Answering a reader question: Is it a good idea to heavily document an accident investigation?

Bob Sands posted a question that may be on other readers’ minds about my earlier blog entry on OSHA’s new emphasis on recordkeeping.

Is the collection of real-time accident evidence/documentation (photos, video, audio etc.) a detriment or benefit to a company trying to comply with OSHA’s record keeping regulations? If we document our accidents heavily are we setting ourselves up for more scrutiny? Are there any existing or upcoming regulations that require us to gather such evidence documentation like photos/video etc.?

Here’s the answer:

A comprehensive accident investigation that includes extensive documentation and root cause analysis is never a detriment and is always a benefit to a company. In fact, a comprehensive accident investigation is an essential component of a “world-class safety program.” There is no current OSHA regulation that requires companies to investigate accidents in a prescribed manner. There is some talk in the “new OSHA” regarding another attempt at issuing a federal safety and health program standard that could require companies to document accidents in a certain way. In my opinion, a safety and health program standard will not be issued in the near future if OSHA tries to mandate all the elements of a safety and health program for all covered companies.

Companies are presently required to complete and make available the OSHA 300, 301 and 300A. Other accident investigation records requests should not be released to OSHA until you have had a chance to look at the documents and/or review them with upper management and/or legal counsel. Objections to this type of records request may be made on the grounds that the internal accident investigation is legally protected from disclosure.