Day 20: Incidents, Recordkeeping, Metrics, and Module Mini-Exam
10% of the exam - about 2 hours - 14 practice questions
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Reading
Incident Response
The sequence when an incident occurs: secure the scene and care for the injured first, notify per the emergency plan, preserve the scene and evidence, investigate to root cause, implement corrective action, and communicate the lessons across the site.
Reporting and recording deadlines run in parallel with this sequence; they do not wait for the investigation to finish.
Reporting to OSHA
The thresholds are specific and appear on the exam. A work-related fatality must be reported within 8 hours. A work-related in-patient hospitalization, amputation, or loss of an eye must be reported within 24 hours. The clock runs from when the employer learns of the event. A death is reportable only if it occurs within 30 days of the work-related incident, and a hospitalization, amputation, or loss of an eye only if it occurs within 24 hours of the incident. Reporting is to OSHA directly, by phone or the online form.
Recordkeeping
Under 29 CFR 1904, covered employers must maintain the OSHA 300 log of recordable injuries and illnesses, the 301 incident report, and the 300A annual summary, which must be posted from February 1 through April 30. Employers with 10 or fewer employees, and establishments in certain low-hazard industries, are partially exempt from routine recordkeeping, but construction is not on the low-hazard industry list. Every employer, even an exempt one, must still report fatalities and severe injuries.
A case is recordable if it involves death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, loss of consciousness, or a significant diagnosis by a licensed health care professional. The first aid exclusion is the distinction most often tested: a defined list of treatments counts as first aid and does not make a case recordable, while treatment beyond that list does.
Root Cause Analysis
The exam's posture on investigation is that stopping at the immediate cause is a failure. "Worker was not wearing fall protection" is not a root cause; it is an observation. The root cause analysis asks why: was the equipment available, was the anchorage provided, was the worker trained, was production pressure rewarded over stopping, did supervision enforce, was the JHA done and communicated? Corrective actions aimed at the system prevent recurrence, while corrective actions aimed only at the individual generally do not.
Leading versus Lagging Indicators
This distinction is tested and it matters.
Lagging indicators measure outcomes after the fact: Total Recordable Incident Rate, Days Away Restricted or Transferred rate, Experience Modification Rate, lost time cases, fatalities. They are objective and comparable but they tell you only about failures that already happened, and on a project small enough, a zero TRIR may reflect luck rather than safety.
Leading indicators measure activity that precedes outcomes: near-miss reports, safety observations completed, JHAs performed, training hours delivered, toolbox talks held, percentage of corrective actions closed on time, inspection findings closed. They predict rather than count.
A mature program tracks both, and the exam rewards recognizing that managing only to lagging indicators creates a perverse incentive to under-report. A site whose near-miss reporting rises is often getting safer, not more dangerous, because near misses are being surfaced rather than hidden.
TRIR is calculated as the number of recordable incidents multiplied by 200,000, divided by total hours worked. The 200,000 represents 100 full-time workers at 40 hours for 50 weeks, which normalizes rates across projects of different sizes. Expect at least one calculation.
Experience Modification Rate compares a company's workers' compensation loss history to the industry average. An EMR of 1.0 is average, below 1.0 is better than average, and many owners set a maximum EMR as a prequalification threshold. A CM advising an owner on contractor prequalification should understand that EMR is a lagging measure and a small contractor's EMR can swing on a single claim, so it belongs in a prequalification package alongside program review and reference checks rather than as a sole gate.
Safety and the Schedule
The exam periodically tests the relationship between schedule pressure and incidents. Acceleration, overtime, trade stacking, and night work all correlate with increased incident rates. A CM evaluating an acceleration proposal should account for safety risk as one of its costs, and a CM who accelerates without adjusting safety staffing and planning has accepted a risk on the owner's behalf without saying so.
Practice Questions
1. A work-related fatality must be reported to OSHA within:
24 hours
8 hours
4 hours
7 days
Answer: b. Eight hours for a fatality. The short window exists so OSHA can see the scene before it changes.
2. A work-related amputation must be reported within:
30 days
8 hours
24 hours
72 hours
Answer: c. Twenty-four hours for an amputation, as for an in-patient hospitalization or loss of an eye. Fatalities are the eight-hour case.
3. The OSHA 300A annual summary must be posted:
Only on request
January 1 to March 1
Year round
February 1 to April 30
Answer: d. February 1 through April 30. The 300A summary goes up where employees can see it, which is the point of posting rather than filing it.
4. A case requiring medical treatment beyond first aid is:
Recordable
Exempt in construction
Not recordable
Reportable within 8 hours
Answer: a. Medical treatment beyond first aid makes a case recordable. Recordable and reportable are different tests: recording goes in the log, reporting means calling OSHA.
5. "The worker was not tied off" is best characterized as:
A root cause, because it names the exact behavior that led to the fall
A corrective action
A leading indicator
An immediate cause or observation, not a root cause
Answer: d. Not tied off describes what was observed, not why. The root cause is whatever made not tying off possible or normal: no anchorage, no enforcement, schedule pressure, missing equipment.
6. Near-miss reporting rate is:
Not a safety metric
Required by 1904
A leading indicator
A lagging indicator
Answer: c. Near-miss reporting looks forward. It tells you about hazards before anyone is hurt, which is the definition of a leading indicator.
7. TRIR is calculated as recordables multiplied by 200,000 divided by:
Days on site
Contract value
Total hours worked
Number of employees
Answer: c. Recordables times 200,000 divided by total hours worked. The 200,000 normalizes to 100 full-time workers over a year, so sites of different sizes can be compared.
8. A project worked 400,000 hours with 4 recordable incidents. TRIR is:
4.0
0.5
1.0
2.0
Answer: d. 4 times 200,000 divided by 400,000.
9. An EMR of 0.85 indicates:
Nothing meaningful
Exactly average
Better than industry average
Worse than industry average
Answer: c. EMR is indexed to 1.0 as the industry average. Below 1.0 means better than average loss experience, and it directly affects workers compensation premium.
10. Managing exclusively to lagging indicators risks:
Lower EMR accuracy
Improved reporting
Higher training rates
A perverse incentive to under-report incidents
Answer: d. Lagging indicators only move when someone gets hurt. Managing to them alone creates pressure to keep the number down, and the easiest way to do that is to not record things.
11. A CM accelerates a project with overtime and trade stacking without adjusting safety staffing. The CM has:
Accepted increased safety risk on the owner's behalf without disclosing it
Managed cost well
Reduced liability, because overtime shifts responsibility for safety onto the trade contractors
Improved leading indicators
Answer: a. Overtime and trade stacking both raise incident risk. Accelerating without adjusting safety staffing accepts that risk on the owner's behalf, and not telling the owner removes their ability to weigh it.
12. A worker receives an over-the-counter pain reliever and a bandage for a minor cut and returns to full duty the same day. This case is:
Recordable, since any treatment triggers recording
Not recordable, since it falls within the first aid exclusion
Reportable within 24 hours, since the worker received treatment on site
Reportable within 8 hours
Answer: b. Over-the-counter medication and a bandage for a minor cut, with a same-day return to full duty, sit inside the defined first aid list. The case is not recordable on that basis alone.
13. A project worked 250,000 hours with 2 recordable incidents. TRIR is:
1.6
2.0
4.0
0.8
Answer: a. 2 times 200,000 divided by 250,000 equals 1.6. Working the formula on unfamiliar numbers, not just recalling a memorized answer, is what the exam is checking.
14. A site owner sets a maximum EMR as a prequalification cutoff and treats it as the sole basis for approving or rejecting a small contractor. The most accurate criticism of this approach is:
EMR should never be used in prequalification, because workers' compensation history says nothing about safety practice
EMR is a lagging, noisy measure for small contractors, so it belongs beside program review and references
EMR only applies to general industry, not construction, because construction contractors are rated under a separate index
A lower EMR always means a less safe contractor
Answer: b. EMR is useful but noisy at small scale. One claim can move a small contractor's number substantially, so treating it as the only gate risks screening out contractors whose actual safety practice is sound.
Glossary
Recordable
An incident meeting OSHA's 1904 threshold (medical treatment beyond first aid, days away, restriction, or transfer), logged on the OSHA 300.
Reportable
An incident that must be called in to OSHA directly: a fatality within 8 hours, or an in-patient hospitalization, amputation, or loss of an eye within 24 hours.
OSHA 300A
Annual summary of recordable cases, posted where employees can see it from February 1 through April 30.
Root Cause
The underlying condition that made an unsafe act or condition possible or normal, distinct from the immediate observation ("not tied off").
Leading Indicator
A forward-looking safety metric, such as near-miss reports or toolbox talks, that moves before anyone is hurt.
Lagging Indicator
A metric that only moves after an incident, such as TRIR or lost time cases.
TRIR
Total Recordable Incident Rate: recordables times 200,000, divided by total hours worked.
EMR
Experience Modification Rate, indexed to 1.0 as the industry average; used in contractor prequalification alongside other factors, not as a sole gate.
First Aid Exclusion
Defined list of minor treatments that do not make a case recordable even though care was given.
OSHA 301
Incident report documenting the details of each recordable case, maintained alongside the OSHA 300 log.