Occupational Injury and Illness

1. Purpose

a) To establish a uniform method for accident investigation and/or procedure for reporting near misses, injuries and property damage.   The overall objective of this procedure is to establish a uniform method of accident investigation that will:

i. Reduce injuries and illnesses

ii. Identify potential hazards in the workplace

iii. Implement consistent reporting

iv. Evaluate the controls implemented

v. Prevent accidents on similar operations

vi. Determine the root cause.

vii. Not intended to fix blame for the incident or injury.

b) The purpose of the accident investigation process is to collect, analyze, interpret information, and to assign responsibility to appropriate personnel for elimination of accident and incident causing factors.

2. Scope

a) This policy covers all ESCO Group employees, ESCO locations and customer locations.  ESCO employees on company business are also included regardless of location (i.e. an automobile accident on a public road).  This policy applies to all incidents noted below: 

i. Fires

ii. Property damage

iii. Employee work-related injuries and illnesses

iv. Near miss incidents

v. Chemical spills, oil spills or environmental releases

b) Guests and visors involved in any incident listed on 1-5 above are also covered under this procedure.  However, ESCO Worker’s Compensation does not cover guests or visitors. 

3. Definitions

a) Accident:  an occurrence in which personal injury was incurred by an employee of ESCO Group resulting in a Worker’s Compensation Claim.

b) Incident is considered as any occurrence that takes place within the company, wherein serious injury to employees may have occurred or damage to property or equipment occurred or could have occurred or an environmental release could have occurred.  

c) OSHA Recordable Incident:  any injury which meets the recording requirements of 29 CFR 1904.

d) Reportable Incidents: include, but are not limited to, the following:

i. Injury to personnel that is of greater magnitude than minor cases involving first aid treatment.  This includes all disabling or potentially disabling work injuries.

ii. First Aid Cases:  an injury not resulting in an OSHA recordable injury.   

iii. Tool or equipment failure.  This includes “near miss accidents” that might have resulted in death or serious injury (e.g., failure of a lifting device, or other serious tooling and equipment malfunctions.)

iv. Fire or explosions of any magnitude.

v. Release of toxic or noxious gases.

vi. Spills of flammable or toxic materials.

vii. Oil spills 

viii. Automatic or manual actuation of fire control systems or damage to the systems.

ix. Vehicle incidents of any dollar amount.  

x. All fork truck incidents with or without property damage.

xi. Property damage, any dollar amount.

e) Accident/Incident Report Form –ESCO Group form to document the reporting and investigation of an accident.

4. Policy

a) All accidents, incidents and first aid treatments will be reported immediately by all ESCO employees, supervisors, contractors, vendors and guests.  Immediately is defined as within the shift for acute injuries (i.e. lacerations, burns, etc.) and with 48 hours for cumulative injuries (i.e. repetitive, soft tissue injuries).

b) It is ESCO Group’s policy to investigate all accident and incidents which results in injury, potential injury, property damage, or environmental release (See OSHA Recordable Incident definition).  First Aid incidents which do not meet the criteria of a OSHA Recordable Incident will be logged and analyzed for trends.  

c) Incident reporting and investigation activities are directed at discovering the root cause of the occurrence and to prevent re-occurrence of the events that caused the incident. Incident reports shall be used to inform employees of safety events (near miss, 1st aid case, medical aid, property damage, etc) to prevent reoccurrence of safety event. 

5. Incidents

a) The ESCO GROUP EMPLOYEE’S WORK INJURY report will be completed by the affected employee and supervisor to document the incident occurrence and extent of possible injuries or consequences. 

b) The supervisor will review the incident report, conduct an investigation, document the findings, and recommend corrective action on ESCO Group’s Supervisor’s Investigation Report.   

c) Corrective action is reviewed by the management team and verified for effectiveness.    

d) If and incidents involves Contractors, Vendors and Guests:

i. The ESCO Employee representative will complete the ESCO Group’s Supervisor’s Investigation Report.

ii. The employer of the Contractor, Vendor or Guest will provide ESCO with a copy of the following, if applicable:

1. Company incident report

2. Company corrective action

3. Any work restrictions

iii. Incidents requiring First Aid Treatment will be reported to the Safety Department.  

6. Responsibilities

a) Employees

i. Employees must report all accidents and incidents that they experience at work to ensure:

1. That documentation of the occurrence exists.

2. To provide ESCO Group the opportunity to investigate the situation and develop corrective action plans to correct the problem and prevent re-occurrence.

3. Completion of the accident or incident report is the injured employee’s account of the injury occurrence.  This report must be completed and signed by the employee.  The completed report will serve as a legal record of the accident or incident.

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b) Supervisors

i. The supervisor should be familiar with the equipment, operation or process involved in the accident or incident.  A supervisor is the most likely person to conduct the investigation since they have direct knowledge of the job and the employees conduct in his/her work area.  However, depending on the circumstances, additional personnel or outside investigators may be called upon to conduct the investigation.  The determining factor is the scope and severity of the accident.

ii. If the investigator is not familiar with the machinery or process involved in the accident, he or she should consult someone who is knowledgeable about the process or equipment.  A chemical leak or spill will require expertise from other sources.  Know what authorities should be called when an accident occurs.  As a supervisor, your job is to assist experts from outside sources, when they are requested to conduct the investigation.  

iii. The supervisor will complete ESCO Group’s Supervisor’s Investigation Report.   

iv. The supervisor is responsible for notifying the Safety Department immediately of all incidents. Acceptable methods of communication include email or leaving a phone message

c) Department Manager

i. Upon receipt of an Accident or incident report, shall ensure that those measures noted are taken immediately to prevent recurrence.

ii. Meet with the Supervisor to review the report if additional information is required.

iii. Sign the report and send it to the Safety, Health and Environmental Manager.

d) Safety Director

i. Shall review the report immediately upon receipt and conduct additional investigation if required.

ii. Enter any additional measures needed for completion of the report.

iii. Shall evaluate the remediation measures recommended by the supervisor and make suggestions for further actions.

iv. Follow-up on closures of all recommendations for remediation with time schedules affixed.

v. Meet OSHA recording requirements.

vi. Notify ESCO Group management team of any incidents requiring review.  

vii. Report all incidents as required to appropriate Customer Representatives.  

viii. Follow-up with the employee’s medical provider to monitor recovery and treatment options.

ix. Coordinate return to work activities as required in the Recovery Road Map procedures.

x. Follow-up with employees, supervisors and Department Manager for implementation of return to work restrictions, work hardening, etc.

xi. Participate in development of records and case information if the claim escalates into the Worker Compensation hearing stages.

xii. Complete all necessary Workers’ Compensation reports.

xiii. Compile all claim forms for workers comp insurance provider.

xiv. Copy and distribute reports to HR Representative for Case Management.

xv. Responsible for training all personnel on their responsibilities for incident investigation.

xvi. Maintain all documentation from investigations and training.

e) Special OSHA and EPA Requirements (The Safety Director must document that this report was made.)

i. A death or hospitalization of three (3) employees from the same accident must be reported within 8 hours to the Iowa Division of Labor.  

ii. Special reporting requirements exist for environmental accident or incidents.  Normally these will be communicated to the authorities having jurisdiction.

f) Customer Reporting Requirements:

i. Incidents on customer’s property will be reported to the customer in the manner and time frame in which the customer requests.    

ii. Injuries on a customer site may be documented on the customers incident form.  If necessary, the ESCO forms will be used to verify all incident information is included.   

g) Insurance Representative

i. Will coordinate all interviews required in connection with the accident or incident with the representatives of current workers compensation insurer.

h) Chief Executive Officer or Designee

i. Will act as public information contact for communications with the media if the accident/injury warrants this level of activity.

7. Guidelines For Investigation

a) On-site Activity:

i. Every accident or incident is unique and requires an investigation tailored to the particular situation.  There are, of course, certain techniques that should be employed when gathering information to be analyzed.

ii. The following actions are recommended:

1. Survey the accident scene personally and as quickly as possible.

2. Take in all details, no matter how small, relative to the accident scene.

3. Acquire an understanding of the “big picture” using whatever information is immediately available, which in most cases is your visual assessment of the environment.

iii. This process can begin while first aid is being administered and you are working to eliminate further danger.  This initial “big picture” will also help you establish a plan for the investigation to come.

iv. The actual sequence and amounts of investigation activities vary with each investigation.  It is essential to determine   what protective equipment may be necessary to conduct the investigation safely.

b) Taking Control:

i. The first consideration at the accident or incident scene is to take care of any injured employees and ensure that the safety of all personnel is not jeopardized.  Summon emergency responders to the scene.  

1. Make certain that all injured persons receive medical attention.

2. After injured employees are cared for, secure the area.

3. Survey the area and determine what evidence will be related to the accident or incident.

4. Determine what employees have information concerning the event.

5. An accident or incident can be very disruptive to employees who are concerned for their coworkers who were involved in the accident or incident. Assure them that everything is being handled as efficiently as possible and that they can return to work.  You may have to eliminate the fears concerning their well-being.

6. Contact HR to notify employee’s spouse or individual designated as the emergency contact if the employee is hospitalized as a result of the accident.  Call HR in if necessary.

7. Seek technical assistance if necessary.

c) Securing the Area:

i. Take immediate action.  Depending on the scope and severity of the accident or incident, it may be necessary to follow procedures outlined in the “Emergency Response Plan”.  If a piece of equipment is involved, shut down the power source to machinery that could cause additional harm and lock it out.  If chemicals are involved, roping off the area or evacuation may be necessary.  Again, the severity of the accident or incident will dictate what action is to be taken.

ii. It is vital to the success of your investigation to preserve all evidence that will assist in determining the true nature of the accident or incident.  Therefore, secure the area before evidence can be destroyed.

1. Rope off the area with high visibility tape.

2. Only authorized employees are allowed to enter the accident scene area.

3. Do not touch, move, or mark anything at the accident, unless directed by investigators.

4. Identify high value, critical equipment or processes at the accident scene.

5. It is crucial to preserve the accident scene.

6. No one should be allowed to move, remove, or deface evidence.

7. Broken parts, stains, debris, scars, and marks are all forms of evidence that must not be disturbed.

8. Lockout equipment if involved in the accident.

d) Determine Depth of Investigation

i. The conditions of the accident will determine whether a large or small scale investigation must be conducted.

ii. If any of the following conditions exist, a comprehensive (large scale) investigation must be conducted:

1. A life threatening injury or illness (e.g. dismemberments, amputations, disfiguring, or critical hospitalization, etc.)

2. Could have, under slightly different circumstances, resulted in an occupational death (e.g., entrapment in equipment or confined space, etc.)

3. Involved a number of employees (e.g., fire, explosion, chemical spills, etc.)

4. A life threatening injury or illness that has a high potential to be repeated within the plant or facilities.

5. A “near miss” that could have resulted in a life threatening injury or illness.

e) Documentation of Accident Scene

i. Vital information is lost when parts at an accident or incident are mishandled by personnel who do not know how significant this part can be to the investigation.  For this reason, the investigation must be conducted immediately following the accident or incident.  This is often the case if the area must be immediately made suitable for work again.  Photographs represent a record of everything in sight.  Because they are visual, they are a form of documentation that will not change.  Remember to sign and date photographs and that photographs of the scene should be taken from all angles.

ii. Photographs can be used to identify:

1. Marks and scrapes

2. Chemical spills

3. Sand and plastics

4. Warning signs

5. Evidence of deterioration

6. Location of parts in machines

7. Location of parts on the floor

8. Location of parts on shelves and workbenches

9. Location of debris

10. Location of machines

11. The current cycle of a machine

12. Information possibly overlooked earlier.

13. The position of the equipment and control panels

f) Identification of Witnesses

i. The following personnel may be sources of information to determine the cause of an accident:

1. Injured employee.

2. Eyewitnesses:   Those who saw events leading to the accident or incident and those who came to the scene immediately after the accident or incident.

3. Co-workers having information about work habits and those who know the equipment involved.

4. Acquaintances.

5. Supervisor.

6. Customer Personnel.

7. Emergency response personnel responding to the accident or incident.

g) Interviewing Techniques:

i. Interviewing the Injured Employee or Employee Involved in the Incident:  Emphasis must immediately be placed on determining the root cause not in fixing blame.  A supervisor should not direct his inquiries as if he were looking into a case of pilfering.  Hardly ever does an employee deliberately mean to bring injury on himself or to others.  Even if the cause proves to be a personal unsafe action, the reason for it may not necessarily be negligence.  It may be wrong instructions, lack of training, or lack of job skill.

1. Put the person at ease.  Serious accidents can cause a high level of anxiety, grief or fear.  Explain the value of this interview to your investigation, and therefore in the prevention of such accidents in the future.  Avoid any hint of blame or disciplinary repercussions.  Be understanding and appreciative of your subject’s participation in your investigation.

2. Do the interview on-the-spot.  This is invariably the way to get the freshest, most accurate recall of the events that resulted in the accident.  Some situations, of course, prevent on-the-spot interviews.  It is up to the investigator to determine the most effective time and place to gather information.

3. Keep the interviews private.  This will result in uncovering information that might otherwise be withheld.  Explain to people gathered at the scene that you will be talking to each of them individually, and that everyone will have an opportunity to relate their recollection of the incident.  When conflicts in information occur, re-interview the people who delivered the conflicting information to clarify and document the differences in their stories.  If differences cannot be resolved with a private interview, then conduct an interview in the presence of ALL parties who are presenting conflicting information.

4. Do not lead the interview.  Simply allow the subject to relate the facts as they observed them, including their personal opinions.  It is your job to place a value on those opinions, not to edit them.  Do not suggest what you think happened.  Interrupt as little as possible.  Never make judgmental remarks, such as “that was a stupid thing to do”.  Wait until the interviewee is finished before you ask clarifying questions.

5. Repeat the story you have just heard back to the interviewee, as you understand it.  Again, you are repeating the interviewee’s story, not your collective knowledge and opinion.  You are attempting to verify that you have recorded the interview correctly, while allowing the person the opportunity to change the story or correct your playback.

6. End the interview on a positive note.  If the interview has contributed to your investigation in a positive way, let the person know.  Express your gratitude.

7. Record the information you have just learned as quickly as possible.  Be sure to write down names, dates, locations, times, and numerical data relevant to the incident. While it is a good idea to take notes during the interview, save this final summary until after the interview has concluded.  In the case of serious accidents, a word-for-word accounting of the interview may be necessary.  In this case, a tape recorder may be helpful.  Be aware, however, that many people are intimidated by tape recorders, particularly in a stressful accident situation.  Try to avoid using a tape recorder when possible.

8. It is important to keep in mind that information offered by a witness may not be completely accurate.  Most witnesses are not trained observers.  They may not have been paying close attention.  They may have observed only a few details and may have imagined the rest.  The witness’s own personality and perspective may distort his/her account of the accident or incident.  

9. The witness may intentionally give wrong information to protect himself or fellow employees.  All these issues must be carefully evaluated when gathering information about an accident or incident.

h) Analyzing and Determining Causes

i. There are four basic causes of accidents in the workplace.  Every accident, without exception, can be attributed to one or more of these causes.  It is not uncommon to find more than one of these causes at the root of an accident.

1. PEOPLE/PROCEDURES - because procedures dictate the behavior of people, including the operation of equipment and the management of an environment, people and procedures are considered the same when investigating an accident.  Examples of an accident that could be attributed to this category is an injury resulting from improper operation of equipment by an inexperienced and inadequately trained employee.  Servicing equipment in motion, making safety devices inoperative, horseplay, improper use of equipment and taking an unsafe position or posture.

2. EQUIPMENT - Sometimes an accident is caused when equipment fails.  If the failure is not related to an improper operation or maintenance (which are “people/procedures” issues), any accident that results from equipment failure can be attributed to this category.  Examples would be a belt snapping off a motor and striking a worker, inadequate guarding and failure to warn.

3. MATERIAL - Accidents that result in injuries from contact with materials or exposure to certain materials fall into this category.  Such an accident might include a worker who is overcome by toxic fumes.  If the incident was precipitated, however, by improper use of the toxic material, or to the failure of equipment, then the basic cause of the incident is attributed to “people/procedures” instead of “material”.

4. ENVIRONMENT - sometimes an accident occurs because of where the work is being done.  Frostbite, for example, is not attributable to people, equipment or material.  However, if the frostbite resulted from an improper procedure or a failure to use equipment correctly, then the cause can be attributed elsewhere.

5. Remember the purpose of assigning causes to accidents is NOT related to employee discipline.  It is to better understand the failure of the safety system, with a view toward correcting that system in the future.  All four of these categories should be considered and thoroughly explored in the course of an Accident Investigation.

6. In addition to the BASIC CAUSES are those acts of negligence on the part of some person or organization other than those that directly cause the accident or incident.  Examples are:

a. Inadequate codes and standards

b. Failures of supervisors and managers to perform their duties

c. Lack of enforcement

d. Faulty design

e. Inadequate maintenance

f. Inadequate training

g. Lack of safety training

ii. These factors must be explored during the Accident Investigation to ensure the evaluation of all related and root causes to the incident.  Review the investigation check list to ensure that all potential sources of information have been evaluated during the investigation.

i) Reopening the Scene of an Accident or Incident for Use

i. Once all the evidence is gathered and it is safe to return personnel to the area, remove the barriers, restore the power and allow personnel to function at the accident or incident scene as normal as possible.

j) Procedure

i. The following activities should be considered prior to releasing the accident scene:

1. Inspect the work area to ensure that nonessential items have been removed.

2. Inspect the equipment and/or machinery to be sure it is intact and capable of operating properly.

3. Check the area around the equipment and/or machinery to be sure all workers have been safely positioned or removed.

4. Remove locks.  Make sure that locks removed ONLY by those workers who attached them.

5. Notify all affected workers immediately after removing the locks and before starting the equipment and/or machinery.

6. Start equipment and/or machinery by following the proper start-up sequence.

7. Run equipment and/or machinery to verify that everything operates correctly.

k) Completing The ESCO Group Supervisor’s Investigation Report

i. The “The ESCO Group’s Supervisor’s Investigation Report. t” is a legal document of the SUPERVISOR’S account of the accident or incident.  The supervisor’s portion of the report is NOT to be completed by the involved or injured associate or by anyone other than the supervisor of that associate or acting supervisor at the time of the accident or incident.

ii. The supervisor is to explain in detail the following:

1. How the accident or incident occurred.

2. Specific body part injured (i.e., left middle finger).

3. Direct, indirect, or basic cause of accident or incident.

4. Corrective action for all accident or incident causes.

iii. Because this is a legal document, the supervisor must sign and date the report. The report must be completed in ink.  If there were no witnesses to the reported injury, the supervisor must be careful to word the report as follows:

1. “The employee alleges” or “According to the employee...... however, there were no witnesses to the accident or incident claim.”

iv. “The ESCO Group’s Supervisor’s Investigation Report should only convey that information that the supervisor knows to be true from his/her thorough investigation.  Avoid personal opinions.

v. This report, once complete, will be sent to the Safety Director for review and agreement with planned corrective actions.  The Safety Director will forward the incident information to the Management Team.

l) Making and Implementing Recommendations

i. Your investigation is likely to reveal underlying weaknesses in procedures and policies which management will want to improve.  Some changes and corrective actions will involve mechanical improvements, design improvements, disciplinary action, further employee training, and/or procedural changes.  You will probably have the authority to implement your own recommendations in most injury cases.  However, if site policy changes are necessary, these changes may exceed your authority, therefore, you will have to make recommendations to higher management.

ii. All recommendations should address ALL causes of the accident or incident occurrence.  Don’t stop short by addressing only the INDIRECT, only the DIRECT, or only the BASIC cause of the accident or incident.  All causes identified must be properly addressed to ensure that each accident or incident does not result in a second, third or fourth occurrence.  Recommendations to eliminate and control hazards are the means by which action is initiated to solve safety problems.  Recommendations must be based on the Hierarchy of Health and Safety Controls.  Select the control method according to the priority:

1. First Priority - Elimination or Substitution  Eliminates the reliance on supervisor and worker behavior for effectiveness.100% reliability Eliminates long-term cost

2. Second Priority - Engineering Controls  Minimizes inspection, maintenance, training, behavior for effectiveness, Minimizes long-term costs associated with inspection and maintenance

3. Third Priority – Warnings Relies heavily on supervisor and worker behavior for effectiveness, Minimal costs to maintain warnings

4. Fourth Priority - Training and Procedures Relies heavily on supervisor and worker behavior for effectiveness, Significant recurring costs due to supervision and retraining

5. Fifth Priority - Personal Protective Equipment Relies heavily on supervisor and worker behavior, inspection, maintenance, training for effectiveness.  Significant recurring cost due to supervision, inspection, and maintenance.

m) Legal Considerations

i. It is important for the accident or incident investigator to understand how the investigator’s activities could relate to possible litigation.  “ESCO Group’s Supervisor’s Investigation Report.” and other paperwork concerning the investigation could become admissible evidence in a legal proceeding.  This includes your opinions, recommendations, as well as the facts.  When conducting an investigation keep these points in mind:  

1. Never venture beyond the scope of your knowledge in an investigation.  If you are confronted with a technical matter for which you do not have the required training call on the expert for assistance.

2. Never destroy evidence.  Save all information gathered in a safe place.   Keep records of employee injury involvement in personnel files for future reference.

3. Confidentiality of all records pertaining to the accident or incident and personnel action taken must be maintained.

8. Illness and Injury Procedure

a) Make the injured person as comfortable as possible.  Do not remove a seriously injured person, except in extreme emergencies.

b) If the accident involves serious injury, call an ambulance immediately.

c) Telephone numbers for obtaining medical, hospital and ambulance assistance should be posted.

d) Only emergency personnel and immediate family should be allowed to ride with emergency vehicles when transporting the injured.

e) Temporary medical treatment should be administered by someone trained in standard Red Cross First Aid Practices or with equivalent training that can be verified by documentation.

f) First aid kits must be ready available if needed, there shall be a first aid kit placed in each work area on the job site. The first aid kits will contain the 22 items required by the ANSI standards. ESCO Group first aid kits will be inspected weekly and documented on the inspection sheet that is placed inside of the kits.

g) In the absence of an eye wash station on the job site the first aid kits do contain two bottles of eye wash/flushing solution.

h) The injured employee must report the accident to his foreman.  That report MUST be made no later than the end of the current shift.

i) If the accident is of serious nature, notify the company main office at once.  Be prepared to explain the circumstances of the accident, number of fatalities, if any, and the extent of injuries.

j) Secure the area as soon as possible after the accident in order to prevent any alteration of the scene before the investigation.  If this is impractical, cordon-off the area and post a security guard to keep out unauthorized personal.

k) Obtain names and address of witnesses at the scene of serious accidents.  Signed witness statements should be solicited immediately, prior to witnesses leaving the premises.  Forward all witness statements to THE ESCO GROUP main office at once.

l) Have two or more employees inspect the scene and note existing physical conditions.

m) Have photographs taken of the scene and accident and surroundings.

n) Do not antagonize accident victims or witnesses by arguing that the accident was the injured person’s fault.  Do not blame an employee at the scene for causing the accident.

o) Do not admit responsibility.

p) Do not offer to pay medical expenses.

q) Do not mention insurance.

r) Do not discuss the accident with strangers, other than the public officials.

s) Job Superintendents or their subordinates shall not make news releases or statements to the public.  Any interested party requesting information shall be informed to contact the main office.

t) If questioned by representatives of OSHA, the owner, or an insurance investigator, advise the party to contact the main office.

u) If ever served with summons, complaint or writ, send immediately to the main office.  An answer must be filed with the court within a given time period.  Legal documents received too late to file a response, will result in a default judgment.

v) Employees returning to work following medical treatment shall report to the superintendent or safety director.

w) The employee is required to report to the foreman following medical treatment whether the injury was job related or of a non-job related nature, regardless of duration.

x) Any employee suffering from a non-job related injury will not be allowed back to work until given a full release by the attending physician.

y) Any employee suffering from a job-related injury with a recommendation of light duty by the attending physician shall be put to such light duty work ONLY if available.

z) All medical bills, information and physician releases should be forwarded to the main office:

ESCO Group
Attn: Safety Department
P.O. Box 708
Marion, IA. 52302

aa) This information should contain:

i. The Insurer’s name and local address

ii. Date of occurrence and employee’s name

iii. Policy number