The 2010 Census and OSHA Rule 29 CFR 1904: A Lesson in Recordable Incidents and Safety

Understanding what qualifies as a Recordable Incident under OSHA’s Recordkeeping Rule, 29 CFR 1904 is difficult under basic work conditions. Now consider sending your workforce out of the office and into the streets (where you have limited control of the environment), the compliancy challenges grow exponentially.

Case in point, the U.S. Census Bureau currently has over 635,000 census takers canvassing the United States in what is described as “the largest peacetime mobilization our country does.” The dangers inherent in having such a mobile workforce are not lost on Dr. Robert Groves, Director of the U.S. Census Bureau, who said recently, “… when you have 600,000 people out there, all sorts of bad things happen.”

The “bad things” Dr. Groves is referring to equate to a range of recordable incidents and compliancy challenges. For instance, according to a FoxNews.com report, during the 2000 Census, the Census Bureau reported 1,103 dog bites and another 180 assaults on its employees during the canvassing period. In 2000, the Census Bureau also reported 13 auto accident deaths and a fatal dog attack.

Already this year, FoxNews.com reports there have been 15 attacks on census workers, on top of six auto accident fatalities. The question from an incident management perspective is “Are all of the above incidents recordable?” The answer is maybe.

Mitigating factors include where exactly the incident takes place, what the employee was doing and/or the type of treatment required. Given the diversity of incidents and the dynamic environments in which they occur, how can the Census Bureau or any employer with a mobile workforce know what a recordable incident is and stay compliant?

Here are four steps any establishment can follow:

Step 1: Understand the basic tenants of 29 CFR 1904 which requires employers to provide safe/ healthful workplaces and prepare and maintain records of occupational injuries and illnesses.  While the requirements are not the same for every business, some low hazard industries and businesses with fewer than 10 employees are exempt, all establishments must report incidents that result in fatalities or hospitalization of three or more employees.

Step 2: Get familiar with OSHA Forms 300, 301, and 300A. Most recordable incidents require reporting on all three forms.  Form 300 is a log of work-related injuries and illness. Form 301 is an incident report that captures details about the incident. Form 300A is a summary of work-related injuries and illnesses.

Step 3: Employ a Recordable Incident Decision Tree. Ask the following questions: Was there an injury or illness? Was it work related? Was it a new event or exposure? Does it meet the general or specific additional recording criteria?

This third step may seem simple enough; however, what seasoned safety officers can tell you is that deciding whether an incident is recordable or not is not always intuitive, especially when trying to decide if an event outside the workplace was work related or falls under the geographic presumption of a work environment.

An online Incident Management product can help you determine whether an injury or illness qualifies as a recordable incident and enables you to centralize the recording, tracking and reporting of workplace injuries, illnesses and incidents.

More importantly, it can help you track all of your data and quickly identify and address workplace hazards. And that is the ultimate goal, stopping workplace injuries and illnesses before they occur - which leads us to step four.

Step 4: Train your employees how to be safe.

This fourth step is one the U.S. Census Bureau takes seriously. According to Dr. Groves, census taker training this year included preparing for different situations and environments, dealing with angry or hostile folks, and safe driving techniques. Hopefully these precautions will be enough to reduce the number of recordable incidents during the 2010 Census.

For the rest of us, understanding what qualifies as a recordable incident is just the beginning. Today, any company can reduce the number and severity of recordable incidents, regardless of where employees work, by emphasizing safety and maintaining complete and accurate injury and illness records. Even better, there are easy-to-use online tools that can help.

Looking for a better way to manage your injury and illness records? Call MSDSonline today at 1.888.362.2007 for information about Incident Management, the online compliance management application that streamlines OSHA injury and illness recordkeeping processes.

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