Procedure: Work health and safety incident management

Purpose

This procedure describes how the Australian National University (ANU) investigates, reports and takes action when incidents and events (referred to in this procedure as incidents) occur following injuries, illness, hazards and other system failures with a potential to impact on health and safety. This procedure links to the Work Health and Safety policy and meets compliance requirements for incident management as defined in the Work Health and Safety Act 2011 (Cth) (WHS Act), the Work Health and Safety Regulations 2011(Cth) and the Australian Radiation Protection and Nuclear Safety Act 1998 (Cth).

Definitions

Dangerous incident means an incident, prescribed under WHS Act 2011 (Cth) Section 37, in relation to a workplace that exposes a worker or any other person to a serious risk to a person’s health or safety emanating from an immediate or imminent exposure to:

1. an uncontrolled escape, spillage or leakage of a substance; or
2. an uncontrolled implosion, explosion or fire; or
3. an uncontrolled escape of gas or steam; or
4. an uncontrolled escape of a pressurised substance; or
5. electric shock; or
6. the fall or release from a height of any plant, substance or thing; or
7. the collapse, overturning, failure or malfunction of, or damage to, any plant that is required to be authorised for use in accordance with the regulations; or
8. the collapse or partial collapse of a structure; or
9. the collapse or failure of an excavation or of any shoring supporting an excavation; or
10. the inrush of water, mud or gas in workings, in an underground excavation or tunnel; or
11. the interruption of the main system of ventilation in an underground excavation or tunnel; or
12. any other event prescribed by the regulations;

but does not include an incident of a prescribed kind.

Emergency is the result of an incident requiring immediate action and a coordinated response that may include external emergency response services and coordination of stakeholders until the situation is controlled.

First aid injury (FAI) is any workplace injury which requires immediate first aid treatment. It does not warrant treatment at the level provided by a qualified medical practitioner and the injured person can return to work within the shift.

Hazard is an occurrence with potential to harm a person, the environment or property.

Incident or event is an occurrence that could have or did result in harm to a person, the environment or property damage.

Lost time injury (LTI) is a workplace injury or illness significant enough to require: admission to hospital; the next full scheduled day of work missed, is the result of an event, and is outside the control of the WHS management systems of the University. An LTI is not an aggravation of pre-existing injury.

Medical treatment injury (MTI) is a workplace injury or illness, significant enough to require treatment by a qualified medical professional (for example a doctor). Treatment at this level begins with a stich/suture or a prescription. A sterile strip (medical skin closer) to close a wound is not an MTI as a First Aider could apply this as a standard item in a first aid kit. Visits to a physiotherapist following a workplace injury are an MTI if more than four visits are required.

Near miss is an occurrence/event that may have resulted in an injury or illness. A near miss can be notifiable as prescribed in the WHS Act based on the potential risk of an event.

Notifiable incident to Comcare is an incident that results in death(s), serious injury or illness and/or a dangerous incident.

Notifiable Radiation Incidents mean incidents prescribed under section 58 of Australian Radiation Protection and Nuclear Safety Regulations 2018 that must be reported to the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA). In the context of ANU, this mean

1. a spill of more than 20 ALI (Annual Limit on Intake); or
2. radioactive contamination on a person or clothing exceeding 50 Derived Work Limits (DWL); or
3. above the International Nuclear and Radiological Event (INES) scale of an incident (Level 2).

Radiation accident is an occurrence associated with controlled apparatus, controlled materials or at a controlled facility, which results in, or has the potential to result in, exposure to ionising or non-ionising radiation, such as to injure, damage or harm any person or the environment. This includes occurrences involving, or resulting from, acts or omissions that were deliberate, reckless or negligent.

Serious injury or illness of a person means an injury or illness requiring the person to have:

immediate treatment as an in‑patient in a hospital; or immediate treatment for the amputation of any part of his or her body; or a serious head injury; or a serious eye injury; or a serious burn; or the separation of his or her skin from an underlying tissue (such as de-gloving or scalping); or a spinal injury; or the loss of a bodily function; or serious laceration; or

1. medical treatment within 48 hours of exposure to a substance; and includes any other injury or illness prescribed by the regulations but does not include an illness or injury of a prescribed kind.

[a. to c. are prescribed under WHS Act 2011 (Cth) Section 36]

1. Any infection to which the carrying out of work is a significant contributing factor, including any infection that is reliably attributable to carrying out work that involves providing treatment or care to a person; contact with human blood or body substances; and/or handling or contact with animals, animal hides, skins, wool or hair, animal carcasses or animal waste products.
2. The following occupational zoonoses contracted in the course of work involving handling or contact with animals, animal hides, skins, wool or hair, animal carcasses or animal waste products: Q fever; Anthrax; Leptospirosis; Brucellosis; Hendra Virus; Avian Influenza; or Psittacosis.

[d. – e. are prescribed under WHS Regulations 2011 (Cth) Regulation 699]

Workers is anyone who carries out work for the University and include staff, Visiting and Honorary Appointments (VaHA), volunteers, titleholders, affiliates, labour hiring workers, student gaining work experience and contractors of ANU. HDR students may be ANU workers depending on their role but they are covered under the scope of this procedure.

The Work Health and Safety Management System (WHSMS) Handbook provides practical guidance for University and its local areas on how to implement the University WHS Management System and defines the responsibilities and actions required by management and workers within the management system.

Procedure

Scope

1. This procedure applies to all workers and other personnel at workplaces under the management or control of the University.
2. This procedure contains four parts:

• incident response;
• incident reporting;
• incident investigation; and
• identifying actions.

Incident response

3. When an incident occurs, everyone in the close vicinity of the incident location shall:

• remove themselves and others, if safe to do so, from the immediate danger;
• make the area safe as appropriate;
• report to their supervisor immediately.

4. Supervisors of the location, activity or persons involved in the incident shall:

• provide assistance or seek additional help from key emergency personnel as appropriate (e.g. first aid officer);
• make the area safe if safe to do so;
• if the incident is a notifiable incident to Comcare or in doubt, call the Deputy Chief People Officer, Safety and Wellbeing, Safety and Wellbeing Team, via 0407 546 974 immediately after being made aware of the incident. If unavailable, contact WHS Manager via 0406 403 025. Preserve the incident scene and do not disturb the incident scene until the Deputy Chief People Officer, Safety and Wellbeing directs to do so.
• if the incident is afterhours, contact University Security (02 6125 2249).

Incident reporting

5. University workers and students report incidents and hazards immediately to their supervisor and through Figtree within 48 hours with as much detail as possible without delay.
6. Where a staff member is unable to report an incident due to incapacity, hospital stay, computer access issues etc., the supervisor or first aid officer or other colleagues should report in Figtree within 48 hours on their behalf and complete as much information as possible. When this is not possible please call Safety and Wellbeing (0406 403 025).
7. When a notifiable incident has occurred it is very important that the incident scene is preserved and must not be disturbed for any reason following the emergency response.
8. Scene preservation of a notifiable incident is the responsibility of the local area supervisor, following advice from the local area Safety Officer and a member of Safety and Wellbeing. The scene cannot be returned until the Deputy Chief People Officer, Safety and Wellbeing, has received confirmation from the respective Regulator (or police, emergency services agency or coroner) that it can be returned to operation.
9. Where a single incident involves multiple people/casualties, it is only necessary to submit one incident report in Figtree. The form allows multiple names to be added or additional names can be added at a later date.
10. University staff and students working at another workplace (e.g. CSIRO, another university) report incidents to the host organisation and to the University via their immediate supervisor and Figtree.
11. All visitors and contractors report any incident or hazards that occur in University buildings or on University grounds. They should contact:

• their University supervisor/contact person;
• staff within the building or nearest building;
• responding first aid or security officers; or
• Safety and Wellbeing (0406 403 025).

Reporting notifiable incidents

12. The Deputy Chief People Officer, Safety and Wellbeing, or a delegate, notifies the Regulatory Authority immediately after confirming a notifiable incident occurring.
13. A notifiable incident requires immediate notification by telephone and follow up in writing using the Regulator’s Online Incident Notification Form. This is to be completed by the Deputy Chief People Officer, Safety and Wellbeing or delegate.
14. All records of incidents are kept in accordance with WHSMS Handbook Chapter 3.16 Section 3.16.3 Record Management.
15. In the event of an injury to an employee that is considered compensable, the rehabilitation case management team provide assistance and guidance to develop an injury management plan in accordance with the Rehabilitation Policy.

Incident Investigation

16. All incidents are classified by a competent WHS Consultant from Safety and Wellbeing in accordance with Table 1 and relevant investigators that are authorised to investigate incidents, if required.

Table 1 Incident category matrix

17. Where an incident is determined as Level 4 or 5, it is to be forwarded to Deputy Chief People Officer, Safety and Wellbeing and/or the WHS Manager for confirmation of the rating and to appoint appropriate investigators.
18. Legal advice is considered for medium and high category incidents or incidents likely to be compensable. The Deputy Chief People Officer Safety and Wellbeing will advise following consultation with the Chief People Officer (Director of Human Resources) and the Legal Office.

Incident investigation planning

19. The Deputy Chief People Officer, Safety and Wellbeing or delegate, assigns appropriate investigators with relevant competency to the incident investigation team as required based on the category of the incident.

Incident investigation data collection

20. All data is referenced on the incident investigation reports and in Figtree. The incident investigation team collects the following data where possible:

• a summary of the scene of the incident and any evidence (security footage, photos, sketches), description of environmental factors at the time;
• a timeline leading up to the incident and immediately following the incident;
• a copy of any safe working tools in use at the time (such as safety working instructions, risk assessments, permits to work, relevant training records of persons involved, any manual or maintenance records for equipment involved, any material substance sheets for substances, any checklists);
• supervisor and witness statements; and
• any interviews conducted.

21. Where an incident investigation is required, supervisors of the location, task or person injured/involved in the incident participate in the investigation interview.
22. Any interviews conducted maintain confidentiality to the extent possible and focus on fact finding.

Incident investigation methodology

23. Level 2 and 3 incident investigation is conducted using the Level 2-3 Incident Investigation Tool based on the five whys methodology to determine the root cause of incidents.
24. Level 4-5 incident investigation is conducted using the Level 4-5 Incident Investigation Tool.
25. The methodology is facilitated by a person with competency in these analysis techniques.

Investigation actions

26. Actions are generated by the incident investigation team in consultation with the workers in the area where the incident occurred to address any deficiencies identified from the root causes. Refer to the WHS actions procedure. The hierarchy of controls is used to ensure the actions address the highest level of practical controls. Refer to the WHS hazard management procedure. The actions are documented in the incident investigation report.
27. If an action is relating to the failure of management system implementation, corrective actions are assigned directly to address the deficiency in accordance with various WHSMS Handbook Chapter guidance.

Endorsement/approval of findings from incident investigation

28. Safety and Wellbeing Consultants (WHS Coordinator) review the investigation reports in Figtree to assess if:

• appropriate investigation tool has been used, completed and attached;
• key facts contributing to the incident were accurate;
• root causes are accurate; and
• actions address the root causes.

29. Authorised investigators ensure that feedback from HSE Coordinators of the incidents are incorporated into the investigation report, corrective actions and other documents.
30. For Level 2-3 incident investigations, after approved by the WHS Coordinator, the reports can be released back to local areas. However, for Level 4-5 incidents, the incident investigation data is released back to the area until the Deputy Chief People Officer, Safety and Wellbeing is satisfied with the incident investigation report.

Communication of incidents and actions

31. The Deputy Chief People Officer, Safety and Wellbeing communicates the lessons learned from incidents. This takes the form of a hazard alert or a memorandum on the incident. The locations that these communications are posted include WHS local noticeboards, the Safety and Wellbeing website and minutes of WHS committee meetings.
32. The Deputy Chief People Officer, Safety and Wellbeing communicates safety documents, i.e. Safety Alerts, Safety Awareness Bulletins, Hazard Alerts, Lessons Learned etc., to the University through the Chief People Officer (Director of Human Resources) and the Safety Officer network representing each of the WHS committees in the governance structure. These documents are accessible on the Safety and Wellbeing website.
33. The Deputy Chief People Officer, Safety and Wellbeing communicates the findings from serious incident investigations to the University Audit and Risk Management Committee (ARMC) and/or the University Council on request from the Chief People Officer (Director of Human Resources) via the Deputy Vice-Chancellor (International & Corporate)

• Serious incidents are reported in all WHS Council WHS Performance Reports by the Deputy Chief People Officer, Safety and Wellbeing Monitoring and review of incidents and actions

34. School Directors, College Deans, General Managers and Division Directors monitor the progress of actions identified from incidents for closure in accordance with WHSMS Handbook Chapter 4.2 Corrective Actions and 4.3 Incident Investigations requirements.
35. The Deputy Chief People Officer, Safety and Wellbeing include the system failure trends in the University Council Annual WHS Performance Report.

Training and competency requirements

36. The facilitators of incident investigations have training in incident analysis techniques using the University prescribed incident investigation methodologies.

This procedure is further explained in and supplemented by WHSMS Handbook Chapter 3.16 Incident and Hazard Reporting and Chapter 4.3 Incident Investigations.

Sources

Refer to ANU WHS Legal and Other Requirements Matrix.