| Department | Environmental, Health and Safety | Document no | EHS-025 | ||
| Title | Incident Management Procedure | ||||
| Prepared by: | Date: | Supersedes: | |||
| Checked by: | Date: | Date Issued: | |||
| Approved by: | Date: | Review Date: | |||
Document Owner
EHS Manager
Affected Parties
All Site colleagues
Purpose
This procedure defines the requirements for immediate action, investigation, and reporting, corrective action, follow-up and training associated with EHS incidents.
Scope
This procedure applies to all Divisions of the manufacturing.
Definition
| DR | Deviation Report |
| Incident (Near Hit) | An incident is an unplanned event, which could have led to harm to people, premises, the environment or the business. |
| Serious Incident | A serious incident is an unplanned event, which could have led to seriously harm to people, premises, the environment or the business. In case of a serious environmental incident any of the conditions should be relevant: · The Emergency Services have been involved. · There has been a public or media interest. · Serious complaints have been reported to the Company. |
| Accident | An accident is an unplanned event, which has caused harm to people, premises or environment. The accidents are classified as fatality, major accident, significant accident or minor accident. |
| Occupational Illness | Any abnormal condition or disorder, manifested by a characteristic set of symptoms and signs, other than one arising from an occupational injury, which is caused or mainly caused by exposure to work factors. It includes: · Acute and chronic illnesses or diseases, which may be caused by inhalation, absorption, ingestion or direct contact. · Psychological and psychiatric disorders. |
| Work-related occupational illness | Work-related: “probability of 51% or more” that the case is caused by work factors, (i.e. more likely than not). Reportable cases will include: · Occupational overuse injuries · Cases which are required to be reported under national schemes · All other cases, judged by a competent occupational health professional to be work-related. Only new cases (and recurrences of illnesses resulting from new exposures at work). |
| Immediately Reportable Accident | An accident which falls into one of the following categories: 1. Fatalities, major injuries, serious incidents that could have led to a fatality. 2. Accidents, which result in members of the public needing medical attention. 3. Accidents involving significant damage to plant, or equipment or damage to on site property or any contamination of the environment outside the site boundary which results in public concern, serious complaint, or extensive media attention. 4. Any other accident or incident judged by the EHS Manager to be significant. 5. Prosecutions or other legal notices by regulatory authorities or civil action. |
| Loss of Containment | An instance of raw material, process material or product leaving the process vessel, pipe work, storage vessel, container or package, in which it was designed to be contained. |
Related Documents
| Form-575 | Incident Investigation Form |
| Form-580 | Incident Communication Form |
| EHS-010 | Environmental, Health and Safety – Risk Management |
| EHS-030 | First Aid Procedure |
| QMS-035 | Deviation Report System |
EHS Statement
This procedure ensures that:
Incidents are adequately investigated to determine root causes.
Learning from incidents are recorded and shared.
Organization meets its legislative requirements.
Similar incidents are avoided.
Procedure
1.1. All injuries and illnesses shall be assessed promptly by a qualified First Aider to determine whether medical treatment is required. (See SOP EHS-030)
1.2. Loss of containment incidents (spills) shall be reported to the EHS Manager.
1.3. Fires shall be reported to Security immediately.
1.4. The EHS Manager shall be informed of all injuries or illnesses, regardless of how trivial they may appear.
1.5. Action shall be taken to contain the effects of the incident and/or make the plant, equipment or building, where the incident occurred, are safe.
1.6. Occurrence of the following events shall be reported through the departmental structure to the relevant Divisional Director:
A medical treatment or potential lost time injury;
A loss of containment;
A major non-compliance with a statutory licence condition;
An incident which attracts media attention;
An incident that could be considered serious in that major consequences were only narrowly avoided.
1.7. An EHS Deviation Report shall be raised outlining details of the event including hazards and corrective action taken. (See SOP EHS-010 & QMS-035)
2.1. Persons nominated to investigate incidents shall have the appropriate experience and skills. It is the responsibility of these nominated persons to determine the make up of investigating teams. The injured employee must be included in determining potential solutions. An EHS Committee member may be considered to be part of the Investigation Team particularly in cases in which a solution is not clear or where a number of options are being evaluated. The investigation flowchart is detailed in Appendices 1.
2.2. Investigation of incidents shall follow a five step process, as follows:
Definition of the problem;
Implementation of a quick fix (if applicable);
Identification of root causes in terms of Management Systems failures;
Implementation of corrective action;
Evaluation and follow-up.
2.3. Full details of investigations including the DR number (See SOP QMS-035) shall be recorded on the Incident Investigation Form (Form-575).
2.4. Once the investigation has concluded and corrective actions signed off, the management Response Tasks of the EHS DR shall be completed by the Line Manager/s and approved by the EHS Manager.
2.5. The completed investigation report, supporting records and completed EHS DR shall be consolidated, appropriately indexed and tagged, and be readily accessible. The records shall be held by the EHS Department.
2.6. Root Cause Analysis shall be conducted using techniques such as “Cause and Effect” diagrams. This technique is designed to lead the analysis to causes, which are systematic in nature, e.g. related to failures in procedures, training, employee behaviour, auditing or corrective action.
2.7. A review of the investigation shall be carried out by the Management Team for the following:
Motor Vehicle incidents
Medical treatment or other significant injuries
Lost time injuries
Losses of containment.
Major non-compliances with statutory regulations
Incidents attracting media coverage
Serious incidents where major consequences were only narrowly avoided.
3. Corrective Action and Follow-up
3.1. A regular, documented review of past injuries and incidents shall be carried out to determine whether corrective actions have been completed and whether the actions taken were effective in preventing recurrence. This review shall be conducted by the Management Team and the EHS Committee.
3.2. Actions identified as a result of these reviews shall be included in the EHS Improvement Plans.
4.1. The EHS staff records details of injuries, illnesses and incidents in the register.
4.2. The Line Manager shall receive incident details as soon as possible after the incident (within 24 hours).
4.3. Investigation and proposals for corrective action shall be completed, and available for the EHS Manager to approve, no later than three working days after the injury or incident. The EHS Manager may, in exceptional circumstances, extend this time limit. Investigation and corrective action details shall appear on the Incident Investigation (Form-575) form.
4.4. For serious incidents, as defined above, the Area Manager shall notify the higher management, in any case not more than 24 hours after the occurrence.
4.5. Area Managers will communicate with the respective team members regarding the incident through ‘Incident Communication Form’ (Form-580).
4.6. Criteria for “shared learning” should be based on one or more of the following:
Procedures/practices common to other Departments/Divisions.
Plant and equipment commonly used/potential to be used within other Departments/Divisions.
Working environment common to other and/or commonly visited by personnel in other Departments/Divisions.
4.7. Form-580 should contain:
Brief summary of incident/background
Learning (based on root cause analysis or hazard identification)
Identified corrective / preventative actions
Incident owner contact details, (for further information, clarification, etc).
4.8. The Management Team shall regularly review the root causes identified from the investigation and monitor the progress of corrective actions until all actions are complete.
4.9. Engineering should be notified of incidents so that safety issues and concerns can be included in designing new equipment or making changes to existing equipment.
5.1. New employees shall receive induction training covering the responsibilities of employees and their managers for reporting injuries and incidents.
5.2. Managers shall, on appointment, receive training in the requirements of this procedure.
5.3. All persons directly involved in injury and incident investigation and follow-up shall receive documented training in root cause analysis.
7. SUMMARY OF CHANGES
| Version # | Revision History |
| EHS-025 | New |