HCR 264 Module 5 Root Cause Analysis: OSHA Incident Report and Five Whys Example

Reviewed by Emmett Rockwell, MBA Arizona State University Updated October 2026

This HCR 264 Module 5 sample is the Root Cause Analysis Paper, written for the compliance design course that ASU Health Care Compliance and Regulations students take in their compliance core. The third writing assignment in ASU HCR 264 asks students to complete an OSHA incident report template from a real OSHA case and then analyze its causes with outside research. The composite student uses the case OSHA announced in May 2024: on November 7, 2023, a patient at Circles of Care's Sheridan West unit in Melbourne, Florida, struck a mental health technician at a nurse's workstation with a metal hole punch. OSHA cited a repeat General Duty Clause violation and a late hospitalization report. The paper fills in the form, asks why five times and proposes corrective actions.

CourseHCR 264 Regulatory Essentials of Compliance Program Design
ModuleModule 5
Paper typeOSHA incident report and root cause analysis
LengthAbout 726 words, 5 pages
FormatAPA 7 student paper
SchoolArizona State University
ProgramBS in Health Care Compliance and Regulations
UpdatedOctober 2026

Free sample paper for HCR 264 Module 5

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Incident Report and Root Cause Analysis: A Patient Assault on a Mental Health Technician

Student Name

BS in Health Care Compliance and Regulations, Arizona State University

HCR 264: Regulatory Essentials of Compliance Program Design

Instructor Name

Month Day, Year

What this page is doingThe title states both parts of the deliverable and the event, without naming the injured worker.
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Incident Report and Root Cause Analysis: A Patient Assault on a Mental Health Technician

Purpose

This report reconstructs an OSHA-recordable injury from public enforcement records, completes the information an employer must capture on an injury and illness incident report and analyzes why the event happened. The injured employee is not named; employer records would identify the worker, but a public analysis has no need to.

Part 1: Incident Report

The fields below follow OSHA's Form 301, the Injury and Illness Incident Report, which employers must complete within seven days of learning of a recordable case (Occupational Safety and Health Administration [OSHA], 2024).

Form fieldEntry
EmployerCircles of Care Inc., psychiatric and rehabilitation services, Melbourne, Florida
EstablishmentSheridan West Unit, 400 E. Sheridan Road, Melbourne, Florida
Employee job titleMental health technician
Date of injuryNovember 7, 2023
Where the event occurredNurse's workstation on the inpatient unit
What the employee was doingWorking at the nurse's workstation
What happenedA patient struck the technician with a metal hole punch
InjurySerious injuries to the head, face, hands and arms
Object or substance that harmed the employeeMetal hole punch available at the workstation
Hospitalized as an in-patientYes
Reported to OSHA within 24 hoursNo; OSHA cited the employer for late reporting
What this page is doingEvery entry comes from the public record, and fields the record does not contain are left out rather than invented.
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Part 2: OSHA's Findings

OSHA cited the company with a repeat violation of the General Duty Clause, the catch-all duty to protect workers from serious hazards an employer knows about or should know about, because it had not shielded employees from patient violence. It also cited the company for not reporting the in-patient hospitalization within 24 hours, as the recordkeeping rule requires (29 U.S.C. § 654(a)(1); 29 C.F.R. § 1904.39). Proposed penalties totaled $101,397. The citation was a repeat because OSHA had investigated two serious incidents at another of the company's Melbourne facilities in 2020, including the fatal shooting of a counselor by a former patient (U.S. Department of Labor, 2024).

Part 3: Five Whys

1. Why was the technician injured? A patient attacked the technician at the nurse's workstation.

2. Why could the patient reach the technician with a weapon? The workstation was open to patients and held loose objects that could be used to strike someone.

3. Why was the workstation open and unsecured? The unit's design and supply practices had not been reviewed for violence risk, though patient aggression was a known hazard on psychiatric units.

4. Why had no review taken place? The organization lacked a functioning workplace violence prevention program with worksite analysis, despite earlier serious incidents at another of its facilities.

5. Why was there no functioning program? Leadership had not treated workplace violence as a hazard requiring the same systematic controls as other safety risks, so prior incidents produced no system-wide change.

Root cause: the absence of an organization-wide, management-led workplace violence prevention program, which allowed a known hazard to persist and also explains the missed 24-hour report.

Part 4: Research and Corrective Actions

Workplace violence is a recognized and common hazard in health care, with psychiatric and emergency settings at highest risk, and many assaults go unreported (Phillips, 2016). OSHA's workplace violence guidelines for hospitals, clinics and social service agencies describe the elements of a prevention program: management commitment and employee participation, worksite analysis, hazard prevention and control, training and recordkeeping with program evaluation (OSHA, 2016). Research supports the worksite analysis step. In a study of 21 hospital units, structured walkthroughs that combined each unit's violence data with a checklist of prevention strategies led most units to put environmental, behavioral or administrative changes in place within a year (Hamblin et al., 2017).

Root cause or contributing factorCorrective actionOwner
No prevention programWritten program with leadership commitment and staff on the committeeChief executive and safety officer
Unsecured workstationEnclosed or half-height protected workstation; remove loose heavy objectsFacilities
No worksite analysisAnnual unit walkthroughs using incident dataSafety committee
Late reportingReporting procedure with a 24-hour checklist for supervisorsHuman resources
Prior incidents not acted onReview of every serious incident across all sites by the safety committeeCompliance officer

Conclusion

The injury was caused by a patient, but the conditions that allowed it were organizational. Completing the incident report makes the facts clear, and asking why five times shows that the missing piece was a prevention program that OSHA's own guidelines describe.

References

Duties of employers and employees, 29 U.S.C. § 654 (2024).

Hamblin, L. E., Essenmacher, L., Luborsky, M., Russell, J., Janisse, J., Upfal, M., & Arnetz, J. (2017). Worksite walkthrough intervention: Data-driven prevention of workplace violence on hospital units. Journal of Occupational and Environmental Medicine, 59(9), 875-884. https://doi.org/10.1097/JOM.0000000000001081

Occupational Safety and Health Administration. (2016). Guidelines for preventing workplace violence for healthcare and social service workers (OSHA 3148-06R). U.S. Department of Labor.

Occupational Safety and Health Administration. (2024). Injury and illness incident report (OSHA Form 301). U.S. Department of Labor. https://www.osha.gov/recordkeeping/forms

Phillips, J. P. (2016). Workplace violence against health care workers in the United States. New England Journal of Medicine, 374(17), 1661-1669. https://doi.org/10.1056/NEJMra1501998

Reporting fatalities, hospitalizations, amputations, and losses of an eye as a result of work-related incidents to OSHA, 29 C.F.R. § 1904.39 (2024).

U.S. Department of Labor. (2024, May 9). Department of Labor investigation into worker's serious injuries finds Florida behavioral health facility again failed to protect employees from workplace violence [News release]. https://www.dol.gov/newsroom/releases/osha/osha20240509

What the HCR 264 Module 5 instructions ask for

The third writing assignment in HCR 264 falls in Week 5, the module on the Occupational Safety and Health Act. Instead of an essay, the syllabus asks you to complete an OSHA Incident Report Form template for a real OSHA case and support your analysis with outside research, which is why it is called a Root Cause Analysis Paper. A real case means one OSHA or the Department of Labor has made public, usually through a news release announcing citations, so the facts you enter on the form should come from that record. The form captures who was hurt, where, how and with what; the analysis explains why it happened and what would prevent it. Health care cases on workplace violence, needlesticks, patient handling and chemical exposure are well documented. The assignment shares the course's 300 writing points with the other three papers.

Inside the HCR 264 Module 5 example

After a two-sentence purpose statement, Part 1 completes the incident report as a two-column table of form fields and entries, using only facts the Department of Labor published and leaving out the worker's name. Part 2 summarizes what OSHA cited, the penalty and why the violation was a repeat. Part 3 asks why five times, moving from the patient's act to the missing prevention program, and states the root cause in one sentence. Part 4 brings in research on workplace violence in health care, OSHA's own prevention guidelines and a hospital study of worksite walkthroughs, then lists corrective actions in a table that names an owner for each. A short conclusion separates the patient's act from the organizational conditions that allowed it.

Where the marks sit in the HCR 264 Module 5 rubric

Canvas holds the rubric for this assignment, part of the 300 points for writing. A strong submission completes the form accurately from a real, identifiable OSHA case, separates facts from interpretation, reaches a root cause that is organizational rather than "the employee was careless" or "the patient was violent," supports the analysis with research and OSHA guidance and proposes corrective actions that match the causes. Points go when form fields are filled with guesses, when the five whys stop at the first answer, when the root cause blames an individual, when recommendations do not follow from the analysis and when sources are missing. Graders also look for respect for the injured worker's privacy; a public analysis should not name the person.

HCR 264 Module 5 help with common mistakes

Find your case first; a Department of Labor news release about a health care employer is the easiest starting point, and the newer the better. Copy only facts the release states into the form, and leave fields blank rather than inventing details. Ask "why" until you reach something management controls, such as a missing program, policy or design choice. Check the regulation the employer was cited under. Use OSHA's guidance for your industry to frame corrective actions, and give each one an owner. Keep the injured worker anonymous. If you cannot find a case with enough detail, the desk can suggest public sources that list recent health care citations.

Write yours, or have the desk draft it

This paper is an original model document written by our desk, not a submitted student paper and not an official Arizona State University document. Read it for the moves, then write your own to the instructions in your classroom. If you want one built to your exact prompt and rubric, the first custom sample is free and arrives in 24 to 48 hours.

More HCR 264 and BS in Health Care Compliance and Regulations sample papers

HCR 264 Module 5 questions, answered

Where can I find a free HCR 264 Module 5 sample paper?

On this page: a finished OSHA incident report and five-whys root cause analysis of a patient assault on a mental health technician.

What is OSHA Form 301?

The Injury and Illness Incident Report employers complete within seven days for each recordable work injury or illness.

How fast must an employer report a work-related hospitalization to OSHA?

Within 24 hours of learning of an in-patient hospitalization, under 29 C.F.R. § 1904.39.

What is the General Duty Clause?

The OSH Act's catch-all rule, section 5(a)(1), used when no specific standard covers a serious hazard the employer knew or should have known about.

How do I find a real OSHA case for HCR 264?

Department of Labor and OSHA news releases announce citations with dates, places, injuries, violations and penalties.