Date: March 2020
A comprehensive accident/incident investigation program is an important part of any safety policy. It helps to identify trends and areas where safety efforts may need to be strengthened.
Minnesota OSHA requires employers to develop a workplace accident and injury reduction (AWAIR) program. One of the components of AWAIR is developing a plan to determine how workplace accidents will be investigated and what corrective action will be implemented. Investigation should take place promptly but only after affected employees are given necessary medical treatment and the work area is safe.
Accident/incident investigations should be fact finding and not fault finding. Investigations should go beyond the immediate accident observations and delve deeper to find causal factors that contributed to the loss. Root cause analysis is a technique that can be used to discover the existence of hazardous conditions or unsafe work practices that may have contributed to the accident.
These conditions and practices may not be initially evident when looking at the surface causes of the incident, but taking time to ask further questions and digging deeper can often reveal the true cause(s) of the incident. An example is an investigation into a hand burned by a chemical because the employee was not wearing protective gloves. The contributing cause is due to the employee not wearing gloves. A deeper investigation could unveil that the gloves did not fit, were not comfortable or not required for working with this product. If these root causes are not corrected, the chance of an employee not wearing gloves could happen again.
One of the first steps in incident investigation is determining who conducts the investigation. Often the incident investigation is handled by the injured employee’s supervisor. Supervisors have a better understanding of the relevant work, equipment and procedures that may come into play.
Did You Know …
An accident/incident sample form, as found on MCIT’s website, supplements a First Report of Injury form and is distinct and separate from an accident investigation.
Whoever is responsible for investigating accidents should be properly trained in the following areas:
- the accident investigation policy and its purpose
- standards and guidelines for investigations and reports
- causes and controls of accidents
- responses to accidents—who, when and what functions are to be performed
- witness interviewing techniques and evaluations
- evidence collection and examination
- root cause analysis and determination of contributing causes
- preparation and review of reports
- when, where and how to seek additional assistance, if needed
Incident Investigation Form and Report
An incident investigation form can facilitate the gathering of appropriate information. This form should:
- Identify when, where, who and what was involved in the accident.
- explain the damage.
- describe in detail what happened, before, during and after the accident.
- outline unsafe actions and conditions that occurred (such as inadequacies in the safety program, safety standards or compliance with the standards).
- evaluate the possibility of a similar accident occurring again and the potential severity.
- identify specific actions that can be implemented to control the factors that caused the accident.
- detail the steps that will be taken to monitor the remedial action.
Once the accident has been investigated and a remedial action plan determined, the completed report should be forwarded to the appropriate manager and to the safety committee as identified in the organization’s AWAIR policy (see below). The report should be reviewed by the safety committee and a manager should be assigned responsibility to implement the remedial action plan.
Senior management should follow up to ensure that the remedial action plan has been implemented to prevent the accident from occurring again. The safety committee and management should periodically review all accident data to determine if the same types of accidents continue to occur or if more accidents are occurring at a particular location. If so, corrective action should be taken immediately. The safety committee can also play an important role in accident review and remedial action planning.
Incidents Should Be Investigated To:
- Determine what went wrong
- Identify deficiencies in the operations
- Develop corrective actions to improve overall operations
- Prevent similar recurrences
Information shared with a safety committee in the incident investigation process cannot include personal information or private data about the injured employee (see MCIT Resource Individual Privacy and Accident Investigations).
Members who want more information about incident investigation, including sample forms and training materials, should contact their MCIT loss control consultant toll-free at 1.866.547.6516.
Minnesota AWAIR and Accident Investigation
An accident investigation process is one of the five main components required by Minnesota OSHA under Minnesota Statutes, Section182.653—A Workplace Accident and Injury Reduction (AWAIR) program. The act requires that:
- employers establish a written workplace accident and injury reduction program that promotes safe and healthful working conditions and is based on clearly stated goals and objectives for meeting those goals. The program must:
- describe how managers, supervisors and employees are responsible for implementing the program and how continued participation of management will be established, measured and maintained.
- outline methods used to identify, analyze and control new or existing hazards, conditions and operations.
- illustrate how the plan will be communicated to all affected employees so that they are informed of work-related hazards and controls.
- explain how workplace accidents will be investigated and corrective action implemented.
- express how safe work practices and rules will be enforced.
- an employer must conduct and document a review of the workplace accident and injury reduction program at least annually and document how procedures set forth in the program are met. See also Minnesota Administrative Rules Chapter 5208 for more AWAIR requirements.