08_GS_1202_00
February 17, 2015
USGC Gulfstream Program Page 11 of 22
The Dow Chemical Company
INCIDENT REPORTING, INVESTIGATION,
REPORT REQUIREMENTS
Table of Contents
PURPOSE 4
SCOPE 4
APPLICATION 4
DOW DEFINITIONS 5
1.0 RESPONSIBILITIES 10
2.0 GENERAL REQUIREMENTS 10
3.0 Project HSE 10
4.0 Supervisor/Manager 11
5.0 Contractors 11
6.0 incident REPORTING 12
7.0 INCIDENT DOCUMENTATION 14
8.0 INCIDENT INVESTIGATION 1
9.0 OWNER INVESTIGATION ATTENDEES 2
10.0 CLASSIFYING AND RECORDING INCIDENTS 3
11.0 OTHER REPORTING REQUIREMENTS 4
Overview – Weekly Reports 4
Overview – Monthly Reports 4
Overview – Additional Reports 5
Overview – Reporting Procedure 6
12.0 REFERENCES 7
Contractor and Client Approvals
00 / 11/1/2013 / Document / Procedure in final for initial implementation / BF
Rev. / Date / Revision Summary
00 / Nov 1, 2013 / Initial format for implementation.
Approver Name / Title / Signature / Date
PURPOSE
This practice defines the requirements for reporting, investigating, and managing incidents that have health, safety, or environmental significance. The requirements include reporting, investigating, and managing the following:
· Occupational injuries and illnesses (including classifying cases for recordkeeping/reporting purposes)
· Occupational exposure to toxic substances
· Motor vehicle incidents
· Property damage incidents
· Environmental incidents
· Near-miss and other health- and safety-related incidents
SCOPE
This practice includes the following major sections:
· Responsibilities
· General Requirements
· Reporting
· Investigation
· Classifying and Recording Incidents
· Press Releases
APPLICATION
This practice applies to all work activities and personnel working on the Gulfstream construction sites.
Note: All recording determinations, for recordkeeping purposes, will be made as defined and prescribed by the United States (U.S.) Occupational Safety and Health Administration (OSHA) Recordkeeping Handbook.
DOW DEFINITIONS
The Total Recordable Incident Rate (TRIR) is calculated as follows:
Total Recordable Incident Rate (TRIR)
Number of Recordable Injuries and Illness x 200,000 Hrs / = TRIRTotal Number Hours Worked
Incident Type / Definition
Incident / An unintentional and unplanned event causing, or with the potential to cause, injury, illness, property or asset damage, environmental damage, or loss of production. This covers terms such as near miss, near hit, non-injury incident, and similar phrases.
Injury / Illness / An injury or illness is an abnormal condition or disorder. Injuries include cases such as, but not limited to, a cut, an insect or animal bite/sting, fracture, sprain, or amputation. Illnesses include both acute and chronic illnesses, such as, but not limited to, a skin disease, respiratory disorder, or poisoning.
Near Miss / An unintentional and unplanned incident with the potential to cause injury, illness, property or asset damage, environmental damage, or loss of production.
First Aid / For the purposes of this standard, First Aid includes ONLY:
· Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment);
· Administering tetanus or tetanus/diptheria immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment);
· Cleaning, flushing or soaking wounds on the surface of the skin;
· Using wound coverings such as bandages, Band-Aids™, gauze pads, etc.; or using butterfly bandages or Steri-Strips™ (wound closing devices such as sutures, staples, medical adhesives, etc., are considered medical treatment);
· Using hot or cold therapy;
· Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (Note: Using devices designed to immobilize parts of the body are considered medical treatment);
· Using temporary immobilization devices during transport (e.g., splints, slings, neck collars, back boards, etc.).
· Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister;
· Using eye patches;
· Removing foreign bodies from the eye using only irrigation or a cotton swab;
· Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means (Example: magnet, needle, pins and small tools);
· Using finger guards;
· Using massages. Using stretching, strengthening and exercise. (physical therapy / physiotherapy or chiropractic treatment to treat a specific injury are considered medical treatment);
· Drinking fluids for relief of heat stress;
· Administering an IV as a precautionary procedure prior to diagnosis or during transport in case medication is needed (To keep open a pathway to facilitate potential treatment).
· Administering oxygen as a precautionary procedure provided that the person is not showing symptoms of an injury or illness as determined by Medical Personnel.
NOTE: A visit to a medical facility that does not result in treatment but where any pain, bruising, swelling, discoloration or physical signs from the event or exposure are observed would result in at least a First Aid classification.
LIFE Event / An actual life changing injury or fatality event.
pLIFE Event / A potential LIFE incident is any incident which could have resulted in a LIFE Incident had circumstances been slightly different. This includes reportable injuries less severe than a LIFE Incident and non-injury near misses.
• A Reportable Injury (Precautionary, FAC, RMTC, RWC or DAWC) that reasonably that could have escalated to a LIFE type injury.
• An unplanned event that did not cause a reportable injury, but reasonably could have caused a LIFE type injury.
• Non-injury pLIFEs associated with Life Critical Standard (LCS) errors (see section on LIFE and pLIFE Events)
• Other non-injury pLIFEs (i.e. no LCS error involved)
Precautionary Medical Visit / A visit to a medical facility that is initiated to ensure that no injury or illness has resulted from a work related event or exposure, with no physical impact detected.
Any bruising, swelling, discoloration or physical signs from the event or exposure would result in at least a First Aid classification.
Recordable Medical Treatment Case (RMTC) / A Recordable Medical Treatment Case (RMTC) is a recordable case where:
· medical treatment is given, or;
· it is a significant injury or illness, or;
· Other special cases as defined in requirement 02.11, and;
· it is not a fatality or a Restricted Work Case (RWC) or a Day Away from Work Case (DAWC).
Restricted Work Case (RWC) / A Restricted Work Case (RWC) is a recordable case where, because of a work related injury or illness, Facility/Work Group Leadership and/or Medical Personnel, decide with input from the injured/ill person to restrict work activity beyond the day of injury or onset of illness such that:
· He/she was kept from performing one or more of his/her routine functions, or
· He/she was kept from working the full workday that he/she would have otherwise been scheduled to work, or
· Medical Personnel recommends that he/she not perform one or more of his/her routine functions.
Day Away From Work Case (DAWC, LTI) / A Day Away from Work Case (DAWC), also known as a Lost Time Injury (LTI), is a recordable case where, because of a work related injury or illness, Construction site leadership and/or Medical Personnel determine with input from the injured/ill person that he/she is not able to work beyond the day of injury or onset of illness.
Recordable Case / Recordable / Recorded / Recordability / Those work related deaths, injuries and illnesses that are reported, are submitted into the Global Incident Reporting Database (GIRD) and are included in the performance metrics. Recordable cases include:
· Fatalities, regardless of the time between the injury, or the length of illness, and death (all fatalities are classified as DAWCs)
· Day Away from Work Cases
· Restricted Work Cases
· Recordable Medical Treatment Cases
· Significant Injuries & Illnesses
· First Aid Cases
· Precautionary Medical Visits
Reportable Case / Reportable / Reported / Reportability / Those work related deaths, injuries and illnesses and potential injuries and illnesses that must be communicated to the Injury & Illness Incident Classifier for evaluation to determine recordability. Reportable cases include:
· Fatalities, regardless of the time between the injury, or the length of illness, and death (all fatalities are classified as DAWCs)
· Day Away from Work Cases
· Restricted Work Cases
· Recordable Medical Treatment Cases
· Significant Injuries & Illnesses
· Other special cases as defined in requirement 02.11
· First Aid Cases
· Precautionary Medical Visits
1.0 RESPONSIBILITIES
Title: Incident Investigation Report (See separate document)
Purpose: Document incidents in detail
Responsibility: Supervisor/Manager or designee
Due: Initial by 10:00 AM the next working day. Final report within 5business days of incident
Distribution: Site Manager/Project Manager, Project/Site HSE Representative, Dow HSE, Dow Construction Manager
Title: Recordkeeping Classification Process
Purpose: Injury classification for recordkeeping/reporting
Responsibility: Site HSE
Due: Within 2calendar days
Distribution: Site Manager/Project Manager, Project/Site HSE Representative, Dow HSE, Dow Construction Manager
Title: Project Incident Log
Purpose: List of all incidents
Responsibility: Project HSE
Due: Monthly
Distribution: Site Manager/Project Manager, Site HSE, Dow HSE, Dow Construction Manager
Incident investigations should be conducted by an investigative “team” led by a line supervisor or manager at the project level.
2.0 GENERAL REQUIREMENTS
The Dow incident reporting form (Excel document) will be used. See naming convention below.
All persons are responsible for reporting incidents as soon as practicable after becoming aware of the incident occurring
All incidents will be formally reported within the terms and requirements of the relevant incountry, statutory authority.
Incidents should be a topic of a Toolbox Meeting for all affected or potentially affected employees on the project/site/office.
All incidents will be communicated at the weekly all hands meetings.
3.0 Project HSE
Project HSE will perform the following:
· Assist line management during the investigation.
· Review the completed Incident Investigation Report for completeness and accuracy.
· Determine the classification and maintain logs and summaries of the incidents.
· Document and report incidents determined to be site-related as required.
· Maintain a repository of case file documentation on all occupational injuries/illnesses, vehicle accidents, property loss, and near-miss incidents.
· Post copies of the (previous year’s) annual accident summary (OSHA 300A or equal) on bulletin boards by February 1 to permit employees to see the summary on their way to and from work.
· Complete an analysis and trend assessment of all incidents and report to construction site management at least monthly.
4.0 Supervisor/Manager
The immediate supervisor/manager will follow contractor company requirements. At a minimum, the supervisor will be involved in the investigation.
5.0 Contractors
Contractors will submit all incident reports and associated documents to the Gulfstream functional mailbox, .
Incident reports are to be titled in the following format: Gulfstream Gulfstream_Project_CompanyName_Incident type_MMDDYY
Example: Gulfstream _PDH_Fluor_FirstAid_120214
If more than one incident occurs during a day, add a number to the end of each incident.
Example: Gulfstream _PDH_Fluor_FirstAid_120214_1; Example: Gulfstream _PDH_Fluor_FirstAid_120214_2, etc.
6.0 LIFE and plife incidents
Two additional categories of events are to be reported to Dow. They are defined as LIFE and pLife events.
LIFE events are events that are actual life altering injuries reported as recordables.
pLIFE events are first aid, precautionary events, or near misses that have the potential to result in a life altering injury if circumstances had been different.
It is important that pLIFE events be investigated as if a severe injury had occurred in order to gather learnings and implement action items to prevent re-occurrence of the event.
Non-injury events related to errors in following the Dow Life Critical Standards (Hot Work, Confined Space Entry, Elevated Work, Electrical Standard, Line and Equipment Opening, Isolation of Energy, Hydroblasting/Pressure Washing) must be investigated and reported as a pLIFE event. Examples include:
· High Energy Hot Work in a in a flammable area without a Hot Work Permit
· Entry into a Confined Space without a Confined Space Entry permit
· Introduction of a hazardous energy source i.e. nitrogen into a confined space while work is in progress
· Failure to recognize the requirement for a Life Critical Guard
· Aerial lift work or crane work near overhead electrical lines without the proper permits
· Excavation without a permit
Other examples of non-injury pLIFE events that are not related to a life critical standard are:
· Equipment or material falling into an area where people are working where the equipment or material is of sufficient size to have caused a severe injury
· Actual falls from a height of 6 feet or greater where no injury occurs
· Any time fall arrest equipment is engaged from a height of 6 feet or more where no injury occurs
· Motorized vehicle or equipment contact with a person causing no injury
· Exposure to a chemical that could reasonably be anticipated to result in life threatening acute toxicity
Consult with the Dow project safety representative for classification of LIFE and pLIFE events.
7.0 incident REPORTING
Incident communication occurs as follows.
Who Does The Contacting / Who Do They Contact / When / ActionEmployee involved in incident or co-workers witnessing incident / Foreman/Crew Leader/Supervision / Immediately / · Report incident
· Dow – property – Call for ambulance (site emergency numbers; via radio channel)
· Non-Dow property – follow agreed upon process
Foreman/Crew Leader / · On-site Company Supervision
· HSE Representative / Immediately / · Report Incident
On-site Company Supervision / · Contractor company
· Dow contact / Immediately / · Report Incident
· Communicate
Contractor HSE Manager / · Contacts Gulfstream EH&S Leader or designee / Immediately / · Report Incident
· Communicate
The reporting timeline is as follows.
8.0 INCIDENT DOCUMENTATION
A copy of the following documentation is required in every incident package if applicable.
Dow has the option to request an RCI of a near miss after reviewing the event.
Check / Recordable/LIFE/pLIFE / First Aid / Precautionary / DocumentationX / X / X / Dow Incident Form (Excel document)
X / Safe Work Permit & other permits
X / STAC
X / X / PTACC (if applicable)
X / JSA
X / Training Badge
X / Timeline of event
X / Photographs (get permission from Dow first)
X / X / X / Employee statements
X / Witness statements
X / X / At Risk status and documentation (if applicable)
X / Copy of driver’s license (if MVA)
X / Diagram of incident scene if photos can’t be taken
X / Photos of involved equipment or tools
X / Copy of root cause diagram
X / X / X / Copy of corrective actions or flash report
Incident Reporting, Investigation, This is a controlled document. No un-authorized modifications.