Incident Management System FAQ: What Safety Managers Need to Know
Recently, ERA hosted a webinar about OSHA compliance for workplace incidents that focused on Incident Management Systems and automation. Our attendees submitted some of their most pressing questions, and ERA's safety experts have added in some of the most incident management frequently asked questions (FAQs) that they come across. They also touch upon the new OSHA Electronic Reporting Requirements that have rolled into effect. This short article compiles all of their answers for your convenience.
By the way, you can access the Incident Management System webinar on demand for free today by clicking here:
Are OSHA electronic reporting requirements based on the size of the establishment or the size of my firm?
The electronic reporting requirements are based on the size of the establishment, and not on the size of the firm. OSHA injury and illness records are maintained at the establishment level.
An establishment is defined as a single physical location where business is conducted or where services or industrial operations are performed, whereas a firm may be comprised of one or more establishments.
To determine if you need to provide OSHA with the required data for an establishment, you need to determine the establishment's peak employment during the last calendar year. Each individual employed in the establishment at any time during the calendar year counts as one employee, including full-time, part-time, seasonal, and temporary workers.
If a case occurs in one year but results in days away during the next calendar year, do I record the case in both years?
No, you only record the injury or illness once.
You must enter the number of calendar days away for the injury or illness on the OSHA 300 Log for the year in which the injury or illness occurred. If the employee is still away from work because of the injury or illness when you prepare the annual summary, estimate the total number of calendar days you expect the employee to be away from work, use this number to calculate the total for the annual summary, and then update the initial log entry later when the day count is known or reaches the 180-day cap.
May a third party submit data for an establishment or firm?
Yes, just as a third party is allowed to maintain the injury and illness records for an employer, a third party is also allowed to submit the data for that employer. It is a common practice to employ a consultant or use an incident management system to handle OSHA record keeping.
However, for record keeping the responsibility for the completeness and accuracy of the data lies with the employer, not the third party. It's a best practice to always review all incident data managed by a third-party consultant or platform before it gets a final submission. You are accountable for any errors submitted on your behalf.
My firm has multiple establishment that do different things. Which determines whether I have to submit data for those establishments: the industry classification of the firm, or the industry classification of the establishment?
The electronic reporting requirements are based on the industry classification of the establishment, not the industry classification of the firm.
Two groups of establishments are required to electronically submit data to OSHA:
- Establishments with 20-249 employees in certain industries.
- Establishments with 250 or more employees in industries subject to OSHA's record keeping requirement.
Establishments that are partially exempt from OSHA's record keeping due to industry are not required to submit data, regardless of establishment size.
How would my company go about integrating with an insurance provider for digital claim submission?
Our first step in integrating with an insurance company or third-party administration would be to first meet with them to determine the relevant fields required for integration.
These fields normally include:
- employee address
- employee contact information
- facility/location address
- employee social security number… etc. It's different for every insurance company we work with, so there's no single set of standards.
This is a combination of very sensitive information as well as general information. To pull the information to the insurance company or third-party administration seamlessly, a table is setup with all of the different information. Once the table is created ERA can create an HR template to ensure all of the employee is captured in a daily, weekly or monthly import. The data would be encrypted so only HR managers would be able to view it.
This, at least, is how ERA integrates our OSHA records with insurance providers to enable automated electronic submission. If you're working with your own internal databases, you would need to follow a similar procedure: creating tables that match your providers, encrypting data, and working with them to build a portal between your databases.
Where do I log in to create the account to begin logging information? Do you need to input information from previous years?
To create an account and log information, OSHA provided an Injury Tracking Application which is accessible using the following link:
For the second part of this question the answer is yes. You need to submit your OSHA log for the year 2016 by December 31, 2017. If your establishment has more than 20 employees you should log information related to OSHA 300A form in the Injury Tracking Application.
You can also find more answers from OSHA's official website here: https://www.osha.gov/injuryreporting/
Watch the On-Demand Incident Management Webinar for Free Today
This FAQ only skimmed the surface of the Incident Management topics covered in the 40 minute webinar - you can view the webinar in its entirety on demand simply by clicking the button below to gain access.
If you have any questions you'd like to see added to this Incident Reporting System FAQ, let us know in the comments.
Meet the Expert
Dr. Ehsan Maghsoudi has been an Environmental, health and safety enthusiast for over 10 years. He has written extensively in peer-reviewed journals about environmental pollutants and toxic compounds. His most memorable EH&S moment is when he was caught in a torrential storm during field work… he managed to get his water samples and a little more water than he expected.