Analysis of Stagnant Total Recordable Injury Frequency (TRIF) in Long-Term Care Facilities (LTCF)

This document analyzes potential causes for a stagnant Total Recordable Injury Frequency (TRIF) despite a reduction in the number of incidents in Long-Term Care Facilities (LTCF). It provides safety documentation and regulatory guidance to address this issue.

Introduction

A stagnant TRIF despite a reduction in the number of incidents suggests that while the frequency of events leading to injuries may be decreasing, the severity of the recordable injuries sustained in those events remains consistent. This indicates underlying issues in incident management, hazard control, or recordkeeping practices.

Potential Causes for Stagnant TRIF

Inadequate Incident Investigation and Corrective Actions

Description:

If incident investigations are not thoroughly identifying the root causes of incidents, corrective actions may only address the symptoms rather than the underlying problems. This can lead to similar incidents recurring, maintaining a consistent level of recordable injuries.

Corrective Actions:

Employers need to develop in-house capability to investigate incidents that occur in their facilities. A team needs to be assembled by the employer and trained in the techniques of investigation including how to conduct interviews of witnesses, needed documentation and report writing. A multi-disciplinary team is better able to gather the facts of the event and to analyze them and develop plausible scenarios as to what happened, and why. Team members should be selected on the basis of their training, knowledge and ability to contribute to a team effort to fully investigate the incident. Employees in the process area where the incident occurred should be consulted, interviewed or made a member of the team. Their knowledge of the events form a significant set of facts about the incident which occurred. The report, its findings and recommendations are to be shared with those who can benefit from the information. The cooperation of employees is essential to an effective incident investigation. The focus of the investigation should be to obtain facts, and not to place blame. The team and the investigation process should clearly deal with all involved individuals in a fair, open and consistent manner. [7]

Regulatory Guidance:

OSHA expects employers to become aware and to investigate incidents that result in or could reasonably have resulted in a catastrophic release. Some of the events are sometimes referred to as "near misses," meaning that a serious consequence did not occur, but could have. [1]

Inadequate Hazard Control Measures

Description:

Existing control measures may not be effective in preventing injuries, or new hazards may have emerged that are not adequately controlled. This could be due to a failure to reassess hazards regularly or a lack of implementation of appropriate engineering or administrative controls.

Corrective Actions:

Employers should conduct ongoing, periodic in-house safety and health inspections so that new or previously missed hazards or failures in controls are identified. Inspections shall be conducted with a frequency necessary to be effective. [4]

Regulatory Guidance:

Employers must review injury and illness trends over time, so that patterns with common causes are identified and eliminated. [4]

Changes in Processes or Procedures Not Adequately Managed

Description:

Changes in LTCF operations, such as new equipment, procedures, or resident care protocols, can introduce new hazards or alter existing ones. If these changes are not properly evaluated and managed, the risk of injury can increase.

Corrective Actions:

Proper documentation and review of these changes is invaluable in assuring that the safety and health considerations are being incorporated into the operating procedures and the process. [1]

Regulatory Guidance:

For existing processes that have been shutdown for turnaround, or modification, etc., the employer must assure that any changes other than "replacement in kind" made to the process during shutdown go through the management of change procedures. P&IDs will need to be updated as necessary, as well as operating procedures and instructions. If the changes made to the process during shutdown are significant and impact the training program, then operating personnel as well as employees engaged in routine and nonroutine work in the process area may need some refresher or additional training in light of the changes. [6]

Inadequate Training

Description:

If employees are not adequately trained on safe work practices, hazard recognition, and the use of safety equipment, they may be more likely to sustain injuries, even if the overall number of incidents decreases.

Corrective Actions:

Employers need to periodically evaluate their training programs to see if the necessary skills, knowledge, and routines are being properly understood and implemented by their trained employees. The means or methods for evaluating the training should be developed along with the training program goals and objectives. Training program evaluation will help employers to determine the amount of training their employees understood, and whether the desired results were obtained. If, after the evaluation, it appears that the trained employees are not at the level of knowledge and skill that was expected, the employer will need to revise the training program, provide retraining, or provide more frequent refresher training sessions until the deficiency is resolved. Those who conducted the training and those who received the training should also be consulted as to how best to improve the training process. If there is a language barrier, the language known to the trainees should be used to reinforce the training messages and information. Careful consideration must be given to assure that employees including maintenance and contract employees receive current and updated training. For example, if changes are made to a process, impacted employees must be trained in the changes and understand the effects of the changes on their job tasks (e.g., any new operating procedures pertinent to their tasks). Additionally, as already discussed the evaluation of the employee's absorption of training will certainly influence the need for training. [6]

Regulatory Guidance:

Hands-on-training where employees are able to use their senses beyond listening, will enhance learning. For example, operating personnel, who will work in a control room or at control panels, would benefit by being trained at a simulated control panel or panels. Upset conditions of various types could be displayed on the simulator, and then the employee could go through the proper operating procedures to bring the simulator panel back to the normal operating parameters. A training environment could be created to help the trainee feel the full reality of the situation but, of course, under controlled conditions. This realistic type of training can be very effective in teaching employees correct procedures while allowing them to also see the consequences of what might happens if they do not follow established operating procedures. Other training techniques using videos or on-the-job training can also be very effective for teaching other job tasks, duties, or other important information. An effective training program will allow the employee to fully participate in the training process and to practice their skill or knowledge. [6]

Inadequate Recordkeeping

Description:

Inconsistent or inaccurate recordkeeping practices can distort the TRIF. For example, if minor injuries are not consistently recorded, or if the severity of injuries is underestimated, the TRIF may not accurately reflect the facility's safety performance.

Corrective Actions:

Employers must record new work-related injuries and illnesses that meet one or more of the general recording criteria or meet the recording criteria for specific types of conditions. [5]

Regulatory Guidance:

A work-related injury or illness must be recorded 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, 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. [3]

Employee Reluctance to Report Injuries

Description:

Employees may be reluctant to report injuries due to fear of reprisal, concerns about job security, or a perception that reporting injuries is discouraged. This can lead to an underreporting of injuries, which can mask the true TRIF.

Corrective Actions:

Employers should properly document the contact information of all parties because follow-up interviews with a witness are sometimes necessary. [2]

Regulatory Guidance:

Employees are not required to inform their employer that they provided a statement to OSHA. [2]

Focus on Minor Injuries

Description:

If the reduction in incidents primarily involves minor injuries while more severe incidents remain unchanged, the TRIF may not decrease significantly. A focus on preventing severe injuries is crucial.

Corrective Actions:

Employers must provide a mechanism to investigate accidents and "near miss" incidents, so that the root cause and means for preventing a recurrence are identified. For the purposes of this section, the term "accident" means any unexpected happening that interrupts the work sequence or process and that may result in injury, illness, or property damage. [4]

Emergency Preparedness

Description:

Each employer must address what actions employees are to take when there is an unwanted release of highly hazardous chemicals. Emergency preparedness or the employer's tertiary (third) lines of defense are those that will be relied on along with the secondary lines of defense when the primary lines of defense which are used to prevent an unwanted release fail to stop the release. [7]

Conclusion

Addressing a stagnant TRIF requires a comprehensive approach that includes thorough incident investigation, effective hazard control measures, proper management of change, adequate training, accurate recordkeeping, and fostering a culture of safety where employees feel comfortable reporting injuries. Regular audits and reviews of safety programs are essential to identify and correct any deficiencies.

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