidents. In this followup article, we look at key policy considerations. Without an effective policy, your accident reporting procedures might fail to meet requirements, and be much less effective in identifying trends or training needs. Your policy must be understandable, consistently applied and enforced in order to be effective.   

The following elements are critical to an effective accident reporting policy:

  • Purpose. Stress not only legal compliance but also the value of reports in preventing future accidents.
  • Definition of “accident.” Be specific so that those responsible for reporting know exactly what types of accidents must be reported. Encourage the reporting of “near misses” as well, since such incidents are often the precursor to more serious accidents and injuries.
  • Reporting procedures. Include a brief summary of the information that should be reported (Who, What, When, Where, How, Why), where forms can be obtained, how soon the report must be completed, and other relevant requirements. Consider “short form” methods for reporting safety concerns or near misses that result in no damage or injury, and would not otherwise require the completion of a more formal report. Safety related suggestions or concerns are not normally a part of the “Reporting” and “Recordkeeping” policy, but their importance is no less than the “big” incidents. From a workplace safety and training perspective, such information properly collected and acted upon is often of greater importance for its usefulness in the prevention of those “big” incidents. Including the “small stuff” in the Reporting policy gives it the recognition it deserves.
  • Drug testing. If your drug-testing policy requires tests after certain accidents, your accident forms and policies should be coordinated with your drug-testing policy.
  • Documentation. Attach copies of accident report forms to the policy statement and describe any special certification required.
  • Responsibilities. Stress the importance of the supervisor’s role in reporting accidents, getting medical help for injured employees, filling out report forms, etc. If you have a safety committee, talk about its role in accident reporting and investigation.
  • Confidentiality. Make sure your policy sets out confidentiality requirements and procedures for employee medical information. Keep accident reports separate from personnel files to protect confidential information. In order to foster employee’s willingness to report minor injuries, accidents or near misses, it is very important that confidentiality of witness reports be protected as well. Anonymous reporting might be considered, but understand that followups would be difficult, if not impossible, should insufficient information be provided.
  • Workers’ compensation. Accident reports are often required for workers’ compensation insurance. These forms should also be completed when accidents are reported.
  • Potential litigation. Be sure to also cover the manner in which the report should be maintained, distributed, and written if there is a potential for litigation. You want to avoid a situation in which an accident report admits liability and is used in future litigation against you. Include only known facts, and avoid inserting opinion, hearsay or conjecture.

Other Policy Considerations

Here are some other vital issues to consider when reviewing your accident reporting policy:

  • Does your policy comply with your state’s workers’ compensation statute?
  • Do different reports need to be completed when the accident involves a business visitor? Such accidents may lead to lawsuits and the form in which you record the events and the persons to whom you give it may become critical issues in litigation.
  • If you have general liability insurance that may cover an accident, did you consult with your insurance carrier when you designed your policy and report forms? They may require specific information, and your forms must be able to capture that. Going back for the missing information later will result in needless delays. Likewise, you should minimize or eliminate gathering of information that is not required for legal, investigative or insurance purposes.
  • Have you coordinated any short-term and long-term disability or accidental death policies with your accident reporting policy? The same issues apply here as those concerning GL insurance requirements. Get the needed information now, when it is readily available, rather than having to dig for it later.
  • Are employees aware of the consequences of not reporting what might seem to them a minor injury, that later proves more serious? Such consequences could include not being covered by Worker’s Comp insurance for failure to follow procedure, or at least delays or limitations in coverage.

The Bottom Line

As you have seen, there is a lot more to recordkeeping and reporting of accidents than simply satisfying OSHA regulations. The reports serve to protect both the company and the employees when used as a tool for prevention and training. The information obtained is useful for followup training or the regular updating of safety procedures and policy. Maintaining an understandable, coherent reporting system that is used to enhance safety in the workplace can increase employee confidence that their safety matters to their leadership. This, in turn, fosters a greater buy-in and strong safety culture.

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Categories: Safety, Training
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