AWO Safety Statistics Instruction · PDF fileAWO Safety Statistics Instruction Manual ......

46
AWO Safety Committees 2010 AWO Safety Statistics Instruction Manual

Transcript of AWO Safety Statistics Instruction · PDF fileAWO Safety Statistics Instruction Manual ......

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AWO Safety

Committees

2010

AWO Safety

Statistics

Instruction Manual

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AWO Safety Statistics

Instruction Manual 2010

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Index

I. Introduction …………………………………. page 4

II. Determination of Recordability …………………………………. page 7

III. Counting Manhours …………………………………. page 27

IV. Calculating Incident Rates …………………………………. page 31

V. AWO Safety Statistics Reporting …………………………………. page 35

VI. Appendices …………………………………. page 39

A. Registration Form …………………………………. page 40

B. Frequently Asked Questions …………………………………. page 41

C. AWO Safety Statistics Data

Job Tool …………………………………. page 42

D. Operating Sectors …………………………………. page 43

E. Useful Links …………………………………. page 44

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I. Introduction

This Injury/Illness Recordkeeping Instruction Manual was developed by the Statistics

Subcommittee of the Interregion Safety Committee as a resource for member companies

of the American Waterways Operators. The Safety Committee believes that

development of this Instruction Manual is an essential part of its mission ―to promote the

continuous improvement of safety in the towing industry‖ by providing guidance in

tracking and reporting of work-related injuries and illnesses. Collecting of injury and

illness statistics is a requirement of the American Waterways Operators (AWO)

Responsible Carrier Program (RCP), and the Safety Committee believes that gathering

and tracking of safety statistics is an essential part of any effective safety management

program. Data collected can be used to develop focused safety programs targeting

specific areas that may be revealed as a particular problem area(s) for any given

company. Data can also be used by a company to benchmark its safety performance

against other companies operating in its sector and the towing industry as a whole. In

addition to this Instruction Manual, additional help and mentoring is available to AWO

member companies needing extra assistance in collecting and reporting safety statistics

by contacting the AWO Safety Department.

This Instruction Manual seeks to respond to the need for a standardized procedure for

collecting and reporting Injury/Illness data for the tugboat, towboat, and barge industry

that, up to this time, has been missing due to insufficient guidance or direction in

maritime regulations. Some limited direction regarding injury reporting and

recordkeeping is located in 46 CFR 4.05-1 and 46 CFR 4.05-10. These provisions

instruct the maritime industry to notify the nearest Marine Safety Unit (MSU) if any

injuries beyond first aid occur and to complete a 2692 report within five days.

Since federal Occupational Safety and Health Administration (OSHA) regulations

provide guidance on injury recordkeeping in the workplace, most maritime companies

have elected to use these regulations as guidance for the collecting and reporting of injury

statistics.

To establish a standard reporting criterion for members of AWO, this Instruction Manual

provides a general overview of topics related to collecting and reporting injury and illness

statistics, including sections on Frequently Asked Questions (FAQs). This handbook is

intended to be a resource for tugboat, towboat, and barge companies of all sizes.

This Instruction Manual will provide answers to recordkeeping questions raised by

employers, and employees of AWO member companies who wish to obtain information

on specific recordkeeping criteria. The reader will find this information useful in

understanding the recordkeeping criteria of the RCP and the Voluntary Safety Statistics

Program and will be able to easily locate a variety of specific and necessary information

pertaining to each data set. Readers will also find this Instruction Manual useful as a

research and training tool for their management personnel and vessel crews.

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This Instruction Manual is divided into five sections: The first section is an introduction

that describes the use and intent of the manual; the second outlines how to determine if an

injury is a recordable injury; the third contains instructions on how to count manhours,

calculate an incident and/or severity rate, and compare their company’s numbers to the

rest of the industry in the SIC; the fourth section provides detailed instructions on how to

sign up and submit data to the AWO Voluntary Safety Statistics Program; and the fifth

and final section is an appendix that provides useful sources to gain more information.

This Instruction Manual is in the public domain and may be reproduced, fully or partially,

without permission.

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II. Determination of Recordability

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II. Determination of Recordability

Recording Criteria

Each company participating in the Responsible Carrier Program (RCP) is required to

keep records of manhours, fatalities, injuries, illnesses, and falls overboard and should

record each fatality, injury, and illness that:

is work-related;

is a new case; and

meets one or more of the general recording criteria.

Implementation

To meet the recording requirements of the RCP, the following information can be used as

a resource to assist companies in determining recording criteria for recording work-

related injuries and illnesses.

How to decide whether a particular injury or illness is recordable

The decision tree for recording work-related injuries and illnesses below shows the steps

involved in making this determination:

NO ←

Did the employee experience an

injury or illness?

YES

NO ←

Is the injury or illness work-

related?

Yes

Is the injury or illness a new case? NO → Update the previously recorded injury or

illness entry if necessary

YES

NO ←

Does the injury or illness meet the

general recorded criteria or the

application to specific cases?

→ YES

Do not record the injury

or illness Record the injury or illness

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FREQUENTLY ASKED QUESTIONS: Recording criteria

Question: Does an employee report of an injury or illness establish the existence of the

injury or illness for recordkeeping purposes?

Answer: No. In determining whether a case is recordable, the employer must first decide

whether an injury or illness has occurred. If the employer is uncertain about whether an

injury or illness has occurred, the employer may refer the employee to a physician or

other health care professional for evaluation and may consider the health care

professional's opinion in determining whether an injury or illness exists.

Basic requirement

You must consider an injury or illness to be work-related if an event or exposure in the

work environment either caused or contributed to the resulting condition or significantly

aggravated a preexisting injury or illness. Work-relatedness is presumed for injuries and

illnesses resulting from events or exposures occurring in the work environment.

Question: What is the "work environment"?

Answer: The work environment is "the vessel and other locations where employees are

working or are present as a condition of their employment. The work environment

includes not only physical locations, but also the equipment used by the employee during

the course of his or her work."

Question: Are there situations where an injury or illness occurs in the work environment

and is not considered work-related?

Answer: Yes, an injury or illness occurring in the work environment that falls under one

of the following exceptions is not work-related and, therefore, is not recordable.

You are not required to record injuries and illnesses if :

1. At the time of the injury or illness, the employee was present in the work environment as a

member of the general public rather than as an employee.

2. The injury or illness involves signs or symptoms that surface at work but result solely from a

non-work-related event or exposure that occurs outside the work environment.

3. The injury or illness results solely from voluntary participation in a wellness or flu shot

program or in exercise class, racquetball, or baseball.

4.

The injury or illness is solely the result of an employee eating, drinking, or preparing food or

drink for their own personal consumption.

Note: If the employee is made ill by ingesting food contaminated by workplace

contaminants (such as lead) or gets food poisoning from food supplied by the employer,

the case would be considered work-related.

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5. The injury or illness is solely the result of an employee doing personal tasks (unrelated to their

employment) at the establishment outside of the employee's assigned working hours.

6. The injury or illness is solely the result of personal grooming or self medication for a non-

work-related condition, or is intentionally self-inflicted.

7. The injury or illness is caused by a motor vehicle accident and occurs on a company parking

lot or company access road while the employee is commuting to or from work.

8.

The illness is the common cold or flu. (Note: contagious diseases such as tuberculosis,

brucellosis, hepatitis A, or plague are considered work-related if the employee is infected at

work.)

9.

The illness is a mental illness. Mental illness will not be considered work-related unless the

employee voluntarily provides the employer with an opinion from a physician or other licensed

health care professional with appropriate training and experience (psychiatrist, psychologist,

psychiatric nurse practitioner, etc.) stating that the employee has a mental illness that is work-

related.

Question: How do I handle a case if it is not obvious whether the precipitating event or

exposure occurred in the work environment or occurred away from work?

Answer: In these situations, you must evaluate the employee's work duties and

environment to decide whether or not one or more events or exposures in the work

environment either caused or contributed to the resulting condition or significantly

aggravated a preexisting condition.

Question: How do I know if an event or exposure in the work environment "significantly

aggravated" a preexisting injury or illness?

Answer: A preexisting injury or illness has been significantly aggravated when an event

or exposure in the work environment results in any of the following:

Death – provided that the preexisting injury or illness would likely not have resulted

in death but for the occupational event or exposure.

Loss of consciousness – provided that the preexisting injury or illness would likely

not have resulted in loss of consciousness but for the occupational event or exposure.

One or more days away from work, days of restricted work, or days of job transfer

that otherwise would not have occurred but for the occupational event or exposure.

Medical treatment in a case where no medical treatment was needed for the injury or

illness before the workplace event or exposure, or a change in medical treatment was

necessitated by the workplace event or exposure.

Question: Which injuries and illnesses are considered preexisting conditions?

Answer: An injury or illness is a preexisting condition if it resulted solely from a non-

work-related event or exposure that occurred outside the work environment.

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Question: How do I decide whether an injury or illness is work-related if the employee is

on travel status at the time the injury or illness occurs?

Answer: Injuries and illnesses that occur while an employee is on travel status are work-

related if, at the time of the injury or illness, the employee was engaged in work activities

"in the interest of the employer." Examples of such activities include travel to and from

vessels, conducting job tasks, and entertaining or being entertained to transact, discuss, or

promote business (work-related entertainment includes only entertainment activities

being engaged in at the direction of the employer).

However, injuries or illnesses that occur when the employee is on travel status do not

have to be recorded if they meet one of the exceptions listed below.

If the employee has: You may use the following to determine if an injury or illness is

work-related:

1. Checked into a

hotel or motel for

one or more days.

When a traveling employee checks into a hotel, motel, or another

temporary residence, he or she establishes a ―home away from

home.‖ You must evaluate the employee's activities after he or

she checks into the hotel, motel, or other temporary residence for

their work-relatedness in the same manner as you evaluate the

activities of a non-traveling employee. When the employee

checks into the temporary residence, he or she is considered to

have left the work environment. When the employee begins

work each day, he or she reenters the work environment. If the

employee has established a ―home away from home‖ and is

reporting to a fixed worksite each day, you also do not consider

injuries or illnesses work-related if they occur while the

employee is commuting between the temporary residence and

the job location.

2. Taken a detour for

personal reasons.

Injuries or illnesses are not considered work-related if they occur

while the employee is on a personal detour from a reasonably

direct route of travel (e.g., has taken a side trip for personal

reasons).

Determination of work-relatedness

This section sets out criteria for determining whether a given injury or illness is work-

related. An injury or illness must be considered work-related if an event or exposure in

the work environment caused or contributed to the injury or illness or significantly

aggravated a preexisting injury or illness. For recordkeeping purposes, work relationship

is presumed for such injuries and illnesses unless an exception listed specifically applies.

A number of injuries and illnesses that occur, or manifest themselves, at work are caused

by a combination of occupational factors, such as performing job-related bending and

lifting motions, and factors personal to the employee, such as the effects of a preexisting

medical condition. In many such cases, it is likely that occupational factors have played

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a tangible role in causing the injury or illness, but one that cannot be readily quantified as

"significant" or "predominant" in comparison with the personal factors involved.

Injuries and illnesses also occur at work that do not have a clear connection to a specific

work activity, condition, or substance that is peculiar to the employment environment.

For example, an employee may trip for no apparent reason while walking from one vessel

to another, be sexually assaulted by a coworker, or be injured accidentally as a result of

an act of violence perpetrated by one coworker against a third party. In these and similar

cases, the employee's job-related tasks or exposures did not create or contribute to the

risk that such an injury would occur. Instead, a causal connection is established by the

fact that the injury would not have occurred but for the conditions and obligations of

employment that placed the employee in the position in which he or she was injured or

made ill.

Employers should consider an injury or illness to be "work-related" if an event or

exposure in the work environment either caused or contributed to the resulting condition

or significantly aggravated a preexisting injury or illness. Work relatedness is presumed

for injuries and illnesses resulting from events or exposures occurring in the work

environment.

The determination of work-relatedness is made by the employer. Employers are in the

best position to obtain the information, both from the employee and the workplace, that is

necessary to make this determination. Although expert advice may occasionally be

sought by employers in particularly complex cases, the final rule provides that the

determination of work-relatedness ultimately rests with the employer.

Preexisting conditions, for recordkeeping purposes, are conditions that resulted solely

from a non-work-related event or exposure that occured outside the employer's work

environment. Preexisting conditions also include any injury or illness that the employee

experienced while working for another employer.

FREQUENTLY ASKED QUESTIONS: Determination of work-relatedness

Question: A deckhand wakes from his off-watch time complaining of back pain; would

this be considered a work injury?

Answer: Not necessarily. It would not be a work injury unless upon investigation it was

found that a preceding work-related event or exposure contributed to the back injury.

Question: A deckhand has a car wreck while driving a rental car from the vessel; is this

considered work-related even though he wasn’t “on” the vessel?

Answer: Yes, he was still ―on-duty‖ in regard to working.

Question: A deckhand has a car wreck coming to work; is this work related?

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Answer: No, he is on his own time until he reports to the office and signs in.

Question: A deckhand is injured while tripping or riding over on another vessel, not his

assigned one; is this treated the same as if he was on his own vessel?

Answer: Yes.

Question: A deckhand is injured while riding/tripping over with another company, does

that count against us?

Answer: No, it would go with the company he was working for at the time of injury.

Question: Are cases of workplace violence considered work-related under the new

Recordkeeping rule?

Answer: The Recordkeeping rule contains no general exception, for purposes of

determining work relationship, for cases involving acts of violence in the work

environment. If two crewmembers get in an altercation and one or both are injured, this

is considered a work-related incident.

Question: What activities are considered "personal grooming" for purposes of the

exception to the geographic presumption of work-relatedness?

Answer: Personal grooming activities are activities directly related to personal hygiene

such as combing and drying hair, brushing teeth, clipping fingernails, and the like.

Question: What are "personal tasks" for purposes of the exception?

Answer: ―Personal tasks‖ are tasks that are unrelated to the employee's job. For

example, if an employee uses tools from the engine room to build a bird house during his

off-watch time to take home, he is engaged in a personal task.

Determination of new cases

Employers may occasionally have difficulty in determining whether new signs or

symptoms are due to a new event or exposure in the workplace or whether they are the

continuation of an existing work-related injury or illness. Most occupational injury and

illness cases are fairly discrete events, i.e., events in which an injury or acute illness

occurs, is treated, and then resolves completely. For example, a worker may suffer a cut,

bruise, or rash from a clearly recognized event in the workplace, receive treatment, and

recover fully within a few weeks. At some future time, the worker may suffer another

cut, bruise, or rash from another workplace event. In such cases, it is clear that the two

injuries or illnesses are unrelated events and that each represents an injury or illness that

must be separately evaluated for its recordability.

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Basic requirement

You must consider an injury or illness to be a "new case" if:

The employee has not previously experienced a recorded injury or illness of the same

type that affects the same part of the body, or

The employee previously experienced a recorded injury or illness of the same type

that affected the same part of the body but had recovered completely (all signs and

symptoms had disappeared) from the previous injury or illness, and an event or

exposure in the work environment caused the signs or symptoms to reappear.

FREQUENTLY ASKED QUESTIONS: Determination of new cases

Question: When an employee experiences the signs or symptoms of a chronic work-

related illness, do I need to consider each recurrence of signs or symptoms to be a new

case?

Answer: No, for occupational illnesses where the signs or symptoms may recur or

continue in the absence of an exposure in the workplace, the case should only be recorded

once. Examples may include occupational cancer, asbestosis, and silicosis.

Question: When an employee experiences the signs or symptoms of an injury or illness,

such as an episode of occupational asthma, as a result of an event or exposure in the

workplace must I treat the episode as a new case?

Answer: Yes, because the episode or recurrence was caused by an event or exposure in

the workplace, the incident must be treated as a new case.

Question: May I rely on a physician or other licensed health care professional to

determine whether a case is a new case or a recurrence of an old case?

Answer: You are not required to seek the advice of a physician or other licensed health

care professional. However, if you do seek such advice, you must follow the physician’s

or other licensed health care professional's recommendation about whether the case is a

new case or a recurrence. If you receive recommendations from two or more physicians

or other licensed health care professionals, you must make a decision as to which

recommendation is the most authoritative (best documented, best reasoned, or most

authoritative) and record the case based upon that recommendation.

The criteria for determining whether any injury or illness, including a musculoskeletal

disorder, is to be treated as a new case or as the continuation of an ―old‖ injury or illness

are as follows: First, if the employee has never had a recorded injury or illness of the

same type and affecting the same part of the body, the case is automatically considered a

new case and must be evaluated for recordability. This provision will handle the vast

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majority of injury and illness cases, which are new cases rather than recurrences or case

continuations. Second, if the employee has previously had a recorded injury or illness of

the same type and affecting the same body part, but the employee has completely

recovered from the previous injury or illness, and a new workplace event or exposure

causes the injury or illness (or its signs or symptoms) to reappear, the case is a recurrence

that the employer must evaluate for recordability.

Question: How is an employer to determine whether an employee has "recovered

completely" from a previous injury or illness such that a later injury or illness of the

same type affecting the same part of the body resulting from an event or exposure at work

is a "new case"? If an employee's signs and symptoms disappear for a day and then

resurface the next day, should the employer conclude that the later signs and symptoms

represent a new case?

Answer: An employee has "recovered completely" from a previous injury or illness

when he or she is fully healed or cured. The employer must use their best judgment

based on factors such as the passage of time since the symptoms last occurred and the

physical appearance of the affected part of the body. If the signs and symptoms of a

previous injury disappear for a day only to reappear the following day, that is strong

evidence the injury has not properly healed. The employer may, but is not required to,

consult a physician or other licensed health care provider (PLHCP). Where the employer

does consult a PLHCP to determine whether an employee has recovered completely from

a prior injury or illness, it must follow the PLHCP's recommendation. In the event the

employer receives recommendations from two or more PLHCPs, the employer may

decide which recommendation is the most authoritative and record the case based on that

recommendation.

General recording criteria

Basic requirement

You must consider an injury or illness to meet the general recording criteria, and

therefore to be recordable, if it results in any of the following: death, days away from

work, restricted work or transfer to another job, medical treatment beyond first aid, or

loss of consciousness. You must also consider a case to meet the general recording

criteria if it involves a significant injury or illness diagnosed by a physician or other

licensed health care professional, even if it does not result in death, days away from

work, restricted work or job transfer, medical treatment beyond first aid, or loss of

consciousness.

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Implementation

A work-related injury or illness must be recorded in the manner established in company

policy if it results in one or more of the following:

- Death

- Days away from work

- Restricted work or transfer to another job

- Medical treatment beyond first aid

- Loss of consciousness

- A significant injury or illness diagnosed by a physician or other licensed

health care professional

FREQUENTLY ASKED QUESTIONS: General recording criteria

Question: How do I record a work-related injury or illness that results in the employee's

death?

Answer: A work related injury or illness that results in a death will be classified as a lost

time injury or illness and is recordable. However, the number of lost work days will not

be counted.

Question: How do I record a work-related injury or illness that results in days away

from work?

Answer: When an injury or illness involves one or more days away from work, you

should record the injury or illness according to company policy. If the employee is out

for an extended period of time, you should estimate the number of days that the employee

will be away and update the day count when the actual number of days is known.

Question: Do I count the day on which the injury occurred or the illness began?

Answer: No, you begin counting days away on the day after the injury occurred or the

illness began.

Question: How do I record an injury or illness when a physician or other licensed health

care professional recommends that the worker stay at home, but the employee comes to

work anyway?

Answer: You should record these injuries and illnesses using the number of days away

recommended by the physician or other licensed health care professional. If a physician

or other licensed health care professional recommends days away, you should encourage

your employee to follow that recommendation. However, the days away must be

recorded whether the injured or ill employee follows the physician or licensed health care

professional's recommendation or not. If you receive recommendations from two or

more physicians or other licensed health care professionals, you may make a decision as

to which recommendation is the most authoritative, based upon that recommendation.

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Question: How do I handle a case when a physician or other licensed health care

professional recommends that the worker return to work, but the employee stays at home

anyway?

Answer: In this situation, you must end the count of days away from work on the date

the physician or other licensed health care professional recommends that the employee

return to work.

Question: How do I count the days the employee would not have worked anyway?

Answer: You must count the number of calendar days the employee was unable to work

as a result of the injury or illness, regardless of whether or not the employee was

scheduled to work on those day(s). It does not matter if the employee would have been

on his normal time off or not.

Question: How do I count the lost work days if the physician says the employee needs to

be off work and they return to the vessel until the Company can safely get the employee

off the vessel?

Answer: You begin the day count the day following the appointment with the physician.

Question: How do I record a case in which a worker is injured or becomes ill on the day

before their regular scheduled time off?

Answer: You need to record a case of this type only if you receive information from a

physician or other licensed health care professional indicating that the employee should

not have worked, or should have performed only restricted work, during the scheduled

time off. If so, you should record the injury or illness as a case with days away from

work or restricted work, and enter the day counts, as appropriate.

Question: Is there a limit to the number of days away from work I must count?

Answer: Yes, you may "cap" the total days away at 180 calendar days. You are not

required to keep track of the number of calendar days away from work if the injury or

illness resulted in more than 180 calendar days away from work and/or days of job

transfer or restriction. In such a case, entering 180 in the total days away column will be

considered adequate.

Question: May I stop counting days if an employee who is away from work because of an

injury or illness retires or leaves my company?

Answer: Yes, if the employee leaves your company for some reason unrelated to the

injury or illness such as retirement, vessel lay-up, or to take another job, you may stop

counting days away from work or days of restriction/job transfer. If the employee leaves

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your company because of the injury or illness, you must estimate the total number of days

away or days of restriction/job transfer and enter the day count.

Question: 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?

Answer: No, you only record the injury or illness once. You should enter the number of

calendar days away for the injury or illness on the log for the year in which the injury or

illness occurred.

Question: How do I record a work-related injury or illness that results in restricted work

or job transfer?

Answer: When an injury or illness involves restricted work or job transfer but does not

involve death or days away from work, you should record the injury or illness as part of

your RCP recordkeeping as required by company policy.

Question: How do I decide if the injury or illness resulted in restricted work?

Answer: Restricted work occurs when, as the result of a work-related injury or illness:

You keep the employee from performing one or more of the routine functions of his

or her job, or from working the full workday that he or she would otherwise have

been scheduled to work; or

A physician or other licensed health care professional recommends that the employee

not perform one or more of the routine functions of his or her job, or not work the full

workday that he or she would otherwise have been scheduled to work.

Question: What is meant by "routine functions"?

Answer: For recordkeeping purposes, an employee's routine functions are those work

activities the employee regularly performs at least once per week.

Question: Do I have to record restricted work or job transfer if it applies only to the day

on which the injury occurred or the illness began?

Answer: No, you do not have to record restricted work or job transfers if you, or the

physician or other licensed health care professional, impose the restriction or transfer

only for the day on which the injury occurred or the illness began.

Question: If you or a physician or other licensed health care professional recommends a

work restriction, is the injury or illness automatically recordable as a "restricted work"

case?

Answer: No, a recommended work restriction is recordable only if it affects one or more

of the employee's routine job functions. To determine whether this is the case, you must

evaluate the restriction in light of the routine functions of the injured or ill employee's

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job. If the restriction from you or the physician or other licensed health care professional

keeps the employee from performing one or more of his or her routine job functions or

from working the full workday the injured or ill employee would otherwise have worked,

the employee's work has been restricted and you should record the case.

Question: How do I record a case where the crewmember works only a partial work shift

because of a work-related injury or illness?

Answer: A partial day of work is recorded as a day of job transfer or restriction for

recordkeeping purposes, except for the day on which the injury occurred or the illness

began.

Question: If the injured or ill crewmember takes longer to do a task than he or she would

have produced prior to the injury or illness but otherwise performs all of the routine

functions of his or her work, is the case considered a restricted work case?

Answer: No, the case is considered restricted work only if the crewmember does not

perform all of the routine functions of his or her job or does not work the full watch that

he or she would otherwise have worked.

Question: How do I handle vague restrictions from a physician or other licensed health

care professional, such as that the employee engages only in "light duty" or "take it easy

for a week"?

Answer: If you are not clear about the physician or other licensed health care

professional's recommendation, you may ask that person whether the employee can do all

of his or her routine job functions and work all of his or her normally assigned work shift.

If the answer to both of these questions is "Yes," then the case does not involve a work

restriction and does not have to be recorded as such. If the answer to one or both of these

questions is "No," the case involves restricted work and should be recorded as a restricted

work case. If you are unable to obtain this additional information from the physician or

other licensed health care professional who recommended the restriction, record the

injury or illness as a case involving restricted work.

Question: What do I do if a physician or other licensed health care professional

recommends a job restriction, but the employee does all of his or her routine job

functions anyway?

Answer: You must record the injury or illness as a restricted work case. If a physician or

other licensed health care professional recommends a job restriction, you should ensure

that the employee complies with that restriction. If you receive recommendations from

two or more physicians or other licensed health care professionals, you may make a

decision as to which recommendation is the most authoritative and record the case based

upon that recommendation.

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Question: How do I decide if an injury or illness involved a transfer to another job?

Answer: If you assign an injured or ill employee to a job other than his or her regular job

for part of the day due to the injury or illness, the case involves transfer to another job.

Note: This does not include the day on which the injury or illness occurred.

Question: Are transfers to another job recorded in the same way as restricted work

cases?

Answer: Yes, both job transfer and restricted work cases are recorded the same. For

example, if you assign, or a physician or other licensed health care professional

recommends that you assign, an injured or ill worker to his or her routine job duties for

part of the day and to another job for the rest of the day, the injury or illness involves a

job transfer. You must record the injury or illness.

Question: How do I count days of job transfer or restriction?

Answer: You count days of job transfer or restriction in the same way you count days

away from work. The only difference is that, if you permanently assign the injured or ill

employee to a job that has been modified or permanently changed in a manner that

eliminates the routine functions the employee was restricted from performing, you may

stop the day count when the modification or change is made permanent. You must count

at least one day of restricted work or job transfer for such cases.

Question: How do I record an injury or illness that involves medical treatment beyond

first aid?

Answer: If a work-related injury or illness results in medical treatment beyond first aid,

you must record it. If the injury or illness did not involve death, one or more days away

from work, one or more days of restricted work, or one or more days of job transfer, you

enter where the employee received medical treatment but remained at work and was not

transferred or restricted. This is considered a ―Medical‖ case only.

Question: What is the definition of medical treatment?

Answer: ―Medical treatment‖ means the management and care of a patient to combat

disease or disorder. Medical treatment does not include:

Visits to a physician or other licensed health care professional solely for observation

or counseling.

The conduct of diagnostic procedures, such as x-rays and blood tests, including the

administration of prescription medications used solely for diagnostic purposes (e.g.,

eye drops to dilate pupils).

For the purposes of recordkeeping, "first aid" means the following:

Using a nonprescription medication at nonprescription strength (for medications

available in both prescription and nonprescription form, a recommendation by a

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physician or other licensed health care professional to use a non-prescription

medication at prescription strength is considered medical treatment for recordkeeping

purposes)

Administering tetanus immunizations (other immunizations, such as Hepatitis B

vaccine or rabies vaccine, are considered medical treatment)

Cleaning, flushing, or soaking wounds on the surface of the skin

Using wound coverings such as bandages, Band-AidsTM

, gauze pads, etc.; or using

butterfly bandages or Steri-StripsTM

(other wound-closing devices such as sutures,

staples, etc., are considered medical treatment)

Using hot or cold therapy

Using any non-rigid means of support such as elastic bandages, wraps, nonrigid back

belts, etc. (devices with rigid stays or other systems designed to immobilize parts of

the body are considered medical treatment for recordkeeping purposes)

Using temporary immobilization devices while transporting an accident victim (e.g.,

splints, slings, neck collars, back boards)

Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister;

Using eye patches

Removing foreign bodies from the eye using only irrigation or a cotton swab

Removing splinters or foreign material from areas other than the eye by irrigation,

tweezers, cotton swabs or other simple means;

Using finger guards

Using massages (physical therapy or chiropractic treatment are considered medical

treatment for recordkeeping purposes)

Drinking fluids for relief of heat stress

Question: Are any other procedures included in first aid?

Answer: No, this is a complete list of all treatments considered first aid.

Question: Does the professional status of the person providing the treatment have any

effect on what is considered first aid or medical treatment?

Answer: No, the treatments listed above are considered to be first aid regardless of the

professional status of the person providing the treatment. Even when these treatments are

provided by a physician or other licensed health care professional, they are considered

first. Similarly, the treatment beyond first aid is considered to be medical treatment even

when it is provided by someone other than a physician or other licensed health care

professional. The USCG is vague on the definition of ―beyond first aid‖, and the

interpretation varies from one MSU to another.

Question: What if a physician or other licensed health care professional recommends

medical treatment, but the employee does not follow the recommendation?

Answer: If a physician or other licensed health care professional recommends medical

treatment, you should encourage the injured or ill employee to follow that

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recommendation. However, you must record the case even if the injured or ill employee

does not follow the physician’s or other licensed health care professional's

recommendation.

Question: Is every work-related injury or illness case involving a loss of consciousness

recordable?

Answer: Yes, you must record a work-related injury or illness if the crewmember

becomes unconscious, regardless of the length of time the employee remains

unconscious.

Employers will thus be clear that any condition that is treated, or that should have been

treated, with a treatment not on the first aid list is a recordable injury or illness for

recordkeeping purposes. In general, first aid treatment can be distinguished from

medical treatment as follows:

First aid is usually administered after the injury or illness occurs and at the location

(e.g., workplace) where the injury or illness occurred.

First aid generally consists of one-time or short-term treatment.

First aid treatments are usually simple and require little or no technology.

First aid can be administered by people with little training (beyond first aid training)

and even by the injured or ill person.

First aid is usually administered to keep the condition from worsening, while the

injured or ill person is awaiting medical treatment.

Question: Is a work-related skin rash recorded even if it didn't result in medical

treatment?

Answer: No, a case of work-related skin rash is recorded only if it results in days away

from work, restricted work, or transfer to another job, or medical treatment beyond first

aid.

Question: Does the size or degree of a burn determine recordability?

Answer: No, the size or degree of a work-related burn does not determine recordability.

If a work-related first-, second-, or third-degree burn results in one or more days away,

work restrictions, medical treatment, etc., the case must be recorded.

Question: If an employee dies during surgery made necessary by a work-related injury

or illness, is the case recordable?

Answer: If an employee dies as a result of surgery or other complications following a

work-related injury or illness, the case is recordable.

Question: An employee hurts his or her left arm and is told by the doctor not to use the

left arm for one week. The employee is able to perform all of his or her routine job

functions using only the right arm (though at a slower pace and the employee is never

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required to use both arms to perform his or her job functions). Would this be considered

restricted work?

Answer: No, if the employee is able to perform all of his or her routine job functions, the

case does not involve restricted work. Loss of productivity is not considered restricted

work.

Question: Are surgical glues used to treat lacerations considered "first aid?"

Answer: No, surgical glue is a wound-closing device. All wound closing devices except

for butterfly and steri strips are by definition "medical treatment," because they are not

included on the first aid list.

Question: Does "drinking fluids for relief of heat stress" on the first aid list include

administering intravenous (IV) fluids?

Answer: No, intravenous administration of fluids to treat work-related heat stress is

medical treatment.

Question: Is the use of a rigid finger guard considered first aid?

Answer: Yes, the use of finger guards is always first aid.

Question: If a physician or other licensed health care professional recommends medical

treatment, days away from work, or restricted work activity as a result of a work-related

injury or illness, can the employer decline to record the case based on a

contemporaneous second provider's opinion that the recommended medical treatment

days away from work, or work restriction are unnecessary, if the employer believes the

second opinion is more authoritative?

Answer: Yes. However, once medical treatment is provided for a work-related injury or

illness, or days away from work or work restriction have occurred, the case is recordable.

If there are conflicting contemporaneous recommendations regarding medical treatment

or the need for days away from work or restricted work activity, but the medical

treatment is not actually provided and no days away from work or days of work

restriction have occurred, the employer may determine which recommendation is the

most authoritative and record on that basis.

Question: The guide defines first aid, in part, as "removing splinters or foreign material

from areas other than the eye by irrigation, tweezers, cotton swabs, or other simple

means." What are "other simple means" of removing splinters that are considered first

aid?

Answer: ―Other simple means‖ of removing splinters, for purposes of the first-aid

definition, means methods that are reasonably comparable to the listed methods. Using

needles, pins, or small tools to extract splinters would generally be included.

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Question: How long must modification to a job last before it can be considered a

permanent modification?

Answer: Employers stop counting days of restricted work or transfer to another job if the

restriction or transfer is made permanent. A permanent restriction or transfer is one that

is expected to last for the remainder of the employee's career. Where the restriction or

transfer is determined to be permanent at the time it is ordered, the employer must count

at least one day of the restriction or transfer. If the employee whose work is restricted or

who is transferred to another job is expected to return to his or her former job duties at a

later date, the restriction or transfer is considered temporary rather than permanent.

Question: If an employee loses his arm in a work-related accident and can never return

to his job, how is the case recorded? Is the day count capped at 180 days?

Answer: If an employee never returns to work following a work-related injury, the

employer should enter an estimate of the number of days the employee would have

required to recuperate from the injury, up to 180 days.

Question: If an employee who routinely works 12 hours a day is restricted from working

more than 8 hours following a work-related injury, is the case recordable?

Answer: Generally, the employer records any case in which an employee's work is

restricted because of a work-related injury. A work restriction occurs when the employer

keeps the employee from performing one or more routine functions of the job, or from

working the full workday the employee would otherwise have been scheduled to work.

The case in question is recordable if the employee would have worked 12 hours had he or

she not been injured.

Question: If an employee is exposed to chlorine or some other substance at work and

oxygen is administered as a precautionary measure, is the case recordable?

Answer: If oxygen is administered as a purely precautionary measure to an employee

who does not exhibit any symptoms of an injury or illness, the case is not recordable. If

the employee exposed to a substance exhibits symptoms of an injury or illness, the

administration of oxygen makes the case recordable.

Question: Are work-related cases involving chipped or broken teeth recordable?

Answer: Yes, these cases are considered a significant injury or illness when diagnosed

by a physician or other health care professional. Work-related fractures of bones or teeth

are recognized as constituting significant diagnoses and, if the condition is work-related,

are appropriately recorded at the time of initial diagnosis even if the case does not

involve any of the other general recording criteria.

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Question: Does the employer have to record a work-related injury or illness if an

employee experiences minor musculoskeletal discomfort and the health care professional

determines that the employee is fully able to perform all of his or her routine job

functions, but the employer assigns a work restriction to the injured employee?

Answer: A case would not be recorded if (1) the employee experiences minor

musculoskeletal discomfort, and (2) a health care professional determines that the

employee is fully able to perform all of his or her routine job functions, and (3) the

employer assigns a work restriction to that employee for the purpose of preventing a

more serious condition from developing.

Question: An employee has a work-related shoulder injury resulting in days of restricted

work activity. While working on restricted duty, the employee sustains a foot injury

which results in a different work restriction. How would the employer record these

cases?

Answer: For purposes of recordkeeping the employer would stop the count of the days of

restricted work activity due to the first case, the shoulder injury, and enter the foot injury

as a new case and record the number of restricted work days. If the restriction related to

the second case, the foot injury, is lifted and the employee is still subject to the restriction

related to their shoulder injury, the employer should resume the count of days of

restricted work activity for that case.

Covered employees

Basic requirements

You should record the recordable injuries and illnesses of all employees on your payroll,

whether they are labor, executive, hourly, salary, part-time, seasonal, or migrant workers.

You also should record the recordable injuries and illnesses that occur to employees who

are not on your payroll if you supervise these employees on a day-to-day basis. If your

business is organized as a sole proprietorship or partnership, the owner or partners are not

considered employees for recordkeeping purposes.

Implementation

If a self-employed person is injured or becomes ill while doing work at your business,

(e.g. if an electrician or maintenance person boards the vessel to work on a piece of

equipment and is injured), you do not need to record this injury because he is not under

your direct supervision.

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III. Counting Manhours

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III. Counting Manhours

The calculation of manhours in the maritime industry differs from general industry. The

Merchant Marine Act of 1020 (Jones Act) states that employers are responsible for all

crewmembers injuries, not only those that are work-related, but also those that occur

during crewmembers’ time living aboard the vessel or during their travel to or from the

vessel. Therefore, AWO has adopted the use of a 24-hour work day for employees

living onboard the vessel.

Reporting Criteria

Crewmembers of live-aboard vessels are exposed to possible injury 24-hours per day,

therefore injuries occurring during their off-watch time are considered work-related. For

example if a crewmember is coming down the stairs to the galley during his off-watch

time and falls, this injury would be considered work-related.

Crewmember working an 8 or 12-hour day and going home during the off-duty hours,

manhours should not be counted on a 24-hour basis, but only for actual time worked.

As examples, a company operates 10 live-aboard vessels working year-round with 10

crewmembers aboard; 5 tugs working around the clock with 3 crewmembers on watch on

each tug and going home off-watch; and, 5 other tugs working 12 hours per day with 3

crewmembers each. Manhour calculations should look something like this for a 30-day

month:

10 vessels X 10 crewmembers X 24 hours X 30 days = 72,000

5 tugs X 3 crewmembers X 24 hours X 30 days = 10,800

5 tugs X 3 crewmembers X 12 hours X 30 days = 5,400

Total company manhours for the month 88,200

FREQUENTLY ASKED QUESTIONS: Counting manhours

Question: How can I find out how many vessels were running through the month and

how many crewmembers were onboard throughout the month?

Answer: Normally your Payroll Department or your Vessel Dispatch can provide you

with that information.

Question: Can I just guess at how many crewmembers were on the vessel during the

month without having to check to see if someone got sick and the boat ran short-handed

for a few days?

Answer: Yes, you can. Those few manhours would normally not make any change to

your incident rate. Conversely, your numbers would be more accurate if you received

that information from your payroll department.

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Question: Do I have to separate our office hours or our land-based operations hours

from our vessel hours for reporting purposes?

Answer: You should. Most companies report only their vessel manhours that fall under

the Jones Act. However, there is no rule that says you can’t add in your manhours for

your office support group if you report their injuries as well.

Question: Should I count the manhours of contract crews or trip employees?

Answer: If those employees are under your company’s direct supervision, then yes,

count their manhours and likewise count any of their injuries that might occur.

Question: Does a vessel need to be in operation to count the manhours?

Answer: No, if you have crewmembers onboard a vessel that is not running and they are

under your company’s direct supervision, their hours are to be counted as if it were

running.

Question: Do I need to track the times of Port Captains and Port Engineers who

frequently ride the vessels?

Answer: Normally, they are considered office personnel and usually aren’t counted.

However, if you can get an accurate count of the time they spend onboard the vessels,

you could certainly add that to your manhour count.

Question: Can I group my vessels separately for reporting purposes, such as inland dry,

canal, and fleets?

Answer: Actually, if you have vessels operating in those three areas, that is exactly what

you should be doing. This would help our industry arrive at more accurate numbers.

Question: Would I use three different forms to report those three different operations?

Answer: Yes, but you would show your company’s name and ID number on all three

forms. You should show the correct number of manhours for each operation and the

number of injuries and overboard incidents for each as well.

Question: Should I count overtime employees’ work onboard the vessel?

Answer: No, if the overtime occurs while onboard the live-aboard vessel, you are already

counting a 24-hour day. A crewmember cannot work any more than 24 hours per day.

For vessels where the crewmember goes home each day, you would count all hours

worked, including those hours of overtime work.

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Question: If a worker spends part of their time onboard a vessel and part of their time on

the dock, how would you count their hours?

Answer: This is entirely up to the employer. You could count just the time he or she is

onboard the vessel or you could count only the time where he or she spent the greatest

amount of time working.

Summary

There is very limited specific guidance for the maritime industry regarding the counting

of manhours for mariners. However, due to the requirements of the Jones Act and the

employers’ responsibilities within the act, AWO has adopted this way of counting

manhours.

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IV. Calculating Incident Rates

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IV. Calculating Incidence Rates

An incident rate is the number of recordable injuries or work-related illnesses occurring

among a given number of full-time workers over a period of time. To evaluate your

operation’s injury experience over a period of time or to compare your operation’s

experience with that of the rest of the maritime industry, you need to compute your

incident rate. (When submitting to AWO’s independent collector, those incidence rates

are calculated for you.) Because a specific number of workers and a specific period of

time are involved, these rates can help you identify problems in your operations and/or

progress you may have made in preventing work-related injuries. These rates also help

identify trends and target safety activities.

Incident rates can be calculated for different things using a standard universal formula.

This formula allows for an ―apples-to-apples‖ comparison because it takes into account

employee variations such as a different number of crewmembers onboard the vessel. The

most common incident rate is the recordable incident rate, but companies can also

compute lost-time incident rates (LTA), severity rates, recordable incident rates, or even

specific rates such as overboard incidents or slip-and-fall incidents. For example, if a

company has been experiencing numerous slip/fall injuries at its five locations, all of

different sizes, count the number of slip/fall incidents and use the manhours for each to

determine where to concentrate slip/fall prevention measures.

The standard formula, developed by the Bureau of Labor Statistics, for computing the

recordable incident rate is as follows:

The number of recordable injuries X 200,000 divided by number of manhours worked =

recordable case rate.

(The 200,000 figure in the formula represents the number of hours 100 employees

working 40 hours per week, 50 weeks per year would work and provides the standard

base for calculating incident rates.) For example, a small company working only one

vessel with nine crewmembers with one recordable injury during the year would be

exactly equal to a 65-vessel company with the same crew compliment having 65 injuries

during the year.

Lost Work Time Rate = (number of LTAs X 200,000 / total number of manhours)

Lost Work Day Rate = (number of days away from work X 200,000 / manhours)

Recordable Severity Rate = (number of days off work or restricted duty X 200,000 /

manhours

As you can see above, plug whatever category you want to measure into the first part of

the equation and determine the ―experience rate‖. The recordable severity rate is an

indicator of safety performance as it measures the more serious injuries involving lost

work days and the days of restricted duty activity. The regular recordable injury rate is

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also a good general indicator, but is limited because it gives equal weighing to both minor

and major injuries.

Maintaining incident rates allows a company to benchmark their safety program with like

operations within the maritime industry. The incident rates can also help companies

know where they should concentrate their time and efforts to reduce injuries.

FREQUENTLY ASKED QUESTIONS: Calculating Incident Rates

Question: How can I use my numbers to compare our operation with other similar

operations?

Answer: On the AWO statistics report, your numbers would be the first at the top. If

you reported your company as an ―Inland Dry‖ company for example, you would go

down the list until you find the inland dry numbers and go across to determine the

average recordable, lost-time, and overboard rates for that group, which would enable

you to benchmark with other companies.

Question: How can I compare my company’s incident rates with other companies of like

size and trades?

Answer: Actually you can’t compare your numbers with other companies the size of

your operation using the AWO report due to privacy issues. Although you could contact

companies of similar size and trade and see if they would be interested in a friendly

statistics exchange with you.

Question: Are there other ways to compare our numbers to those of others in our

industry?

Answer: Yes, the Bureau of Labor Statistics (BLS) collects data from a statistical sample

of employers in all industries and across all size classes, using the data to compile the

occupational injury and illnesses statistics for the nation. The problem with these

numbers is that they are only from a sample of operations.

Question: How can I find the Bureau of Labor Statistics numbers for my operation?

Answer: If you are looking for your BLS numbers, you will find these numbers in the

Major Group 48 – 49 for Water Transportation in the North America Industry

Classification System (NAICS) at http://www.bls.gov/iif/oshwc/osh/os/ostb1917.txt.

The old Standard Industrial Classification (SIC) was Major Group 44. Once you find

your Major Group, go down the page until you find the one that best describes your

operation.

Question: If I submit my numbers to the AWO third-party agent, is there any way

another company could figure out my incident rates?

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No. There is no way another company could figure out what anyone else submitted to

the agent. The following is a copy of the report:

As you can see from this 2008 report, it is impossible to identify any company.

Fatalities Recordable Injuries Lost Time Injuries Fall Overboards Manhours Number Rate Number Rate Number Rate Number Rate 0.18

Coastal East Quarter 1,490,830.25 0 0.00 23 3.09 14 1.88 2 0.27 YTD 6,199,457.00 0 0.00 80 2.58 48 1.55 7 0.23

Coastal Harbors Quarter 1,913,517.00 0 0.00 12 1.25 10 1.05 0 0.00 YTD 7,094,740.00 0 0.00 64 1.80 48 1.35 1 0.03

Coastal West Quarter 949,518.00 0 0.00 20 4.21 15 3.16 0 0.00 YTD 4,365,353.00 0 0.00 78 3.57 49 2.24 0 0.00

Fleets Quarter 1,005,900.25 0 0.00 18 3.58 4 0.80 4 0.80 YTD 3,709,599.72 0 0.00 97 5.23 31 1.67 21 1.13

Inland Dry Quarter 7,320,572.00 0 0.00 74 2.02 38 1.04 4 0.11 YTD 27,461,647.00 1 0.01 298 2.17 154 1.12 17 0.12

Inland Liquid Quarter 5,483,962.00 0 0.00 45 1.64 21 0.77 1 0.04 YTD 21,111,962.05 0 0.00 163 1.54 80 0.76 12 0.11

All Participants Quarter 19,537,050.00 0 0.00 203 2.08 109 1.12 11 0.11 YTD 75,446,742.77 1 0.00 818 2.17 423 1.12 63 0.17

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V. AWO Safety Statistics Reporting

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V. AWO Safety Statistics Reporting

Background

On November 1, 2002, a Working Group of the Interregion Safety Committee contracted

with the Hile Group, an independent contractor, to work with members of AWO to

collect safety statistics in four areas: crew fatalities, recordable injuries, lost-time

injuries, and man-overboard incidents. The Hile Group receives reports from

participating companies and produces summary reports on a quarterly basis. These

reports include quarterly and year-to-date totals in a format that can be used to compare a

company’s fatality, fall-overboard, and injury rates to companies of similar size engaged

in like operations and against the universe of participants as a whole. Participating

companies receive data from their own companies and aggregate totals based on

information reported by other participants. The chief method to distribute the data and

communicate with the participants is via email.

Reporting Process

Registration for this valuable, industry-wide data-gathering project is simple and

voluntary. To maintain confidentiality, AWO employs Hile Group as a trusted but

neutral third-party clearinghouse for gathering and analysis of these safety statistics.

Step One

Request a registration form by sending an email message to Hile Group

([email protected]) or calling them at 309-888-4453. Hile Group will forward four

documents to you including a registration form (Appendix A), Frequently Asked

Questions (Appendix B), an explanatory Job Tool (Appendix C), and a description of the

Operating Sectors (Appendix D).

Step Two

Fill out the registration form, which asks for the following information: your company

name; the name of the person who will submit data and receive reports; complete contact

information for that person, including address, phone number, fax, and email; and the

sector for which data is submitted. (Appendix D)

Step Three

Return the registration form to Hile Group; they will confirm receipt via email. Hile

Group’s message will include your randomly chosen confidential identification number,

additional details about how to submit data each quarter, and a schedule of deadlines for

the year.

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Step Four

Companies submit data each quarter by emailing, faxing or mailing the completed Data

Submission Form shown as –Appendix C of this manual– to Hile Group. Contact them

via email at [email protected] or via fax at 309-888-4454 or via U.S. Postal Service

to 1100 N. Beech St., Building 15, Normal, IL 61761. Hile Group is available by

telephone at 309-888-4453.

The Safety Statistics Submission Form requests the following five criteria be submitted,

by Division, on a quarterly basis:

Employee hours

Total number of crew fatalities

Total number of recordable injuries

Total number of lost-time injuries

Total number of falls overboard

This information is then entered in an analysis system, stripped of identifying information,

and compiled into timely, industry-wide reports offering a verifiable view of the health of

our maritime safety.

Corrections

You may submit corrections to your company data by emailing updated information to

[email protected] or calling the office at (309) 888-4453. Corrections will only be

accepted during the same calendar year. A final annual report will be released in May of

the following year, and no corrections will be accepted after that date.

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V. Appendices

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Appendix A.

AWO SAFETY STATISTICS PROGRAM REGISTRATION FORM

To register for the AWO Safety Statistics Program, follow these three easy steps:

1. Complete the following information:

Company name:

Name of person who will submit data/receive reports:

Contact person’s information:

Address:

Phone:

Fax:

Email:

Operating Sectors for which data is submitted (please choose one): Fleets, Inland

Dry, Inland Liquid, Coastal East, Coastal West, Coastal Harbors

2. Submit information to Hile Group

You can submit the above information to Hile Group:

Email to Hile Group associate Lora Ferraro at ([email protected]).

Fax at (309) 888-4454.

Mail to Hile Group, ATTN: Lora Ferraro, 1100 N Beech, Building 15 Normal IL

61761.

3. Receive confirmation from Hile Group:

After you register, Hile Group will send a reply email confirming registration. We

will do the following:

Randomly assign each company a confidential identification number.

Provide details on how to submit data each month.

Supply a schedule with all deadlines for current year.

Please see the Frequently Asked Questions (FAQ) sheet for more information on the

program. For a copy, contact Lora Ferraro at Hile Group—email:

[email protected] or phone: (309) 888-4453

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Appendix B.

FREQUENTLY ASKED QUESTIONS (FAQ): AWO SAFETY STATISTICS PROGRAM

How to Register to Participate and Submit Data

Q: How do I register for the first time?

Email Hile Group associate Lora Ferraro ([email protected]) the following

information:

Company name.

Name of person who will submit data/receive reports.

Contact person’s information: address, phone, fax, and email.

In return, Hile Group will send a reply email confirming registration. We will:

Randomly assign each company a confidential identification number.

Provide details on how to submit data each month.

Supply a schedule with all deadlines for current year.

007AQ: How do I submit my monthly data?

You will submit data by emailing, faxing, or mailing the completed form to Lora Ferraro

at [email protected], fax number (309) 888-4454, or 1100 N. Beech St., Building 15,

Normal, IL 61761.

Q: What are the “Operating Sectors” referred to in the introductory email?

You can submit monthly data in one or more of the following Operating Sectors:

Inland Dry, Inland Liquid, Fleets, Coastal East, Coastal West, Coastal Harbors.

Q: What do I need to submit?

There are five criteria that need to be submitted, by division, on a monthly basis:

Employee hours

Total number of crew fatalities

Total number of recordable injuries

Total number of lost-time injuries

Total number of falls-overboards

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Appendix C.

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Appendix D.

Operating Sectors

AWO Vessel Operating Sectors

Canal This sector is eliminated as few companies routinely operate on this waterway.

Data should be reported Inland Liquid or Inland Dry as applicable.

Coastal East This sector operates ocean and coastwise vessels departing from ports on the

Atlantic and Gulf Coasts on routes from Maine to the Texas Gulf Coast and on

International Voyages originating from Atlantic and Gulf Coast ports.

Coastal Harbors This sector operates vessels on Coastal Harbors such as New York, Baltimore,

Miami, Mobile, Los Angeles, Seattle, and Anchorage. Vessels generally perform

ship-assist, bunkering, and misc. harbor services. A Coastal Harbor is a protected

body of water with direct access to international waters.

Coastal West This sector operates ocean and coastwise vessels departing from ports on the

Pacific Coast on routes from San Diego to Alaska and Hawaii, and on International

Voyages originating from Pacific Coast ports.

Fleets This sector is for vessels operating exclusively or primarily in areas located on the

inland river system and Gulf Intercoastal Waterway (GIWW) designated as barge

mooring areas popularly known as fleets. Vessels in this sector generally operate

in a defined geographic area, often on a 12-hour schedule, and shift barges to make

up larger tows. Operations often include meeting line haul vessels and picking up

or dropping off barges that make up large tows.

Inland Dry This sector operates line haul vessels transporting dry cargos such as agricultural

products, coal, and construction materials on inland river routes such as the

Mississippi, Ohio, Columbia/Snake Rivers, Gulf Intercoastal Waterway (GIWW),

and Atlantic Intercoastal Waterway. These vessels generally operate on longer

voyages often transiting several states.

Inland Liquid This sector operates line haul vessels transporting liquid cargos such as petroleum,

chemicals, and fertilizer on inland river routes such as the Mississippi, Ohio,

Columbia/Snake Rivers, Gulf Intercoastal Waterway (GIWW), and Atlantic

Intercoastal Waterway. These vessels generally operate on longer voyages often

transiting several states.

Determining

Sectors

Companies that operate in different sectors may chose to report in all applicable

sectors but should not count the same injury data in more than one sector. Since

sectors are for comparison only, companies should determine which sector they

wish to compare their data against and report in that sector. Companies operating

construction equipment should report in either of the Coastal sectors or Inland

Fleets. Great Lakes Operators should report in the Coastal East sector.

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Appendix E.

Useful Links

U.S. Coast Guard Reporting Requirements (46 DFR 4.05-1) & (46 CFR 4.05-10):

http://edocket.access.gpo.gov/cfr_2008/octqtr/46cfr4.05-1.htm

OSHA Recordkeeping Handbook:

http://www.osha.gov/recordkeeping/handbook/index.html#roadmap

Bureau of Labor Statistics data:

http://www.bls.gov/iif/oshwc/osh/os/ostb1917.txt

Merchant Marine Act of 1920 (Jones Act):

http://www.insuremarine.com/WC/jonestext.html

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The American Waterways Operators

801 North Quincy Street

Suite 200

Arlington, Virginia 22203

(703) 841-9300

FAX: (703) 841-0389