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<CompanyName>

Incident Investigation Program

Version <Version>

Updated: <Date>

Contents

1.	Program Purpose	3

2.	Definitions	3

3.	Responsibilities	3

4.	Procedures	5

5.	Analysis	9

6.	Corrective Actions	9

7.	Reporting Requirements	10

Appendix I: Near Miss Incident Report	11

Appendix II: Incident Report	12

Employee Acknowledgement	14

Program Purpose

To outline the procedure for reporting accidents and incidents at <CompanyName> and to provide information that will ensure effective investigations of work related incidents and injuries which will promote the reduction or elimination of future incidents.

The practice of investigating and analyzing all incidents and near misses, no matter how minor, is vital for the safety and well-being of everyone in the organization.

The benefits include:

Identifying unsafe conditions and behaviors that need to be corrected

Identifying needed organizational changes

Reducing the likelihood of future incidents, saving lives and money

The goal of an incident investigation is not to place blame, but rather to determine the root causes of the incident and make changes that prevent similar incidents from recurring

Definitions

Incident – an event that causes injury or death to people or damage to property

Near miss – an event that almost results in injury, death, or damage and also is a warning sign that an incident is likely to occur

Direct cause – the most obvious reason that an incident occurred when the circumstances of the incident are considered

Root cause – a factor that underlies the other contributing causes and could eliminate recurrence of the problem if it is addressed

Unsafe acts – activities that create or increase the risk of injury or property damage, such as the bypassing or disabling of safety devices

Unsafe conditions – when features of the worksite create or increase the risk of injury or property damage, such as slick walking surfaces or heights

Responsibilities

<ProgramAdmin> shall administrate the Incident Investigation Plan for <CompanyName>. The Plan Administrator is responsible for the following tasks:

Assuring that all incidents and near misses are properly documented and reported

Communicating with OSHA as needed

Assembling the incident investigation team:

Include both management and employees.

The team should include or have access to technical expertise in safety, engineering, operations, or any other subjects that might be helpful.

Assign roles to each member in writing (such as who conducts interviews).

Some members may be permanent team members who can immediately respond when an incident occurs. However, members may need to be added or changed based on the nature of the incident after it occurs.

Assuring that management, supervisors, and incident investigation team members are trained in this policy and training is documented

Reviewing this policy at least once a year and updating it as needed

Incident investigation team:

The incident investigation team are responsible for the following:

Following this policy while conducting investigations

Documenting investigations (Appendix II) and reporting to the Plan Administrator

The incident investigation team consists of the following job positions and/or employees:

Employee	Job Position	Department
<Employee1>	<Position1>	<Department1>
<Employee2>	<Position2>	<Department2>
<Employee3>	<Position3>	<Department3>
<Employee4>	<Position4>	<Department4>
<Employee5>	<Position5>	<Department5>
<Employee6>	<Position6>	<Department6>
<Employee7>	<Position7>	<Department7>
<Employee8>	<Position8>	<Department8>
<Employee9>	<Position9>	<Department9>
<Employee10>	<Position10>	<Department10>

Supervisors:

Supervisors are responsible for cooperating with the investigation as needed, notifying the Plan Administrator of an incident or near miss, and assuring that corrective actions are put into place.

Employees:

Employees are responsible for cooperating with the investigation as needed, and immediately notifying supervisors of unsafe work conditions, potential hazards, incidents, or near misses. It is also the employees’ responsibility to notify <JobPosition1> of any near miss incidents they observe.

Procedures

All incidents and near misses will be investigated, no matter how minor

While the scale of the investigation varies according to the circumstances of the incident or near miss, the following basic stages will always occur:

Control hazards and address any safety and health concerns

Start preserving evidence as soon as possible

Gather information

Conduct interviews

Analyze the data

Suggest corrective actions

Immediately following an incident:

Check the scene for hazards to yourself and others

If you can do so safely and if necessary, control hazards or remove people from hazards

Respond to medical needs: if necessary, summon help by calling emergency medical services (EMS) and/or provide first aid to the level you are trained

Secure the area if necessary to prevent further injury or disruption of evidence

Contact the appropriate personnel, such as supervisors, management, or appropriate agencies, after injured parties are medically stable

Do not disturb the scene unless a hazard exists

Note: If this is a reportable incident, the scene must be left as is, not only for the internal investigation but also for OSHA’s investigation. OSHA notification is not required for property damage or minor injuries.

Preserving Evidence

Inspect the incident site as soon as possible before any changes occur

Photograph details of the scene before removing any evidence

Take measures to isolate any evidence that may not be removed from the scene (e.g., damaged heavy machinery)

Label evidence carefully and keep accurate records

Make sketches of the incident scene

Gathering Information

Collect as much data as possible by interviewing personnel involved in the incident (covered in the next section) and documenting the entire incident site. The more information you have, the easier it will be to see the “big picture”.

In addition, gather the following information if relevant (and make copies of documents):

Company policies and normal operating procedures

Flow diagrams or maintenance charts

Pertinent maps

Any photographs or video of the scene

Reports, especially reports of difficulties or abnormalities

Questions to answer:

What happened? How did it occur? Where did the incident occur? When did it occur?

Who was involved and who was a witness? (Get a full witness list.)

What events immediately preceded the incident?

Was there anything out of the ordinary right before the incident? If yes, how so, when, and where?

Were normal operating procedures being followed? (What are normal operating procedures?)

What is the estimated damage?

Near Miss Incidents

An employee who witnesses a NEAR MISS incident must complete the NEAR MISS REPORTING form (Appendix I) and submit to <JobPosition2>. The reporting system is non-punitive and, if desired by the person reporting, anonymous.

All NEAR MISS INCIDENTS will be reviewed by <JobPosition3> to identify the root cause and the weaknesses in the system contributing to the incident. The reporting employee may also be asked to participate in the incident investigation.

Investigation results will be used to improve safety systems, hazard control, risk reduction, and to educate employees. All of these represent opportunities for training, feedback on performance, and a commitment to continuous improvement.

Conducting Interviews

<JobPosition4> shall appoint a person or persons in the incident investigation team to conduct interviews.

As needed, the team assigned to this task may include an individual who is from a governmental jurisdiction, who is with the organization's insurance company, or who has a legal background.

Who should be interviewed?

Everyone involved in the incident, including victims

Witnesses of the incident

People who were present before the incident

People who arrived at the site shortly after the incident

Working with witnesses:

Interviewers are responsible for the following:

Arrange for a convenient time and place to talk to each witness, but conduct interviews as soon as is possible.

If possible, conduct interviews close to the scene of the incident.

Conduct interviews in private.

Plan the questions ahead of time, but allow the subject's answers to guide what is asked next.

Explain the purpose of the investigation, and put the witness at ease. (Assure the witness that the goal is not casting blame but preventing future incidents.)

Ask open-ended questions, allowing the witness to tell the story in their own words. Do not ask leading questions.

Be sure the witness understands the question.

Do not interrupt, argue, or try to assist with an answer. Listen courteously and let each witness speak freely.

Do not make assumptions about what you expect the answers to be: keep an open mind and do not jump to conclusions.

After you have gotten unassisted answers from the witness, you can show them sketches and diagrams and get their feedback on these documents.

Recordkeeping:

Interviewers are responsible to do the following:

Get preliminary statements as soon as possible from all witnesses

Identify the qualifications of each witness (name, address, occupation, years of experience, etc.)

Record the exact words used by the witness to describe each observation

Use a recording device, but only with the consent of the witness

Take notes without distracting the witness

Keep accurate records of each interview

Note what information was directly observed and what is hearsay

After the interview:

Ask witnesses to sign their statements for the record

Supply each witness with a copy of his or her statement

Locate the position of each witness on a master chart (including the direction of view)

After interviewing all witnesses:

The team will analyze all statements. (Analysis is covered further in the next section.)

They may wish to re-interview one or more witnesses to confirm or clarify key points.

While there may be inconsistencies in witnesses' statements, the team should assemble the available testimony into a logical order.

Considering inconsistencies:

There are many potential reasons for inconsistencies:

Witnesses may remember different information due to how they perceive.

A witness may omit entire sequences because of a failure to observe them or because their importance was not realized.

A witness who has had a traumatic experience may not be able to recall certain details.

A witness within close proximity to the incident may have a different perspective from one who saw it at a distance.

Physical traits such as eyesight, hearing, and reaction time can affect powers of observation.

Some witnesses may also change their stories after they have discussed it with others. This one reason why immediate interviews are so important and why questions should be as impartial as possible.

A witness who has a vested interest in the results of the investigation may offer biased testimony.

While inconsistences are not always important, they could potentially give clues about areas that require further investigation.

Analysis

Piece together a likely sequence of events.

Determine the various causes.

Look for root causes. A root cause is a factor that underlies other contributing causes and could eliminate recurrence of the problem if it is addressed.

Rather than just focusing on the actions of the people involved in the incident, try to consider the organization as a whole and whether there are any weaknesses in the current procedures that may have contributed to the incident.

Using multiple methods of data analysis can help uncover root causes that may have been missed using only one.

Avoid making these assumptions:

There can only be one true cause and solution for the accident

Incidents only occur when rules are broken

Someone must be held accountable

Given the same set of facts, everyone will come to the same conclusion

Corrective Actions

Once all root causes of the incident have been determined, recommend corrective actions that can help minimize or eliminate the chances of reoccurrence.

Be specific in your instructions for what each action entails and how it should be implemented.

Keep your recommendations constructive and objective.

Clearly point out instances where human error is a cause, but avoid recommending disciplinary actions, which should be handled by Human Resources.

Consider whether the Job Safety Analyses (JSAs), training for staff, and safety observations need to be updated due to new controls or concerns that have surfaced during the investigation.

Outline a follow-up plan to assure that actions are implemented correctly and work as planned.

Specify the responsible parties for implementation and for assuring the effectiveness of the corrections.

Include due dates for the actions to be implemented.

All corrective actions are to be tracked and documented until implemented.

Set up an audit process. If hazards or risks are not corrected, review the prescribed corrective actions to assure that everything has been implemented as planned and revise the actions as necessary to address any remaining issues.

Once the issues have been verified as adequately resolved, share your results with other departments that may be subject to similar issues.

Reporting Requirements

Conduct a post-investigation briefing.

Prepare a summary report, including the recommended actions to prevent a recurrence. Distribute the report.

An incident investigation is not complete until a report is prepared and submitted to proper management, reviewed with applicable staff, and as necessary, authorities.

Reporting to OSHA:

OSHA notification is not required for property damage or minor injuries.

Accidents and incidents must be reported to the appropriate State or Federal OSHA office in a timely manner. Your location determines the appropriate office to contact.

Work-related fatalities (if death occurs within 30 days of the incident) must be reported within 8 hours of being notified of the fatality.

Work-related incidents resulting in any inpatient hospitalization, amputation, or eye loss (if occurring within 24 hours of the incident) must be reported within 24 hours of being notified of the incident.

Inpatient hospitalization for diagnostic testing or observation only is not reportable.

You must investigate or initiate an investigation on every lost-time injury that workers incur.

OSHA investigations:

If someone is injured or there is significant property damage or loss, it may be required to notify and involve a governmental jurisdiction and/or your insurance company.

The agency with jurisdiction over the location determines the administrative procedures.

Responsible officials will often appoint an individual to be in charge of the investigation.

Do not move the equipment until a representative of OSHA investigates the incident and releases the equipment unless directed by a recognized law enforcement agency or if moving the equipment is necessary to remove victims or prevent further incidents and injuries.

Appendix I: Near Miss Incident Report

This report is to be filled out by any employee involved in or witnessing a near miss. A near miss is an incident that did not result in any personal injury, property damage, or production interruption. It is a very important indicator of potentially harmful future accidents.

Department:	Building:
Date of incident:	Time:
Location: (Describe where incident occurred)
Description of incident/potential hazard:
Ideas for improvement:
Print employee’s name:	Employee’s signature:	Date:
Corrective action(s) taken to prevent recurrence:
Print supervisor’s name:	Supervisor’s signature:	Date:

Appendix II: Incident Report

This form is to be completed in its entirety and must accompany all Employers’ First Report of Injury forms
(C-3 form)

Injured Worker’s Name:
First:	Middle:	Last:
Location/Address of Incident:
Date of Injury:	Was the Injury Reported the Same Day? ☐ Yes ☐ No
Time of Incident:	Employee’s Hire Date:
Employee’s Normal Work Shift days/hours (a.m./p.m.):
What was the employee doing at the time of the incident?:
Were there any witnesses? ☐ Yes ☐ No
If so, list names:
If employee was required to use personal protective equipment to perform the task, was it being utilized? ☐ Yes ☐ No
Did the employee fail to follow safety rules or guidelines? ☐ Yes ☐ No
Were others involved that could have contributed to the cause of the incident? ☐ Yes ☐ No
If so, list names:
Was there a failure or defect in equipment being used? ☐ Yes ☐ No
If so, was the equipment/tool removed from service and held for inspection? ☐ Yes ☐ No
Was the employee trained on the task being performed? ☐ Yes ☐ No
If yes, by whom?
What actions/change of process or retraining will be used to prevent a similar incident from happening again in the future?
Have you any reason to believe this is not a work related/on the job injury? ☐ Yes ☐ No
If yes, why?
Did the Employee miss any days of work prior to reporting this injury? ☐ Yes ☐ No
If so, list dates:
Any other information concerning this incident:

I understand that falsification of this statement, or misrepresented information contained in this statement, can result in disciplinary procedures.

Signature:
Date:

Employee Acknowledgement

I have received information on <CompanyName>’s Incident Investigation Program. By signing below, I agree to abide by the procedures in this document and bring to the attention of my supervisor any questions or concerns had.

Employee Name:
Employee Signature:
Date:

icwgroup.com ICW Group is the marketing name for ICW Group Holdings, Inc. For a list of all ICW Group Holdings, Inc. subsidiaries, please visit our website www.icwgroup.com.
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