How to Conduct Workplace Incident Investigations

No matter how well-prepared workers and their managers are, accidents happen every day in American workplaces. The U.S. Bureau of Labor Statistics’ most recent data shows that companies reported nearly 2.8 million nonfatal workplace injuries and illnesses in 2017. That’s a rate of about three injuries for every 100 workers.

Every small business owner needs to know how to conduct a workplace incident investigation. It’s also in a small business owner’s best interest to cultivate a safe work environment, according to EMPLOYERS’ Regional Loss Control Program Manager Dan Killins.

“Safer workplaces typically have better morale, less attrition, better housekeeping and more engaged employees,” Killins said.

Set workplace accident investigation goals

Before a workplace incident investigation can begin, a small business owner must make sure they are set up to achieve four main goals:

• Determine the root cause
• Develop and implement corrective actions
• Build a safety culture by showing commitment to safety
• Reduce costs, including not only the cost of the incident itself but also indirect costs such as higher workers’ compensation insurance premiums or costs of temporary labor

Preparation is key

Workplace injuries and illnesses can cause “suffering and great financial loss to workers and their families, and also [can] result in significant costs to employers and to society as a whole,” the Occupational Safety and Health Administration (OSHA) notes. This includes medical bills, time away from work and rising workers’ compensation insurance premiums.

More than 90% of workplace accidents are related to breakdowns in policies and procedures.

That’s why it’s critical to have prescribed procedures and courses of action already in place to both conduct workplace incident investigations and correct the conditions or behaviors that created the conditions in the first place. The National Safety Council (NSC) says owners need to pre-determine the person or people responsible for conducting an investigation. This is usually the injured person’s immediate supervisor, though it could also be a safety practitioner or members of a small business’ investigative, review or safety committee.

It’s also important to prepare an investigation kit appropriate for your workplace as a precautionary measure. The kit could include investigation and interview forms, barricade markers/tape, warning tags or padlocks, measuring tape, camera/video recorder found on any smartphone, and personal protective equipment. OSHA offers investigation forms, interview forms and more investigation kit items suggested here.

Take a systems approach

When it comes to how to do an accident investigation, small business owners need to start with the right mindset – they should aim to find causes, not people to blame, according to the NSC. OSHA recommends a “systems approach” for workplace incident investigations based on the principle that an incident’s root cause can often be “traced back to failures of the programs that manage safety and health in the workplace.” This differs from a “behavioral approach,” which attributes workplace accidents to human error or behavioral failures.

A systems approach finds program deficiencies that allowed the behavior that resulted in an incident. This diagnosis helps owners change the environment and/or circumstances that led to unsafe conditions and prevent repeat incidents.

It’s also important to investigate the “near misses,” or incidents that didn’t result in an injury. According to Killins: “You’re going to get similar learnings out of near-miss investigations, so it’s important to investigate them in the same way you would a situation that results in an actual injury.”

Find the root cause

When investigators do find deficiencies, it is important they ask why the root cause existed and why it wasn’t addressed prior to the accident. One good interrogative technique was developed by Toyota Motor Co. founder Sakichi Toyoda – The Five Whys. Asking “why” five times (more or less) helps get to the nature of a problem and a clear solution.

OSHA suggests questions such as: “Did production pressures play a role, and, if so, why were production pressures permitted to jeopardize safety?” The why is the key.

NSC outlines nine steps to follow during a workplace accident investigation:

1. Call/gather the necessary person(s) to conduct the investigation using the investigation kit.
2. Secure the area where the injury occurred and preserve the work area as it is.
3. Identify and gather witnesses to the injury event.
4. Interview the involved worker.
5. Interview all witnesses.
6. Document the scene of the injury through photos or videos.
7. Complete an investigation report, including determination of what caused the incident and what corrective actions will prevent recurrences.
8. Use results to improve the injury and illness prevention program to identify and control hazards before they result in future accidents.
9. Ensure follow-up on completion of corrective actions.

Documentation is crucial throughout the process. This includes listing incidents investigated and information collected, identifying root causes, determining corrective actions and tracking completed corrective actions.

EMPLOYERS’ Killins cautions not to let the process drive the investigation. “That’s a common error I see – letting the form drive the investigation, as opposed to just doing a root cause analysis and then using the data to complete that form,” he said. “What happens is investigators complete the form, but restrict the flow of the investigation in order to check the boxes.” That’s not to say forms and checklists aren’t helpful, especially because investigators must report and keep track of a lot of information. NSC provides a detailed and helpful list of information to gather:

1. Worker characteristics (age, gender, department, job title, experience level, tenure in company and job, training records, and employment status)
2. Injury characteristics (describe the injury or illness, part(s) of body affected and degree of severity)
3. Narrative description and sequence of events (location of incident; complete sequence of events leading up to the injury or near miss; objects or substances involved in the event; conditions such as temperature, light, noise, weather; how the injury occurred; whether preventive measure had been in place; what happened after the injury or near miss occurred)
4. Characteristics of equipment associated with the incident (type, brand, size, distinguishing features, condition, specific part(s) involved)
5. Characteristics of the task being performed when the incident occurred (general task, specific activity, posture and location of injured worker, working alone or with others)
6. Time factors (time of day, hour in injured worker’s shift, type of shift, phase of worker’s day such as performing work, break time, mealtime, overtime, or entering/leaving facility)
7. Supervision information (whether the injured worker was being supervised directly when the injury occurred, whether supervision was feasible)
8. Causal factors (specific events and conditions contributing to the incident)
9. Corrective actions (immediate measures taken, interim or long-term actions necessary)

In the end, small businesses owners must always remember the most important goal for workplace accident investigations.

“It cannot be stressed enough that a successful incident investigation must always focus on discovering the root causes,” OSHA emphasizes. “Investigations are not effective if they are focused on finding fault or blame… The main goal must always be to understand how and why the existing barriers against the hazards failed or proved insufficient.”

EMPLOYERS® is committed to helping small businesses operate safer, more efficient workplaces. Contact EMPLOYERS® today to learn more about our cost-effective workers’ compensation insurance.

The information provided is intended to provide a general overview. This information is not legal advice and should not be relied on as such. EMPLOYERS® makes no warranties for the accuracy, adequacy, or completeness of the information provided, and will not be responsible for any actions taken based on the information contained herein. If you have legal questions or need legal advice, please consult an attorney.