Occupational Safety Incident Investigation: When Operations, Safety, and Public Scrutiny Collide

Authored by Rose Figueroa, Ph.D., CHFP, Practice Leader, Life Sciences.
Published May 11, 2026.

Human factors, biomechanics, and safety engineering analysis can uncover details of workplace incidents, helping understand not just what happened, but also what workers could realistically perceive, decide, and physically do, and whether the system supported a safe environment.

A Q&A with Dr. Rose Figueroa

High-profile workplace incidents, especially those involving large machinery, warehouse operations, or complex industrial environments, can quickly escalate beyond internal investigations into regulatory scrutiny, litigation, and public relations crises.

Understanding not just what happened, but what workers could have realistically perceived, decided, and physically done in the moment, is often central to assessing occupational incidents. It is also important to consider organizational factors and industry standards when determining whether the machinery or operational systems could have supported a safe environment.

Rose Figueroa, PhD, CHFP (Certified Human Factors Professional), is an experienced safety, human factors, and biomechanics expert, leading Rimkus’ occupational incident investigation team. We spoke with her about how organizations and legal teams can navigate these complex, high-stakes situations and work effectively with external consultants like her.

In major workplace incidents, what do you often find missing from traditional company incident and OSHA investigations?

Dr. Figueroa: Many internal investigations focus heavily on policies, procedures, or compliance checklists, but they don’t fully evaluate human performance under real-world conditions; they may also deploy tools, technology, or methodologies that may not apply to the task being tested.

What are the limitations of relying solely on OSHA’s investigation to determine the potential causes of a serious incident?

Dr. Figueroa: OSHA investigations of serious workplace accidents provide valuable insights, but they are often focused on regulatory compliance for a single employer, as that is where OSHA’s authority is rooted. OSHA’s investigation conducted in the wake of a serious workplace incident often leaves important questions not fully investigated or unanswered about the roles of individual employees, the roles of other companies or contractors, and the roles of equipment and equipment manufacturers involved in the incident.

OSHA issuing citations and penalties does not mean they have identified the cause of an incident. OSHA citations are their determination of violation of OSHA regulations, which may or may not relate to the causes of the incident itself. Reliance on OSHA to perform an investigation can also be problematic from a data-gathering perspective, as they may have limited technological resources, may delay providing investigatory materials, and/or many investigatory materials may not be available in their original formats. Additionally, OSHA personnel are not compelled to participate in subsequent private-party claims or litigation arising from an incident, so if there is something ambiguous in an inspection report, a note, or a conclusion they reached, they won’t be there to answer questions.

What are the limitations in relying on a company’s internal investigation into an incident?

Dr. Figueroa: For companies performing investigations of their own incidents, early incident investigations are performed with limited resources and time, with typical goals of determining if employee disciplinary action is warranted, salvaging a contractual relationship, or clearing a stop-work order. The internal company investigation may also be performed by an employee (commonly an internal safety manager or supervisor of the employees involved) whose own actions or inactions related to the incident may be in question. This can call into question the internal investigator’s thoroughness and objectivity in conducting the investigation and in any conclusions they reach.

Internal safety personnel and supervisors who have the responsibility of investigating an incident typically have limited prior experience with investigation of serious or catastrophic incidents – the incident they are suddenly tasked to investigate may be the first time they have ever had to document a scene forensically or interview witnesses to a serious incident. As such, companies commonly rely on personnel with little training or experience in using tools effectively to gather important forensic data in the wake of an incident.

Those personnel may have only a phone or a laptop and are often unaware of the need to fully document a scene or incident and the importance of collecting certain information or documenting certain areas beyond the immediate scene. This leads to limited data collection that can impair the ability to probe the causes of an incident, especially if the scene or equipment is subsequently changed in the wake of an incident and no longer available in its original form.

Two key questions can be left unanswered by internal investigations:

• Based on the available information and resources, did the team design and implement the task to be aligned with human capabilities and limitations?
• Did the investigation gather sufficient data adequately to answer the first question?

Without this lens, it is easy to misidentify and misattribute the causes of an incident.

How does occupational biomechanics factor into these cases?

Dr. Figueroa: Occupational biomechanics allows us to objectively evaluate what is physically feasible, with questions like the following:

• Were the force demands within reasonable human strength capabilities?
• Did posture or reach requirements increase injury risk?
• Did repetitive or cumulative exposures contribute to the incident?

These analyses help distinguish between unavoidable human limitations and design or operational deficiencies. They are especially valuable regarding environments involving:

• Material handling and logistics operations
• Heavy equipment and powered industrial trucks
• Assembly lines and repetitive tasks
• Maintenance and elevated work platforms

How do you approach cases involving large machinery or complex operations?

Dr. Figueroa: These cases often require me to integrate human factors, biomechanics, and safety engineering expertise, along with a deep understanding of the capabilities and limitations of the potential tools and equipment to be used in the evaluations.

I am typically asked to evaluate:

• Equipment design and guarding
• Operator visibility and line-of-sight
• Warning systems and signals
• Written work instructions and warnings
• Training adequacy and behavioral expectations
• Work planning and job safety analysis (JSA)
• Task analysis of individuals involved in the incident

Equally important is understanding both the top-down and bottom-up systems that workers use, and how workers actually interact with equipment and the workplace — not just how these tools are intended to be used.

This is where site inspections, a proper understanding of available technologies for gathering and analyzing data, and data-driven analysis become important.

What role do regulations and standards play in your evaluations?

Dr. Figueroa: Standards and regulations provide an important framework, but they are not the full story.

In these types of cases, it is important to understand the organizational factors, decision effects between teams, related processes, and alignment with industry-specific guidance and best practices.

Incidents our team has investigated involve many OSHA, MSHA, and industry standards, including the following:

• Safety training and education, including OSHA expectations for multi-lingual workplaces and for employees who are unable to read
• OSHA multi-employer citation policy
• OSHA’s general duty clause
• Arboricultural operations and tree-trimming safety (ANSI Z133/Z133.1)
• Baling equipment (ANSI Z245.5/Z245.51)
• Chemical hazard communication (29 CFR 1910.1200, U.S. DOT Hazardous Materials Regulations, MSDS, SDS)
• Control of hazardous energy (Lockout/tagout/LOTO) (ANSI Z244.1, 29 CFR 1910.147)
• Confined spaces (ANSI Z117 series, 29 CFR 1910.146)
• Electrical safety, including power line contact and proximity (NFPA 70E, 29 CFR 1910 Subpart S)
• Scissor lifts, boom lifts, elevated and rotating work platforms (ANSI A92 series, 29 CFR 1910 Subpart F)
• Walking-working surfaces and fall protection (29 CFR 1910 Subpart D, 29 CFR 1926 Subpart M)
• Crane operation (ASME B30 series, 29 CFR 1910 Subpart N, 29 CFR 1926 Subpart CC)
• Machine safeguarding (ANSI B11 series, 29 CFR 1910 Subpart O)
• Conveyor safety (ASME B20 series)
• Power tools and hand tools (UL 745/60745, 29 CFR 1910 Subpart P)
• Powered industrial truck training and operation (29 CFR 1910 Subpart N)
• Environmental and facility safety signs (ANSI Z535.2, 29 CFR 1910.144-145)
• Accident prevention tags and barricade tapes (ANSI Z535.5, 29 CFR 1910.144-145)
• Safety symbols (ANSI Z535.3)
• Product safety labels (ANSI Z535.4)
• Product manuals and other collateral safety information (ANSI Z535.6)

In high-profile incidents, how do you help organizations manage both legal and reputational risk?

Dr. Figueroa: In high-visibility case, such as those involving large organizations or serious injuries, there are often parallel concerns:

• Regulatory investigations
• Litigation exposure
• Public perception

My role is to provide independent, evidence-based analysis that addresses:

• What the worker could reasonably perceive and do
• Whether the system supported safe behavior
• Whether risks were foreseeable and mitigated
• Whether expectations for the work were being met in this context

This helps organizations and legal teams:

• Develop defensible positions
• Communicate findings clearly
• Identify opportunities for meaningful corrective action with evidence-based data

My experience handling high-profile and “newsworthy” cases means I know how to protect client confidentiality, manage external pressures, and stay focused on the job – no matter how much attention a case attracts. Yes, I have even been called by journalists for comment while I am still at a scene. Not ideal, but I know how to handle it.

You incorporate advanced technology into your work. How does that strengthen your analysis?

Dr. Figueroa: Technology plays a great role in translating complex events into objective, visual, and measurable insights. When applicable, I regularly use the following tools:

• Motion Capture systems to collect and analyze kinematics/human movement, posture, and relative positions, kinetics, etc.
• Wearable sensors (e.g., inertial measurement units (IMUs), accelerometers) to quantify forces and object motion and relative positions
• Illuminance or luminance meters
• Miscellaneous equipment for scene or site documentation (e.g., laser scanning, professional, comprehensive photography to support photogrammetry)
• 3D modeling, visualization, and simulations to perform human modeling and depict key components and even “reconstruct” scenes

These tools allow us to:

• Comprehensively document incident scenes and involved equipment
• Recreate incident scenes and scenarios with precision
• Evaluate alternative hypotheses for incident causation
• Evaluate design alternatives for equipment or workplaces
• Communicate technical findings in a clear manner to both technical and non-technical audiences

In litigation, this can be particularly impactful when explaining how an incident likely unfolded, the effect of different variables, and the applicability of the tools used by other experts.

What distinguishes a strong forensic analysis in occupational safety cases?

Dr. Figueroa: In my experience, a strong analysis connects the following three elements.

1. Human Performance: What the worker perceived, understood, and physically could do
2. System Design: Equipment, environment, and procedures
3. Standards and Expectations: Regulatory and industry frameworks

It’s often not enough to identify that an incident occurred — we need to understand and explain individual employees’ actions in that moment, given the conditions.

When should legal teams or companies bring in an expert like you?

Dr. Figueroa: The timeline for hiring an occupational safety expert can vary depending on the urgency, the type of matter, the required tools and equipment, or the systems involved.

Forensic Matters

• As early as possible following an incident –– in many cases, I get called as part of the rapid response expert team as I perform thorough documentation
• When human performance, training, equipment use, warnings, and instructions are at issue
• When biomechanics, such as mechanisms of injury or relative positions, are at play

Proactive Work

• During design, procurement, or process changes, as well as manuals and instructions
• When introducing new equipment or substantially changing operational demands
• When there are questions related to ergonomics, accessibility, or usability

Early involvement typically leads to better data, stronger analyses, and more actionable insights.

Meet the Expert: Rose Figueroa, Ph.D., CHFP