b'SAFETY CSIA 33Thefirststepinagoodaccidentinvestigationthat should be done for every accident. This may procedure is to require that all accidents, whether antakeupsomeofthesupervisorsvaluabletime; employee injury, or property damage, be reportedhowever, these interviews should always be done tothesupervisorassoonaspossible.29CFRbytheresponsiblesupervisor,eveninthecase 1904.35(b)(1)(i)you must establish a reasonableof a very minor accident. Also remember that by procedureforemployeestoreportworkrelatedbeing a safety conscious employer, accidents are injuriesandillnessespromptlyandaccurately.not normally an everyday, or frequent, occurrence. A procedure is not reasonable if it would deter orTherefore, we are not talking about taking a lot of discourage a reasonable employee from accuratelythe supervisors time to do an initial investigation. reporting a workplace injury or illness.You cannot require immediate reporting. Thisalsomeansthateverysupervisorshould be trained in the basics of accident investigation, Ibelievethatagoodaccidentinvestigation,andincludingwitnessinterviews.Howyouchooseto the records of those accident investigations, mustapproach accident investigations should not devolve be performed every time an accident occurs. Thisinto taking shortcuts or into pencil-whipping the will also go far to establish that you are concernedaccident investigation forms. One thing you should about the safety of your employees and that younever do in performing an accident investigation, have a strong safety culture. I recommend that anomatterhowminortheaccidentmayseem,is writtenrecordbemaintainedofeveryaccidentto merely hand out an accident report form to the investigation.Notonlyshouldtheinvestigationemployee(s) involved, ask them to complete it, and documentationshowthatyouinvestigatedandreturn it back to you. Employees should never fill out identified the cause of the accident, but also whatthe investigation forms. corrective action should be, and has been, taken. Remember,anytimethatanemployeeisinjured,No matter how minor an accident may seem, we you have an exposure to liability, at least throughstill need to remember that there are really no small workers compensation but sometimes beyond thataccidentsorincidents.Atthetimetheaccident administrative remedy. These might include thingsoccurs, you will have no clear idea as to how it may that are OSHA-related, and/or indemnification andevolve. For example, after spending decades doing hold-harmlessagreementsthatyoumayhaveworkers compensation defense work for large and signed with the owner of other contractors.small employers, I have seen many minor accidentsCENTRAL STATES INSULATION ASSOCIATIONand/or injuries become magnified MANY times over So, now you are reading this and thinkingdo Iby an aggressive claimants workers compensation have to pull together an entire accident investigationlawyer. Several years ago, I represented a large, team every time someone cuts his finger, gets aself-insured company that employed truck drivers as bandaid,orbruiseshis/herelbow?Theanswerpart of its workforce. I received a call from my client to that is NO! However, I do recommend that youthat he wished me to defend a suspicious workers establishahierarchyforstaffingandconductingcompensation claim that had been filed by one of accidentinvestigations.Obtainingsomebasicthese drivers. My client, who was very experienced information and employing a few basic proceduresin accident investigation and safety-related claims, should be followed in all accident investigations.gathered the claim history through his investigation. The claimant alleged that as he stepped out of his First,youshouldalwaysinterviewtheinjuredtruck cab onto a gravel parking area, he stepped employee.Iftherewasnoinjury(justpropertyonto a small stone that bruised the big toe on his left damage), interview the employee who either wasfoot. My client had performed his usual (excellent) aneyewitnesstotheaccident,orwhoseactionsinvestigation, which revealed that the claimant had may have caused, or contributed, to the accident.been wearing standard work shoes with a thick sole The procedure that I describe above is the minimumwhen he stepped on the stone.continuedpg.34csiaonline.org'