
Section 5.1
INCIDENT REVIEWING AND REPORTING
Contents
Approved by Richard DeBusk
Revised 9/2010
5.1.1 Policy
5.1.1.1
Incident Types
5.1.1.2 Emergency—Immediate Steps to Take
5.1.1.3 Preservation of Other-Than-Minor Incident Scenes
5.1.1.4 Occupational Injuries and Illness Cases
5.1.1.5 Motor Vehicle Accidents
5.1.1.6 Property Damage Incidents
5.1.1.7 Other Cases
5.1.2 Reviewing Work-Related Injuries and Illnesses
5.1.2.1 Procedure for Reviewing Work-Related Injuries and Illnesses
5.1.2.1.1 Notifications
5.1.2.1.2 Investigations
5.1.2.1.3 Analysis and Corrective Action Development
5.1.2.1.4 Investigation Report
5.1.2.1.5 Other Institutional Reporting Systems
5.1.2.1.6 Issues Management: Preventing Recurrence
5.1.2.1.7 Assessment and Improvement
5.1.3 Roles and Responsibilities for Reviewing Work-Related Injuries and Illnesses
5.1.4 Standards
5.1.5 Related PUB-3000 Chapters
5.1.6 References
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5.1.1 Policy
All accidents, injuries, and significant mishaps will be investigated, analyzed, and reported in accordance with the requirements of this chapter, 10 CFR 851, 29 CFR 1904, DOE M 231.1-1A, DOE O 414.1C, and DOE O 226.1A. This investigation and analysis are intended to:
- Determine the underlying causes of an event
- Develop and initiate control measures that will reduce the likelihood of recurrence
- Satisfy regulatory requirements
5.1.1.1 Incident Types
Environment, Health, & Safety (EH&S) incidents at Berkeley Lab are grouped into three categories related to their severity. The three categories are listed below by decreasing severity:
1. Incidents that require a DOE Type A or B investigation, which include the following:
- A fatality
- Disabling injuries to or illness of five or more people
- Property damage in excess of $1 million
- Radiation exposure that exceeds allowable limits
- Serious environmental release, greater than twice the reporting limits
2. Serious Incidents: Injury cases requiring medical treatment and many Occurrence Reporting Processing System (ORPS) reportable events
3. Minor Incidents: Injury cases involving first-aid treatment, low-level Occurrence Reports, etc.
5.1.1.2 Emergency—Immediate Steps to Take
In case of fire, explosion, gas leak, chemical incident, radiological incident, environmental incident, or any other emergency or accident:
- Evacuate personnel from the immediate area to prevent further injury.
- Get help from professional emergency responders by calling 7911 (on site) and 9-911 (off site). Give all information needed to dispatch appropriate aid to the scene. Identify who you are, where you are calling from, the phone number you are calling from, the nature of the emergency, and the extent of the injury or spill. Stay on the phone until released by the dispatcher.
Assign someone to meet the emergency crew and provide directions to the incident.
- Do not move injured individuals unless necessary to prevent further injury.
- Apply first aid to stop severe bleeding and/or restore breathing immediately if you are qualified to do so.
- REFER TO THE EMERGENCY RESPONSE GUIDE FOR DETAILED INSTRUCTIONS. THIS GUIDE IS POSTED THROUGHOUT THE LABORATORY.
5.1.1.3 Preservation of Other-Than-Minor Incident Scenes
Each of these types of incidents will be investigated by an LBNL Incident Review Team or by a DOE Accident Investigation Board. In case of a serious incident, the scene must be preserved until the review team has released the area.
Consult your EH&S Division Occupational Safety Group representative, your Division Safety Coordinator, or EH&S Division Liaison to determine if an incident scene must be preserved for review.
An LBNL Incident Review Team will investigate significant incidents that do not meet the DOE criteria but are of concern to Berkeley Lab management. This determination will be made on a case-by-case basis, and will typically include the following types of cases:
- OSHA recordable injuries
- Cases with the potential for severe injury, exposure, damage, or environmental release
- Many incidents that require an ORPS report
Until senior management or designated individuals arrive, the area supervisor or lead employee is in charge of the scene of any incident. In the event of such an incident, take the following actions:
- Verify that emergency assistance is present, or call ext. 7911 (on site) or 9-911 (off site) for assistance.
- Preserve the scene. Do not permit any equipment or vehicles involved in the incident to be moved.
- Notify the LBNL EH&S Division Office, ext. 5251, immediately.
- When possible, obtain photographs, particularly of transient evidence such as liquid spills or scuff marks.
- Ask witnesses to remain in the vicinity of the incident to provide a statement to the responding investigator only if it is safe to do so. Otherwise, obtain names and contact information of witnesses before they leave.
5.1.1.4 Occupational Injuries and Illness Cases
All occupational injuries and illness cases must be reported to Health Services. Typically, the supervisor will direct the injured employee to report to Health Services for evaluation and treatment. When the injured employee does not or cannot report to Health Services at the time of injury, the supervisor must promptly notify Health Services of the injury. Health Services will initiate the Incident Review process by notifying the supervisor, Division Safety Coordinator, and Occupational Safety Group. Health Services will also initiate any required reports for workers' compensation purposes.
For off-hour injuries, report to the Fire Department for first-aid treatment or for transport to off-site medical care. The Fire Department will notify Health Services to initiate all required reviews and reporting.
For work-related injuries that occur off site or away from the Laboratory, the injured employee or supervisor must notify Health Services as soon as possible. Also notify Health Services of injuries to student employees who were treated at the UC Berkeley Tang Center.
5.1.1.5 Motor Vehicle Accidents
For on-site motor-vehicle accidents, notify Berkeley Lab Security. If a government vehicle is involved, complete the LBNL Motor Vehicle Accident Report and submit it to the motor pool at http://isswprod.lbl.gov/AccidentReport/.
For off-site accidents involving a government vehicle, notify the local police, complete an LBNL Motor Vehicle Accident Report, and submit it to the motor pool at http://isswprod.lbl.gov/AccidentReport/.
For motor-vehicle accidents involving a rental car or personal vehicle on official business, notify the local police, and complete the forms required by the rental company or by the insurance company. Send copies of all reports to the LBNL Risk Manager (Laboratory Counsel).
5.1.1.6 Property Damage Incidents
Incidents that result in property damage may require ORPS reporting. Consult with your Division Safety Coordinator or with the EH&S Division Office for details.
5.1.1.7 Other Cases
Various radiological incidents, chemical exposures, and environmental releases also require reporting and analysis. Consult with your EH&S Division Liaison for appropriate procedures in specific cases.
5.1.2 Reviewing Work-Related Injuries and Illnesses
LBNL will review all work-related injuries and illnesses to understand what caused them, and to develop controls to prevent them from recurring. Reviews of work-related injuries and illnesses are owned by cognizant line management. The EH&S Division Occupational Safety Group Incident Review Program assigns a trained investigator to support and facilitate the investigation and data collection, causal analysis, development of recommended controls to prevent recurrence, and to prepare a report for each review. The trained investigator will apply the review process with a graded approach. Once recurrence controls have been recommended, line management is responsible for management of these issues through the LBNL Corrective Action Tracking System (CATS).
5.1.2.1 Procedure for Reviewing Work-Related Injuries and Illnesses
The procedure for reviewing work-related injuries and illnesses[1] is outlined below:
5.1.2.1.1 Notifications
- Employee reports injury to his/her supervisor and to Health Services.
- Health Services sends the Occupational Health and Medicine (OHM) Report notification to the:
- Injured employee’s supervisor
- Division Safety Coordinator
- Incident Review Program Manager
5.1.2.1.2 Investigations
Definitions
Division Ownership means that the injured employee’s division bears responsibility and accountability for controlling factors related to causing an incident and can institute controls to prevent recurrence.
Division line management means the injured employee’s supervisor or other line management representatives as defined in that division’s Integrated Safety Management (ISM) plan (such as the Division Safety Coordinator, a work lead, or another individual with delegated authority and accountability).
Institutional Ownership means that the injured employee’s division bears no or insignificant responsibility or accountability for factors related to the causes of an incident, and that any controls identified to prevent the recurrence of an incident are likely to have an institutional foundation (e.g., controls developed by the Facilities Division, the EH&S Division, or another LBNL organization).
Upon notification of an injury:
- The Incident Review Program Manager promptly determines whether the injury may have originated from (or is more related to) the employee’s division oversight or an institutional and infrastructure oversight.
- The default classification is Division Ownership and the procedure for Division Ownership cases (immediately below) will be followed unless the injured employee’s line management is notified by the Incident Review Program Manager of a reclassification to Institutional Ownership.
Division Ownership Cases
- If the case appears to relate to the injured employee’s division affiliation, the injured employee’s division line management is responsible for initiating an investigation, ensuring that it is promptly completed, and developing and implementing controls to prevent recurrence of injury.
- Upon notification of an employee injury, the employee’s division line management initiates an investigation into the causes of the injury in accordance with the internal division protocol and the division’s ISM plan.
- Division line management contacts the Incident Review Program Manager to request technical support for the investigation.
- The Incident Review Program Manager will respond or may assign the investigation to a designated investigator.
- The Incident Review Program Investigator will facilitate line management’s prompt investigation guided by this procedure (PUB-3000 Section 5.1) and the division’s ISM program.
- For routine cases, initiation within one day is reasonable. In cases of significant consequence (fatality, hospitalization, equipment failure, chemical or radiation release and exposure, etc.), especially when the incident scene or evidence preservation is important, investigation shall begin immediately upon notification.
- The owner division may opt to take full lead of the investigation pursuant to the procedure defined below under the oversight of the Incident Review Program Investigator.
- To plan and perform the review, the Incident Review Program Investigator contacts:
- The injured employee
- Any other relevant parties (witnesses, infrastructure representatives, etc.)
- The Incident Review Program Investigator:
- Facilitates planning the review
- Facilitates interviews
- Facilitates collection of physical evidence and photographs
- Helps identify and gains participation of other relevant Laboratory departments or personnel for support where subject-matter expertise or ownership is required
Institutional Ownership Cases
- If it appears that the case is not related to the injured employee’s division affiliation, the Incident Review Program Manager initiates and conducts the investigation.
- The Incident Review Program Manager will respond to the incident, or may assign the investigation to one of the designated trained investigators.
- To plan and perform the review, the Incident Review Program Investigator contacts:
- The injured employee’s supervisor and Division Safety Coordinator to notify them of the institutional classification
- The injured employee
- Any other relevant parties (witnesses, infrastructure representatives, etc.)
- The Incident Review Program Investigator:
- Plans the review
- Division line management participates in accordance with their division ISM program
- Conducts interviews
- Collects physical evidence and photographs
- Identifies and inducts participation of other relevant Laboratory departments or personnel for support where subject-matter expertise or ownership is required
5.1.2.1.3 Analysis and Corrective Action Development
The Incident Review Program Investigator will ensure that appropriate causal analysis is conducted to determine direct, contributing, and root causes of the incident in accordance with the Causal Analysis Program Manual (PUB-5519[2]). A graded approach in the application of causal-analysis methods will be applied. For example, for minor incidents where no useful information is likely to result from an incident investigation (typically an injury that did not occur due to some ISM deficiency) the requirement for an investigation can be waived by the Incident Review Program Manager.
- The Incident Review Program Investigator will use the causal-analysis technique most appropriate for the incident.
- The Incident Review Program Investigator will use the selected causal ISM analysis tools to develop recommended corrective actions.
- The Incident Review Program Investigator will review the causal-analysis results and recommended recurrence prevention controls with the line management responsible for the investigation.
5.1.2.1.4 Investigation Report
The assigned Incident Review Program Investigator will prepare the injury investigation report.
- The report will:
- Be completed within seven days from the report of injury to meet regulatory reporting requirements
- Satisfy the content requirements of DOE Form 5484.3 and the OSHA 301 Form
- Describe the activity and events leading up to the incident
- Describe any apparent, direct, contributing, or root causes
- Describe controls that will effectively prevent recurrence
- Line-management ownership of the investigation will be demonstrated by signatory concurrence on the report.
- Line management will review the report for factual accuracy.
- Line management will sign the report by releasing the report in the Supervisor’s Accident Analysis Report (SAAR) system.
- Resolution of differences in cases where line management is unable to concur will be by written statement of minority opinion appended to the report.
- The relevant division director will receive a copy of the report.
- Quality review of the report will be performed by a panel (person or persons) appointed by the EH&S Division Director.
5.1.2.1.5 Other Institutional Reporting Systems
When an injury review is performed in response to an incident that triggers other institutional reporting systems (ORPS, Non-Compliance Tracking System [NTS], Vehicle Incident Report), the Incident Review Program Investigator will assist in integrating the injury investigation and reporting with other reporting systems.
5.1.2.1.6 Issues Management: Preventing Recurrence
Once causes have been determined and recurrence controls identified and recommended, division line management follows the process described in the Issues Management Program Manual (PUB 5519[1]).
- Line management develops corrective actions to effectively implement the recommended recurrence controls.
- Issues and their corrective actions will be entered into CATS within five business days of identifying the issue (i.e., five business days after the final report is issued).
- Issues entered in response to an injury review will use the CATS issue category “Injury/Illness.”
- The Incident Review Program Investigator can help division line management construct corrective actions that address the causal factors and identified recurrence controls.
- The Incident Review Program Investigator can provide guidance on the CATS new issue entry coding and classification (issue type, assessment type, risk level, trend code, and external reporting/significant adverse condition check box).
- Quality review of the corrective actions entered and their effectiveness when completed will be in accordance with the protocol in PUB-5519(1).
5.1.2.1.7 Assessment and Improvement
Institutional assurance systems will be used in the following way:
- The Incident Review Program Manager will provide suggested self-assessment lines of inquiry to the Office of Contract Assurance designed to aid divisions in the monitoring and improvement of their follow-up to injuries and their use of the LBNL Issues Management Program and CATS.
- The Incident Review Program Manager will use the Technical Assurance Program (TAP) process to monitor and measure program effectiveness.
5.1.3 Roles and Responsibilities for Reviewing Work-Related Injuries and Illnesses
Injured employee:
- Reports injury to supervisor and Health Services
- Participates in the incident review
Division line management:
- Supervisor/work lead for injured employee or incident scene
- Initiates and owns overall investigation
- Is responsible for conducting an incident review
- Requests support or oversight from Incident Review Program for completing the injury investigation, analysis, and report
- Reviews and signs report prepared by the Incident Review Program Investigator
- Submits corrective actions into CATS
- Division Safety Coordinator
- Facilitates line-management ownership of the injury review through integration of their division’s ISM plan with the review process
- Facilitates line-management ownership of issues management after an injury review
- Incident Review Program Investigator
- Provides the professional skills and tools for incident investigation, causal analysis, recurrence-control development, and report preparation for all injury-review cases
- Incident Review Program Manager
- Determines whether a review will be “division owned” or “institutional”
- Assigns investigators for all injury reviews
- Where appropriate, waives the requirement for a review for minor cases where a review is unlikely to add value
5.1.4 Standards
- 10 CFR 851, Worker Safety and Health Program
- 29 CFR 1904, Recording and Reporting Occupational Injuries and Illnesses
- DOE Order 225.1, Change 1 and 2, Accident Investigation
- DOE Order 231.1, Change 1, Environment, Safety & Health Reporting
- DOE Manual 231.1-1A, Environment, Safety & Health Reporting Manual
5.1.5 Related PUB-3000 Chapters
5.1.6 References
- Lawrence Berkeley National Laboratory Master Emergency Plan (LBNL/PUB-533), Lawrence Berkeley National Laboratory, latest revision
- Emergency Preparedness Web site (access restricted; LDAP user name and password required)
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Notes
1. For purposes of brevity, the term” injury” throughout the rest of this procedure encompasses both work-related injuries and illnesses.
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