This is the final article of the L&G Contractor (LGC) EHS Management System series, ending in the topics we dread – dealing with incidents, injuries and the pain, before, hopefully, returning to work.
Ideally these topics could be avoided by effective incident prevention, by developing a safety culture when following the principles outlined in the previous articles.
Once you experience a notifiable (serious) incident, the whole EHSMS may come under the scrutiny of legislative authorities such as WorkSafe, with potentially serious penalties if the LGC is found non-compliant and negligent.
This reason, apart from the commitment to preventing work-related deaths and injuries, should be additional incentive to ensure the EHSMS is compliant with legislation, with records providing evidence of active implementation.
The topic is too large to cover in this brief article, so it is vital that the suggested reading (below) is referenced when training or addressing any incident in the workplace.
The LGC EHS Management Systems must address the health, safety and environmental issues of any incident involved in their operations, in accordance with the Incident Management Procedure section of the EHS Management System.
- Maintain a compliant EHSMS with records of all incidents, and monitoring on an Incident Register.
- Train workers in the incident reporting and investigation procedure, including first aid training, Workers Compensation and RTW process.
- Provide adequate first aid resources and facilities.
- Follow incident reporting procedures for any incident experienced or witnessed.
- Actively contribute to the development of CoP and SWMS procedures, and adhere to the control requirements to minimise potential for incidents, including using appropriate PPE.
- Occupational Health and Safety Act (OHS Act) 2004, and other similar state acts.
- Return to Work Act (all states have a separate act covering RTW )
- Occupational Health and Safety Regulations (OHS Regulations) 2017
2.3 Compliance Codes
- Compliance Code – First Aid in the workplace (Edition 1 September 2008)
- Guide to Incident Notification 3rd edition 2008 (Guide to Part 5 of OHS Act 2004)
- Report an Incident (includes COVID-19)
- Safework Australia – Workers Compensation: Covers also RTW, and references the various legislative bodies in all states of Australia
2.5 Australian Standards
- AS1885.1-1990 Workplace injury and disease recording standard
3.0 Incident Reporting Procedure
The Incident Reporting and Investigation Procedure is an essential component of the EHSMS, applicable to employees, contractors, subcontractors and visitors at all LGC controlled sites.
3.1 Incident Definition
An incident is any undesired event that causes, or has the potential to cause injury, illness, property damage, harm to the environment, loss to production or quality or impact on the community or security.
3.2 Incident Reporting
All incidents (except minor First Aid level incidents) are reportable, and logged on the LGC’s Incident Register. They must be recorded using the LGC’s Incident Investigation and Report form, and classified as Minor, Moderate or Serious.
The Minor and Moderate cases require internal investigation to establish root cause and trigger corrective actions and amendments to the SoPs and SWMS to ensure no recurrences in future.
The Very Serious cases are ‘notifiable incidents’ and reportable also to legislative authorities. Refer to 3.3 Incident notification, below.
3.3 Incident Notification (ref OHS Act)
Very Serious incidents require reporting to the relevant statutory authorities within prescribed time limits. Each State has its own criteria as to what constitutes a notifiable incident.
The definition of a notifiable incident varies across jurisdictions. However, the following will always be considered a notifiable incident:
- An incident resulting in someone’s death
- An incident causing a serious injury or illness
- A dangerous incident (including near miss)
3.4 Incidents to be reported
The reporting of all incidents will assist to develop and monitor corrective/preventive programs.
The list below is examples of the types of incidents in LGC controlled sites that should be reported:
- Occupational injuries or illnesses
- Incidents with the potential to cause injuries or illnesses (near miss)
- Incidents that caused or had the potential to cause serious property damage, for example, fires, floods and explosions
- All accidents involving vehicles
- Uncontrolled emissions that may pose a risk to the environment (air, water and land)
- Incidents that had the potential to cause damage to the land, including heritage sites and protected fauna, as per Environmental Management Plan in the EHSMS
3.5 Incident Types
The incident outcome determines the incident type for recording on the LGC Incident Report and Investigation form.
For example, injury/illness, environmental, property, security, near miss, etc.
3.6 Incident Classification
Incidents are classified by their severity to allow an appropriate level of reporting and investigation to be undertaken, and recorded in the Incident register. For example, Minor, Moderate, Serious.
3.7 Procedure for reporting incidents The procedure for reporting incidents requires two actions as follows:
- Employee’s Initial phone/email reporting to LGC Supervision within 1 hour of the incident report.
- Completion of the LGC Incident Report and Investigation form:
- Part 1 – details of the incident, sent to Line Management within 24 hours of the initial report.
- Part 2 – details of the incident investigation, the required corrective actions, and LGC Management review and approvals.
3.8 Statutory Notification
Refer to LGC EHS Manager or Legal Counsel for applicable State requirements for notification of Serious incidents.
4.0 Incident Investigation and Corrective Action
Some level of investigation of all incidents is required to determine the causes so that action can be taken to prevent recurrence.
The 4 stages of an Incident Investigation are:
- Preserve and document the incident scene. First priority should be to ensure that the incident site is safe and secure
- Collect information and interview witnesses
- Determine Root Causes
- Implement Corrective Actions. (Record all incidents in the Incident Register, and track progress of each incident through investigation, root causes, corrective actions, and completion)
5.0 Workers Compensation and Return to Work (RTW)
Refer to Workers Rehabilitation and Compensation Act 1988 for LGC’s Workers’ Compensation and Return to Work (RTW) obligations.
An RTW co-ordinator must be appointed to facilitate the RTW plan.
6.0 First Aid
Refer to 2.3 above: Compliance Code – First Aid in the workplace. This is essential reading to understand where your business specific obligations lie.
EHS Matters, advertising in this publication, can provide a free quotation for any support services required in developing or auditing your EHS Management System. Contact Arved Matt on 0407 771 782.