Incident Classification, Investigation, and Reporting Manual
Incident Classification, Investigation, and Reporting Manual
Incident Classification, Investigation, and Reporting Manual
INCIDENT CLASSIFICATION,
Version 311207
The companies belonging to the Royal Dutch/Shell Group of companies are separate and distinct entities, but in this document the collective
expressions “Shell” and “Group” are sometimes used for convenience in contexts where reference is made to the companies of the Royal
Dutch/Shell Group in general. These expressions are also used where no useful purpose is served by identifying the particular company or companies.
This document is prepared by Shell International B.V. (SI) as a service under arrangements in existence with companies of the Royal Dutch/Shell
Group; it is issued for the guidance of these companies and they may wish to consider using it in their operations. Other interested parties may receive
a copy of this document for their information. SI is not aware of any inaccuracy or omission from this document and no responsibility is accepted by
SI or by any person or company concerned with furnishing information or data used in these guidelines, for the accuracy of any information or advise
given in the guidelines or for any omission from the guidelines or for any consequences whatsoever resulting directly or indirectly from compliance
with or adoption of guidance contained in the guideline even if caused by a failure to exercise reasonable care.
The copyright of this document is vested in Shell International B.V., The Hague, Netherlands.
All rights reserved.
DECEMBER 2007
HEALTH, SAFETY AND ENVIRONMENT PANEL
Incident Classification, Investigation and Reporting
1 Management Summary 4
1.1 Purpose and Scope 4
1.2 Group Standards 5
2 Recording of Incidents 6
3 Investigation of Incidents 7
3.1 Responsibilities and Competence 7
3.2 Extent of Investigation 7
3.3 Investigation Process 7
3.4 Establishing the Sequence of Events 8
3.5 Analysis of Underlying Causes and Weaknesses in Management System 8
3.6 Incident Report and Follow up 9
5 Classification of Incidents 11
5.1 Work Related Activities 11
5.2 Injuries 12
5.3 Illnesses 12
5.4 Incidents Resulting in Asset Damage, Environmental Impact and/or Impact on Company Reputation 12
5.5 Near Misses 12
5.6 Potential Incidents 13
5.7 High Risk Incidents 13
6 Reporting of Incidents 14
6.1 Reporting Company 14
6.2 Reporting of Significant Incidents 15
Appendix 4 Distinguishing between Injuries and Illnesses, and Determining whether Illnesses are
Occupational 30
Musculo-skeletal Conditions including Back Problems 30
Repetitive Strain Injury (RSI) 32
Work Related Stress 32
Burns 32
Dermatitis 33
Animal Bites and Insect Stings 33
Heart Attacks 34
Infectious Diseases 34
Common Subjective Symptoms 34
Food Poisoning 34
Noise Induced Hearing Loss 35
Eye Problems 35
Aggravation of an Existing Physical Deficiency 36
Pre-existing Conditions 36
Infected Laceration 36
Reaction to Medical Treatment 36
Recurrence of Symptoms 36
Medical Verification by a Medically Qualified Person 37
Individual Susceptibility 37
Permanent or Temporary Transfers 37
Overexposure to Health Hazards 37
1 MANAGEMENT SUMMARY
1.1 Purpose and scope (most of this section will be removed when the Manual is released)
The Shell Group HSE policy requires that every Shell Company “has a systematic approach to HSE
management designed to ensure compliance with the law and to achieve continuous performance
improvement” and “sets targets for improvement and measures, appraises and reports
performance”. An essential feature of the systematic approach and continuous performance
improvement is the reporting of incidents, so that they can be investigated, lessons learned, and
performance monitored.
The guiding principles for incident reporting, investigation and learning will be set out in
the new Incident Investigation and Learning Manual. The following is provided as an
interim and will be removed from this document when the Manual is released.
The guiding principles for incident reporting, investigation and learning are that:
management controls should be in place for activities and operations having the
potential for incidents with a significant impact on the company
we will investigate all incidents where management controls should have been in place
(even if the incidents are not formally work related (see definitions)) and take action to
measure the effectiveness of these management controls. It is all about learning.
The guiding principles for classification and recording are that:
we will classify our injury incidents (using the OSHA definitions and OGP scope) and
include these cases in the statistics as a means of benchmarking our performance.
This document provides guidance on the recording, investigation, learning, classification, and
reporting of incidents which result in injury or illness, and in damage to assets, the environment or
company reputation. It also addresses incidents that had no adverse outcome, i.e. near misses. It sets
out the rules for the reporting of incidents by Shell companies and joint ventures. This revision
replaces the Group Incident Classification and Reporting Guide (2002).
The reasons for revising this guide are:
To incorporate a section on Learning from Incidents
To align the guidance on classification of illnesses and injuries more closely with the US
Occupational Safety and Health Administration (OSHA) and the International Association of
Oil and Gas Producers (OGP) system for scope;
To incorporate findings from audits and reviews;
This is a transition document. The high level mandatory requirements will be moved to the new
Incident Investigation and Learning Manual in 2008 under the HSE Control Framework
Project. The majority of the contents will be retained in a supporting document to the new Manual.
The extensive OSHA documentation can also be used as guidance except where this document
specifically excludes its use i.e. Stress. Differences between this document and OSHA should be
brought to the attention of the team responsible for the maintenance of this document via your
Business / organization HSE Data Reporting focal point. The suspected differences will then be
reviewed and either corrected in the next revision or specifically retained.
The Group procedure for an HSE Management System applies to all companies that are under
Shell’s operational control. This procedure requires that “all incidents and near misses with
significant actual or potential consequences shall be thoroughly investigated and reported”.
This section details the standards and procedures that are mandatory for all Companies:
Companies shall implement processes for identifying and logging all incidents that occur in
their activities. They shall classify the incidents in terms of actual consequences and risk rating,
applying the Risk Assessment Matrix (RAM);
Companies shall investigate all significant incidents, i.e. those with actual consequences to the
company which rate 4 or 5 on the RAM, to establish both immediate and underlying causes and
weaknesses in the HSE management system. The investigation shall include Tripod or causal
learning methodologies. They shall recommend actions to prevent recurrence and to improve
effectiveness of the HSE management system. They shall report the findings of their
investigation and their action plan to the business. The Procedure for Reporting and Review of
Significant Incidents is detailed in Appendix 13;
Companies shall investigate all high-risk incidents that have a high risk rating on the RAM, to
establish the immediate and underlying causes and weaknesses in the HSE management system.
They shall recommend actions to prevent recurrence and to improve effectiveness of the HSE
management system. When the investigation reveals significant learning potential (see section 4)
they shall report the findings and learning to the business.
2 RECORDING OF INCIDENTS
(will be rewritten when Manual is released)
The Group is moving towards a common recording system known as Fountain Incident
Management (FIM) that satisfies the requirements for recording incidents. Alternate systems can be
used in the interim. In order to facilitate learning, all RAM 3+ incidents shall be recorded in English.
Details of incidents need to be recorded (logged) before investigations commence. The initial
incident recording will require an initial RAM classification in order to determine the level of
investigation.
All incidents where management controls have failed or should have been in place, or where
learning can be extracted, need to be reported and entered into FIM or equivalent interim system –
even if they are not work related. The primary objective is to learn from the established facts and
prevent recurrence. We will record, investigate and learn from incidents that are not formally work
related under the classification system.
The recording or reporting of a (potentially) work-related injury, illness, or fatality does not mean
that the recording organization was at fault, that a rule or regulation has been violated, or that the
effected party is eligible for workers’ compensation or other benefits. The details recorded in the
system and the classification may change as additional information becomes available as part of the
investigation or subsequent to the investigation.
The FIM system may be used to record and circulate details of accidents that have occurred in other
organizations or industries.
Reporing of Incidents
3 INVESTIGATION OF INCIDENTS
3.4.1 Timeline
A timeline is simply a list of the events in chronological order. For straightforward incidents a
timeline and narrative will suffice as a description of the sequence of events.
The Tripod Beta methodology applies linked HET trios to describe the sequence of events before
and after an incident. It is described in detail in EP 95-0321 Tripod Beta, which is available on the
Exploration and Production web site at:
http://sww.siep.shell.com/hse/index.htm?target=/hse/safe/tripod.htm.
A STEP identifies the actions of key “actors” in the incident and plots them against time. The
“actors” can be people, vehicles, items of process equipment, process conditions etc. The scale of
the time axis is normally not linear, but varies to suit the interval between events. Each event is
described in terms of date, time, actor and action.
The value of a STEP is that it enables a visual representation of the sequence of events to be shared
by investigation team members and witnesses. It focuses the investigators on agreeing the sequence
of events before starting to analyse the causes. A STEP is amenable to a white board and post-it
technique. STEP is particularly powerful in providing an overview of complex process incidents.
An example of a STEP diagram is shown in Appendix 10.
This variation applies the HET trios to represent the sequence of events, and the Tripod theory of
incident causation, including “caused by” and “leads to “ guides, to establish the latent failures. The
Tripod Beta computer tool includes a number of wizards to facilitate the several stages in building a
Tripod tree. It also enables a report to be generated in a standard format.
This method is described in detail in EP 95-0321 Tripod Beta, which is available on the Exploration
and Production web site at:
http://sww.siep.shell.com/hse/index.htm?target=/hse/safe/tripod.htm.
The investigation and analysis of less serious incidents, where a Tripod methodology or causal
learning methodology analysis is not being undertaken, should include an analysis of factors such as
type of incident, type of injury, phase of operation or activity, cause of incident. This type of analysis
of all the incidents occurring over a period of time can provide valuable input to an incident
prevention programme.
The incident report presents the investigation findings, analysis and action plan. Recommended
actions arising from the incident investigation should be entered in Fountain Incident Management
or equivalent system for tracking and close out.
Appendix 11 shows the recommended report format for an investigation of a significant incident. If
Tripod Beta is used for the analysis, the report can be generated automatically in a standard format.
The incident report should be reviewed at the appropriate management level as a check on the
completeness and quality of the investigation and to obtain agreement to the proposed actions.
When compiling incident reports that may be required by authorities and other third parties outside
the company, it is recommended to seek legal advice before commencing the reports. Requests for
copies of incident reports should be considered individually taking into consideration the potential
risks and exposures for the company, its directors and employees and the possibility of criminal or
civil liability.
The text below has been provided by the cross Business LFI Working Group for inclusion in the
new Incident Investigation and Learning Manual. This section will be removed from here
when the Manual is in place.
Learning needs to be extracted and disseminated for all incidents where management
controls have failed or should have been in place, and all incidents where learning can
be extracted; even if the incidents are not classified as work related.
5 CLASSIFICATION OF INCIDENTS
Incidents are unplanned events or chains of events that have, or could have, resulted in injury or
illness or damage to assets, the environment or company reputation. This section describes how to
determine if an incident is work related and then goes on to describe the various types of impact of
incidents. Definitions and explanations of the terms used are presented in Appendix 1 and a
flowchart of the process of classifying incidents is given in Appendix 2. Examples of the different
types of impact of incidents are given in Appendices 3 to 8.
Where there is any doubt, decisions on work relatedness and other classification matters should be
made after the investigation is completed.
Work Related incidents shall be recorded and included in performance statistics. The following
activities should be considered as potentially work related until shown otherwise, as they are
susceptible to incidents with significant impact, for which company controls should be in place:
All work by company personnel;
All work by contractor personnel on company premises;
All work by contractor personnel on non-company premises for which it is concluded on the
basis of risk considerations that company and contractor management controls are required.
For company personnel work includes overtime, attending courses, conferences and company
organised events, business travel, field visits, or any other activity where the employee’s presence is
expected by the employer. Participation in voluntary programs is not considered work related but
high potential incidents arising at such events will be recorded and investigated for their learning
potential.
For contractor personnel, the same activities are included when they are executed under a contract
on behalf of the company. Contractor includes all sub-contracted activities.
Where it is impossible or inappropriate for the company to seek to apply management control on a
contractor, exceptions may be justifiable. Examples may be found in areas where contractor services
are not dedicated to the company, for example:
Manufacturing of components in a factory together with the manufacture of components for
other customers;
Construction at a contractor's fabrication site shared by other customers;
Delivery of goods or products to company locations by a contractor who is also employed to
deliver goods or products to other companies during the same journey;
Customer collection of company products, where the vehicle and drivers are under the control
of the customer.
For these exceptional situations the company should make a conscious, risk based and documented
decision whether or not to maintain management controls and include incidents in performance
reports.
Appendix 12 provides further guidance and a number of examples to illustrate what are work related
activities, see also the definition of Work Related.
Reporing of Incidents
5.2 Injuries
The various terms are defined in Appendix 1 and guidance on the types of Medical Treatment Cases
(MTC) and First Aid Cases (FAC) is given in Appendix 3.
The potential consequences of injuries should be assessed on the RAM.
5.3 Illnesses
Overexposure to hazardous chemicals, noise and other health hazards should be considered as near
misses when the exposure did not result in an identified illness.
Companies should encourage the reporting and analysis of near misses as they provide a valuable
source of learning that can be applied to prevent future incidents.
Potential incidents are unsafe practices or hazardous situations that could result in an incident
(incident has not occurred).
Potential incident data is frequently collected in the course of work-site inspections, unsafe act
auditing, management walks and through incident or near miss reporting systems.
Companies should encourage the reporting and analysis of potential incidents as they provide a
valuable source of learning that can be applied to prevent future incidents.
6 REPORTING OF INCIDENTS
The companies that are required to report incidents in accordance with this guide are Shell
companies and Joint Ventures that are under Shell’s operational control (JVs-uoc), i.e. entities over
which a Shell company has the full authority to impose the adoption and implementation of the
Group HSE Policy and Procedure.
For Joint Ventures not under operational control (JVs-nuoc), Shell companies are required to use
their influence to promote the Group HSE policy and to encourage JVs-nuoc to report their HSE
performance and incident data. Refer to Appendix 9 of Group HSE Management System (1999) for
details of the management of JVs-nuoc.
For shipping activities operational control applies to Group owned and demise (bare boat) chartered
vessels but excludes time or voyage chartered vessels. Trading is only operationally responsible for
the Trading managed fleet. The other fleets that are included in the shipping sector, whilst reporting
to Trading, are the operational responsibility of other operating companies, i.e. Shell UK, Norske
Shell, Shell CAPSA, ALSOC and SCOA.
The data included in the Shell Group external reports will draw on data reported by Shell companies
and JVs-uoc under this guidance and may be subjected to independent verification.
For internal reporting purposes, HSE data is to be reported to Group (CAE) via the Business and
Organization lines. The existing reporting entities as of 2007 are Exploration and Production,
Downstream, Gas & Power, Trading, Shell Global Solutions and Central Functions. This may
change with time. The Shell People Organization Online Unit hierarchy can be used to determine
which organisation unit is responsible for reporting each employee’s incidents and exposure hours to
Group (CAE).
In the case of Contractors, the reporting entity managing and directing the contractor’s activities are
responsible for reporting the contractor’s incidents and exposure hours, wherever they are working.
In some exceptional situations there may be reasons for a unit to establish incident reporting
responsibilities that differ from those stated above. If so, both units HSE Management Systems
must have documented the arrangements prior to any incidents.
When a company employee or contractor/consultant is visiting or on assignment in a Group
company other than his employing company the responsibility for reporting any incidents associated
with that employee lies with the employing company that also records the employee’s exposure
hours. The company being visited is responsible for investigating the incident and for implementing
resulting recommendations. This rule also applies to employees of Group Functions and Shell
Global Solutions International despite the fact that these service providers will have a contractual
arrangement with the company being visited. The presumption is that because they are Shell
companies these consultants will be working to Shell Group standards.
In the case that exposure hours are not calculated, e.g. for third party injuries and environmental
incidents, the company responsible for operating the equipment or facilities involved is responsible
for reporting.
Reporing of Incidents
All significant incidents, having actual consequences rated 4 or 5 on the RAM, shall be notified to
the business director within 24 hours. Final classification on the basis of the investigation report is
the responsibility of the business HSE adviser.
Refer to Appendix 13 for the details of the Procedure for Reporting and Review of Significant
Incidents.
Non-accidental Death
In case of a Non-accidental Death (NAD), there is a requirement to identify whether the incident
may be work related or involve a failure(s) of company or contractor management controls that
should have been in place. This applies also to non-accidental deaths in company premises and
non-company premises including company and contractor accommodation where there is reason
to suspect a relationship between the death and events or exposures related to work.
The NAD shall be notified to the business within 24 hours in all cases where the death occurred
at the company premises and investigated to:
Decide whether there is a causal relationship between work and the death, in which case
the death should be classified as work related and recorded in statistics using definitions
of work-relatedness as defined in this document.
Determine if the company medical emergency response procedures, including first aid,
medical treatment and medical evacuation were suitable and complied with Shell
standards?
If the NAD occurred outside the company premises and/or outside normal working hours, the
NAD shall be notified to the business within 24 hours if and when any of the following questions
is answered by “yes”:
Were there any work related exposures, e.g. contacts with hazardous substances or
working conditions that could have caused or contributed to the death?
Were there any pre-existing medical conditions relevant to the job of the individual?
Has the individual been declared unfit to carry out his normal duties in compliance with
company standards or not had a relevant fitness to work assessment?
Did the individual exhibit any signs or symptoms associated with the cause of death
Deliberate Death
Suicides and homicides should be notified to the business as soon as practicable. If the initial
investigation indicates a work-relationship, they should be investigated in the same way as an
accidental death and included in statistics.
Asset Damage
A direct loss of or damage to plant, equipment, tools or materials resulting from an incident. (Refer
to guidance and examples in Appendix 6).
Business
One of the global Shell businesses, i.e. Exploration and Production, Downstream or Gas and Power.
Business Travel
For a Shell employee, Business Travel is any travel undertaken for the purposes of work activities in
which that person is engaged in the interests of his or her employer, to the following extent:
It includes the period from the time that person leaves their residence or their normal place
of work until they return or until the time they arrive at their destination and check into
temporary accommodation (‘home away from home’).
It includes, on the return trip, the period from when the person checks out of their
temporary accommodation until they arrive at their residence or their normal place of work.
It includes the whole spectrum of travel, from international travel through to simple acts like
crossing a public road on foot between two company buildings.
It excludes a person’s normal commute to work.
It includes travel to the airport for a business trip from the time an employee leaves home
even if that travel follows the same route as their normal commute. If the employee stops in
the office first to work, then the period of employee’s business travel starts from the office
and not their home.
It excludes that person’s commute from their home away from home to their temporary
place of work or a significant detour made for personal reasons.
Any injury or illness occurring during the business trip is considered to be work related for
recording, investigation and learning purposes; but not all injuries and illnesses will be
recordable for statistical purposes.
It includes day-to-day travel undertaken by a Shell contractor in the course of carrying out Shell
work-related activities.
It excludes day-to-day travel undertaken by the Shell contractor when that person is not engaged
in Shell work related activities (such as their normal commute, or any travel undertaken in the
interest of their own employer).
It includes contractor mobilization and demobilization when performed under contract with
Shell.
Business Unit
Activities in one of the Group businesses that are operated as a single economic entity. A business
unit can coincide with a Group company or straddle part or all of several companies.
Company
Company or Group company means a Shell company, a Joint Venture under operational control
(JV-uoc), or a Joint Venture not under operational control (JV-nuoc) that has agreed to report its
HSE performance and incident data to Group following the reporting methodology detailed in this
guide.
Contractor
All parties working for the company either as direct contractors or as subcontractors.
Environmental Impact
The negative impact on the environment resulting from an incident. (Refer to guidance and
examples in Appendix 7).
Exposure Hours
The total number of hours of employment including recorded overtime and training but excluding
leave, sickness and unrecorded overtime hours. Exposure hours should be calculated separately for
company and contractor personnel.
Time off duty, even if this time is spent on company premises, is not included in the calculation of
exposure hours, but incidents during this time should be recorded and investigated. When they meet
the work related definition, they should be included in the statistics as recordable incidents.
(Refer to guidance and examples in Appendix 14).
In many company sites the number of exposure hours can be calculated from computer controlled
access or time keeping records. In the absence of more accurate methods exposure hours can also
be calculated from a headcount and nominal working hours per person or time writing systems.
In order to meet reporting schedules, exposure hours can be estimated on the basis of the previous
data. Corrections can be made at the end of the reporting year when more time is available.
OSHA now requires 24 hrs man-hour counting for Off shore (off shore ruling). Will include text.
Fatality
A death resulting from a work related injury or occupational illness, regardless of the time
intervening between the incident causing the injury or exposure or causing illness and the death.
FAR
The number of fatalities per hundred million exposure hours.
FIM
Fountain Incident Management (FIM) is the Group system for recording incident details, the
investigation, classification and action items. It can also issue notifications and reports. Other
systems can be used in the interim; but all Businesses and Functions are expected to be using FIM
by end 2009. FIM should be used for all potentially work related incidents including those that occur
while in “home away from home status”.
First Aid
An incident is classified as a First Aid if the treatment of the resultant injury or illness is limited to
one or more of the 14 specific treatments. These are:
1. Using a non-prescription medication at non-prescription strength (2);
2. Administering tetanus immunizations;
3. Cleaning, flushing or soaking wounds on the surface of the skin;
4. Using wound coverings such as bandages, Band-AidsTM, gauze pads, etc.; or using butterfly
bandages or Steri-StripsTM.
5. Using hot or cold therapy;
6. Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts,
etc;
7. Using temporary immobilization devices while transporting an accident victim (e.g., splints,
slings, neck collars, back boards, etc.).
8. Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister;
9. Using eye patches;
10. Removing foreign bodies from the eye using only irrigation or a cotton swab;
11. Removing splinters or foreign material from areas other than the eye by irrigation, tweezers,
cotton swabs or other simple means;
12. Using finger guards;
13. Using massages; or
14. Drinking fluids for relief of heat stress.
Note: When determining whether a prescription medicine was used the normal practise is to
apply the definitions used in the country where the incident occurred. However, when making
this classification it should be remembered that the intent is to distinguish those more severe
situations that require a medical practitioner to use strong antibiotics and painkillers from those
that only require first aid. The definition of Prescription Medication may be used as guidance
in making decisions between those that are strong antibiotics and painkillers from those that
only require first aid.
Incident
An unplanned event or chain of events that has, or could have, resulted in injury or illness or
damage to assets, the environment or company reputation.
Incidents do not include operations, maintenance, quality or reliability incidents which had no HSE
consequence or potential. Incidents do not include degradation or failure of plant or equipment
resulting solely from normal wear and tear.
Injury
Any injury such as a cut, fracture, sprain, amputation etc. that results from a single instantaneous
exposure.
First Aid.
Medical Treatment Case (MTC)
Any work related injury that involves neither lost workdays or restricted workdays, but which
receives Medical Treatment. (Refer to relevant definitions in Appendix 3).
Near Miss
An incident that could have caused illness, injury or damage to assets, the environment or company
reputation, or consequential business loss, but did not.
Occupational Illness
Any abnormal condition or disorder of an employee, other than one resulting from an occupational
injury, caused by exposure to environmental factors associated with employment. An illness is
work-related if the balance of probability is 50% or more that the case was caused by exposures at
work.
Occupational illnesses include acute and chronic illness or diseases that may be caused by inhalation,
absorption, ingestion or direct contact with the hazard, as well as exposure to physical and
psychological hazards. (Refer to guidance and examples in Appendix 4).
OSHA occupational illness cases will be captured for benchmarking purposes in FIM (and other
systems where possible).
Operational Control
See “Instructions on Determining Operational Control” – Appendix 5 of the PMR
Prescription Medication
1. All antibiotics, including those dispensed as prophylaxis where injury or illness has occurred to
the subject individual.
Exceptions: Dermal applications of Bacitracin, Neosporin, Polysporin, Polymyxin, Iodine or
similar preparation.
2. Diphenhydramine (Benadryl) greater than 50 milligrams( mg.) in a single application.
3. All analgesic and nonsteroidal anti-inflammatory medication (NSAID) including:
Ibuprofen (such as AdvilTM) - Greater than 467 mg. in a single dose.
Naproxen Sodium( such as AleveTM-) Greater than 220 mg. in a single dose.
Ketoprofen (such as Orudis KTTM) - Greater than 25mg. in a single doge.
Codeine analgesics (Cocodamol, Panadeine, etc.) – Greater than 16 mg. in a single dose.
Exceptions: acetylsalicylic acid (Aspirin) and acetaminophen (paracetamol) are not considered
medical treatment.
4. All dermally applied steroid applications.
Exceptions: hydrocortisone preparations in strengths of 1% or less.
5. All vaccinations used for work-related exposure
Exceptions: Tetanus
6. All narcotic analgesics (except codeine as listed above)
7. All bronchodilators
Exceptions: Epinephrine aerosol 5.5 mg./ml or less
8. All muscle relaxants (e.g. benzodiazepines, methocarbamol and cyclobenzaprine).
9. All other medications (not listed above) that legally require a prescription for purchase or use in
the state or country where the injury or illness occurred.
Note: Where there are apparent contradictions, advice should be sought from a Company physician
and reasoning documented.
Potential Incident
An unsafe practice or a hazardous situation that could result in an incident (incident has not
occurred).
Reputation Impact
The negative impact on company reputation resulting from an incident. The negative impact can be
in the form of adverse attention from media, politicians or action groups, or in public concern about
company activities. (Refer to guidance and examples in Appendix 8).
Restricted Work
Any work related injury or illness that keeps the employee from performing one or more of the
routine functions associated with their job or a physician recommends that the employee not
perform one or more of their job's routine duties.
Significant Incidents
Incidents with actual consequences that rate 4 or 5 on the RAM. (people, environment, damage or
reputation).
Third Parties
Persons or organisations that are not employed by or contracted to a company or contractor.
The OSHA definition of work relatedness excludes a mental illness (unless it is post-traumatic stress
syndrome where it can be tied to a specific workplace incident, or are incidents where the employee
voluntary provides an opinion from a physician or other licensed health care professional stating the
employee’s mental illness is work-related).
Incident occurs
N Actual loss? Y
N Injury/
illness?
Asset, Y
N High risk environment
on RAM? or reputation
incident
Y
Fatality N
or PDT?
Y Illness? N
N Learning
for others?
Y Lost N
Y Workdays?
Y Restricted N
N Consequence work?
4 or 5? Medical
Y N
treatment?
Y
Y
TROI LWC RWC MTC FAC
OSHA occupational illness cases will be captured for benchmarking purposes in FIM (and other
systems where possible).
First Aid.
First Aid
An incident is classified as a First Aid if the treatment of the resultant injury or illness is limited to
one or more of the 14 specific treatments. These are:
1. Using a non-prescription medication at non-prescription strength (2);
2. Administering tetanus immunizations;
3. Cleaning, flushing or soaking wounds on the surface of the skin;
4. Using wound coverings such as bandages, Band-AidsTM, gauze pads, etc.; or using
butterfly bandages or Steri-StripsTM.
5. Using hot or cold therapy;
6. Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid
back belts, etc;
7. Using temporary immobilization devices while transporting an accident victim (e.g.,
splints, slings, neck collars, back boards, etc.).
Note: When determining whether a prescription medicine was used the normal practise is to
apply the definitions used in the country where the incident occurred. However, when making
this classification it should be remembered that the intent is to distinguish those more severe
situations that require a medical practitioner to use strong antibiotics and painkillers from those
that only require first aid. The definition of Prescription Medication may be used as guidance
in making decisions between those that are strong antibiotics and pain killers from those that
only require first aid.
7. All bronchodilators
Exceptions: Epinephrine aerosol 5.5 mg./ml or less
8. All muscle relaxants (e.g. benzodiazepines, methocarbamol and cyclobenzaprine).
9. All other medications (not listed above) that legally require a prescription for purchase or use in
the state or country where the injury or illness occurred.
Note: Where there are apparent contradictions, advice should be sought from a Company physician
and reasoning documented.
Examples
1. A worker was installing a window mounted air conditioning unit. As the worker was sliding it
into place, it tilted and started to fall. The worker caught it and forced it into place, but in doing
so felt a sharp pain in the back. This would be considered work related injury, since the
condition resulted from the sudden effort required to prevent the unit from falling.
2. A worker’s foot slipped in the process of swinging a hammer and a back pain developed
immediately. This would be considered a work related injury, since the onset of symptoms was
directly associated with the slip that occurred in the course of and arose out of employment.
3. An employee with a known back problem experienced a recurrence of back pain whilst lifting a
drum of lubricating oil. This would only be considered a work related injury if the original
condition was aggravated as a consequence of a lifting action which was outside the normal
limits of the task, i.e. over exertion.
4. A clerk who is usually involved in work that is not physically demanding was asked to assist in
unloading a large shipment of heavy items by hand. The clerk felt no discomfort that day but
the following morning the his right shoulder and back muscles are so sore that he was unable to
perform the normal job effectively and had to be given specially selected duties. The injury was
consistent with the type of work performed on the previous day and the case would be
considered a work related injury.
Examples
1. An employee reported severe back pain that gradually developed towards the end of each
workday, but could not attribute the condition to any specific event or activity. After reviewing
the employee's work assignments, it was concluded that the condition resulted from continuous
over exertion in the performance of the employee's duties. The case would be considered an
occupational illness.
2. A seismologist was engaged routinely in the use of a standard mouse in manipulation of on-
screen data. Over a period of some weeks he noted gradual onset of pain, stiffness and local
tenderness over the wrist and forearm that improved following a break from work. After
clinical assessment of the case, it was concluded that the condition primarily resulted from
continuous over exertion and would be considered an occupational illness. See the section on
Repetitive Strain Injury for further guidance on reportability.
Examples
1. An employee sprained lower back muscles in a minor road traffic accident whilst on leave. The
pain eased and the employee was able to return to work a few days later. A recurrence of the
pain was felt when the employee got up from his chair. There is no evidence of a prior incident
at work causing or contributing to the condition. This condition is attributed solely to the
employee’s pre-existing physical condition and therefore would not be considered a work
related injury.
2. An employee reached up without overreaching to pick up a hard hat from the top of a locker
and experienced back pain. There was no evidence of a prior incident, the trigger for the
condition was within normal job limits, the employee had no previous history of work related
back problems, and therefore the condition would not be considered as work related.
Appendix 1
A stress case is considered to be work related when there is an identifiable organisational and/or
interpersonal factor in relation to work and the working environment which has contributed to a
stress related disorder. requiring significant intervention, such as specific counselling or treatment,
modification of duties or loss of time from work.
This is a deviation from OSHA. The Shell definition shall be applied
Stress reactions caused by traumatic events at work, such as being involved in an armed robbery, a
major explosion or fire in the work environment, are also considered to be work related.
Burns
Contact with heat, cold, electricity, intense radiation or a caustic chemical that produces a burn in a
single contact, is a work related injury. Sunburn or welding flash burns that result from prolonged or
repeated exposure are considered occupational illnesses.
Burns should be treated just as other types of injury are, i.e., minor burn injuries will be first aid,
while more serious burns will be at least a medical treatment case because they will involve medical
treatment. For example, a small second degree burn to the forearm that is treated with nothing more
than a bandage is first aid. A larger or more severe second degree burn that is treated with
prescription creams or antibiotics, or results in restricted work, job transfer, or days away from work
is a Recordable Case. The vast majority of first degree burns and minor second degree burns will not
be a Medical Treatment Case because they will not meet the medical treatment criteria. However,
more serious first and second degree burns (e.g. burns to the palm of the hand or face) that receive
medical treatment will usually be recordable, and third degree burns should always be recordable
because they require medical treatment as a minimum.
Appendix 4: Distinguishing between Injuries and Illnesses, and Determining whether Illnesses are Occupational
Dermatitis
Example:
A chemical worker contracted a mild case of dermatitis on both hands while working with a solution
for several hours. The employee was sent to the doctor, who recommended application of a topical
lotion (a commercial, non-prescription remedy). The employee bought a bottle of the lotion and
treated the rash for a few days until it disappeared. There were no subsequent visits to the doctor.
The rash did not prevent the employee from performing all the duties of the job. If considered an
injury, the case would not be recordable since no medical treatment was provided. However, since
the case almost certainly did not involve a single instantaneous exposure, it should be classified as an
occupational illness. A dermatitis or pulmonary condition caused by or aggravated by exposure to a
chemical skin or pulmonary sensitizer is always recordable as an occupational illness. Consequently,
the kind of treatment given by the doctor (even if no treatment is given) is immaterial, since all
occupational illnesses are recordable.
Animal bites and insect stings are normally considered as work related injuries if they occur in the
course of employment. However, repeated exposure may result in disorders that are considered
occupational illnesses.
Example 1:
A snake bit a lineman engaged in routine work. The case would be considered a work related injury.
Example 2:
Insects carrying the disease leishmaniasis bit a member of a party clearing jungle for seismic work.
The resulting sickness would be considered an occupational illness.
Example 3:
Malaria or other diseases that result from mosquito bites or insect stings are classified as
occupational illnesses (see Infectious Diseases).
Heart Attacks
Heart attacks are not normally classified as work related injuries because they normally do not result
from single instantaneous incidents in the work environment. When heart attacks do occur, they
should be assessed against the criteria for occupational illnesses. This means that heart attacks
occurring in the working environment should only be classified as occupational illnesses if they
result or mainly result from exposures at work.
Infectious Diseases
Infectious diseases such as malaria and Chagas disease are only recordable if they have been
confirmed by clinical testing or by a doctor. If the illness is endemic to an area or the country and
employees indigenous to that area are diagnosed with the illness on a regular basis cases should not
be reported. If the illness occurs among employees from an area where the illness is not endemic,
the illness should be classified as an occupational illness. Diseases caused by insect stings, such as
malaria, are normally considered as work related if they occur in the course of employment even if
the mosquito bite may have occurred outside the company premises.
Food Poisoning
Food poisoning should be treated as an illness and will normally impact a group of individuals.
See the definition of Work Related - point 4 Appendix 1 and Meal Period Illnesses in Appendix 12.
If the food poisoning arises from food provided in a hotel or restaurant not under control of the
employer or provided in an airplane, it is potentially recordable as an occupational illness if the
person is involved in a work related activity at the time and it can be demonstrated that multiple
people have been impacted. It is recognized that this is going to be difficult to establish in many
cases.
Non work related cases should be recorded for learning purposes.
Deep Vein Thrombosis (DVT) is a medical condition where a blood clot causes a blockage in a deep
vein - usually in the legs, thighs and pelvis. Complications from DVT can result e.g. when a clot
breaks off and lodges in the lungs, causing Pulmonary Embolism (PE). This is life threatening. DVT
is recordable as an occupational illness if caused by or mainly caused by exposures at the work place,
including business travel. Factors to include to determine reportability as work related include
Medical Removal
If an employee is medically removed under the Company medical surveillance requirements the case
must be reported as an occupational illness. See for criteria Medical Surveillance Guidelines (URL
link to Web).
Noise induced hearing loss should be classified on criteria described in the section below. This is a
deviation from the criteria contained in the SHC Noise Guide (1991) that will be corrected when the
Noise Guide is next updated
If an employee's hearing test (audiogram) reveals that the employee has experienced a work-related
Standard Threshold Shift (STS) in hearing in one or both ears, and the employer's total hearing loss
is 10 decibels (dB) or more in comparison the employee's baseline audiogram (averaged at 2000,
3000, and 4000 Hz) in the same ear as the STS, the case is recordable as occupational illness.
Consult Shell Health Services for additional guidance.
The individual must have sustained an injury or illness before the administration of oxygen, or any
other medical treatment, makes the case recordable.
Example:
If an employee is exposed to chlorine or some other substance at work and oxygen is administered
as a precautionary measure, is the case recordable? If oxygen is administered as a purely
precautionary measure to an employee who does not exhibit any symptoms of an injury or illness,
the case is not recordable. If the employee exposed to a substance exhibits symptoms of an injury or
illness, the administration of oxygen makes the case recordable.
Eye Problems
Example:
An employee goes to a doctor and is informed that she should wear prescription glasses because of
work related eye deterioration caused by the nature of the job. If it can be established that the
disorder was caused or mainly caused by exposures at work this case would be classified as an
occupational illness. However, the company should distinguish work related eye problems from
those due to ageing or hereditary factors unrelated to the job.
Example 1:
An employee with a known knee defect wrenched it whilst climbing down a ladder, when the
bottom rung gave way. This aggravation required medical attention and would therefore be
considered a work related injury.
Example 2:
An employee with a known knee defect, but declared fit for duty, suffered a recurrence of the
disability whilst walking up steps. The incident arose solely out of the employee's pre-existing
deficiency and therefore the resulting disability would not be considered a work related injury.
Example 3:
An employee with a blister unrelated to work knocked the top off the blister in the course of the
employee's work activity. The broken blister became infected and resulted in lost time. This would
be considered a work related injury.
Pre-existing Conditions
An employee's physical or mental defect or pre-existing physical or mental condition does not affect
the classification of a subsequently contracted occupational illness. If in such circumstances an
illness is caused or mainly caused by exposures at work, the company must report it without regard
to the employee's pre-existing physical or mental condition.
Infected Laceration
An infection resulting from a laceration should be classified as a work related injury because the
classification is based on the original event, the laceration, not on the subsequent developments.
Example:
An employee going on a business visit was vaccinated against yellow fever. Some days later the
employee was taken ill and the illness was linked to the vaccination. This would be considered an
occupational illness.
Recurrence of Symptoms
Companies are required to report each new occupational illness when the illness has been
established for the first time. The recurrence of symptoms from a previous case should not be
reported. Deciding whether the emergence of illness symptoms constitutes a new event or the
recurrence of a previous illness may be complex. Generally, each occupational illness should be
reported with a separate entry. However, certain illnesses such as silicosis may have prolonged
effects that recur over time. The recurrence of these symptoms should not be reported as a new
case, unless the occupational illness results in an escalation of severity, e.g. to death or permanent
total disability.
Some occupational illnesses such as certain skin or respiratory conditions may recur as the result of
new exposures to sensitising or other hazardous agents. They should be reported as new cases.
Individual Susceptibility
Example 1
Whilst a crane was lifting a heat exchanger on a crude oil production module, it was dropped onto
an instrument airline that ruptured. Instrument air supply was lost and the module was shutdown
safely without further damage or leakage. It took 6 hours to repair the instrument airline and a
further 6 hours to re-commission the module and re-establish crude oil production.
As the event posed a threat to people in the vicinity and the instrument air loss could have led to
further plant emergencies this event would be considered an (HSE) incident. The asset damage
resulting from this incident was the cost of repairing or replacing the instrument airline. The
consequential business loss was the cost of lost crude oil production. In assessing the cost of lost
production no account should be taken of the possibility of making up the lost production using
spare capacity in the production programme. The cost should be based on the design or
programmed capacity of the module and the downtime.
If the falling heat exchanger had been damaged its repair or replacement cost would be included in
the asset damage. If the repair or replacement of the heat exchanger caused delays in achieving
improved throughput, heat saving or product quality the associated costs would be included in the
consequential business loss.
Example 2
A gasoline process pump was allowed to run dry, the pump vibrated and the bearing failed. The seal
held and there was no leakage of gasoline.
This event resulted in damage to the assets but there was no harm to people, the environment or
company reputation. The event would not be classified as an (HSE) incident. However, it might be
reported as an operational disturbance, a maintenance item or a quality incident.
Atmospheric Emissions
Example 3: Halocarbons
All accidental releases of halocarbons, i.e. CFCs and halon, should be considered as incidents
regardless of size of emission.
If the same spill occurred under conditions of high rainfall and some of the oil was discharged
through the outfall and recovered from the river (controlled water), then the spill clearly had an
environmental impact. If the incident was serious enough to draw the attention of the
environmental authorities and the media, the impact on company reputation should also be taken
into account.
The cost of lost fuel oil and the cost of clearing up and disposing of the oily water are consequential
business loss that should be assessed against the asset damage criteria on the RAM.
Complaints
Non-compliances
Conducting Interviews
Interviews with witnesses should be carried out as soon as possible after the incident, as intervening
time and discussions with others can influence a person’s recollection of events. The value of a
witness's input can be greatly influenced by the style of the interviewer, whose main task is to listen
to the witness's story and not to influence it by making comments or asking leading questions. This
requires patience and understanding. An investigation team is often seen in a prosecuting role, and
witnesses may be reluctant to talk freely if they think they may incriminate themselves or their
colleagues. An investigator is not in a position to give immunity in return for information, but must
try to convince interviewees of the purpose of the investigation and the need for frankness. The
following are some points of good practice when conducting an interview:
Prepare the questions you need answered beforehand;
Avoid interviews by the whole investigation team that may intimidate the witness. The
optimum is two interviewers and a single witness. Also avoid interviews by immediate
supervisors;
Allow the witness to be accompanied by a colleague or friend or a safety representative;
Conduct the interview in private and start off with a general discussion to put the witness at
ease before asking questions about the incident;
Make sure that the witness understands that he or she will not be required to sign a statement;
Ask the witness to go step by step through the events surrounding the incident, describing both
own actions and the actions of others. Do not ask leading questions;
Separate facts from opinions. Ask further questions to confirm the facts, and note the opinions;
Summarise the discussion at the end of the interview to make sure that there is no
misunderstanding. Afterwards, prepare notes of the discussion and agree them with the witness.
Clarify any anomalies and any conflicts with other evidence;
Assess the need for the witness to receive counselling.
Investigators should look for any conditions or factors at the location that could have contributed to
the incident. Factors to check include:
Position of all equipment in relation to other equipment and people;
Position of valves, spades, set points, recorders, override switches, etc.;
Samples of process materials, products of reaction/combustion, drain water etc.;
Process control and safeguarding instrument status. Check that records are retained beyond 24
hours;
Procedures, vehicle tachographs, training records, log books, process logs and test records;
Condition of the load-bearing surface;
Accessibility and evidence of congestion;
Lighting, visibility and audibility at the location;
State of housekeeping;
Condition of all plant, vehicles, equipment and tools;
Effects of weather;
Presence of witnesses;
Evidence of spills or release;
Odours, discoloration, tyre marks;
Presence of unauthorised people;
Evidence of excessive forces;
Presence of warning signs and notices.
Fact Finding
During the initial stages of every investigation, investigators should collect and record all the facts
that may add to the understanding of the incident and the events surrounding it. They should be
aware of the danger of reaching conclusions too early and of failing to keep an open mind to the full
range of possibilities. They should ask the questions who?, what?, when?, where?, why? and how?
about the circumstances of the incident. Here is a checklist of specific questions that should be
answered during the fact-finding process:
What operations were in progress?
What equipment was in use? Had any of the equipment failed?
Where were the key personnel and what were their actions immediately before the incident?
What instructions were given that are related to the incident?
What energy sources and flows were not controlled?
Were there any operational deviations, equipment defects or inappropriate use of resources and
equipment?
Were there any changes of personnel, procedures, processes or equipment that could have
contributed to the incident?
What were the weather conditions?
What action did any third parties take that contributed to the incident?
Were the individuals involved physically fit and competent to perform the job?
Could alcohol or drugs have been a contributory factor? Should tests be done?
Could the effect of fatigue, work cycles and stress be contributory factors?
Could social or domestic pressure have had an impact on an individual’s behaviour?
Could time of day, age of people involved, length of service, training received etc. be
contributory factors?
After a first round of fact finding it should be possible to give a precise description, supported by
the documented facts, of the events leading to the incident, the incident itself and the initial
response to the incident. It should be possible to:
Describe the consequences of the incident in terms of injury, damage and loss, environmental
and reputation impact;
Identify what defences (controls and recovery measures) were in place to prevent the incident;
Identify the substandard acts which breached these defences;
Identify the preconditions which led to the substandard acts;
Identify what additional information and specialist resources are needed to confirm the
immediate causes and to establish the underlying causes (Tripod latent failures);
Comment on response to the incident, including first aid, emergency medical treatment, rescue,
shutdown of the process and fire fighting.
Documentation such as as-built drawings, inspection records, instrument and tachograph records,
printouts, log sheets/books, maintenance records, work permits and load/time sheets may provide
information relevant to the investigation.
Written instructions and procedures may provide evidence of pre-planning and individual
responsibilities. The investigation should try to establish the extent to which these procedures and
instructions were understood and acted upon, as this can indicate the effectiveness of training and
supervision. The relevance and extent of application of procedures should be assessed during the
investigation.
Special Studies
Incidents of a technical or complex nature often require specialist input and further studies to
determine causes of failure. Aircraft crashes, crane failures and plant explosions are examples of
incidents where specialist advice may be required. This should be rapidly identified and the
specialists involved early in the site assessment.
Conflicting Evidence
It is not unusual for witnesses to give differing accounts of an incident. Human memory can be
unreliable and, even if not motivated by self-protection or other subjective arguments; one person's
recollection of an incident can differ from another person's in important details. Investigators should
note any significant differences in accounts of an event. Faced with conflicting witness statements,
investigators should look for the similarities between the statements and commonality with other
evidence. The objective is to use the evidence to understand the incident and not to prove the
accuracy of individual statements, nor to apportion blame.
On-line
P9101 A
Plant Not
manager informed
of problem
Boiler
Reduced
Sequentially Timed Event Plot – Example
feed water
flow flow
This appendix lists the headings and provides guidance on the content of a report of a significant
incident. When the Tripod Beta tool is used to analyse the incident the report can be generated
automatically from the data inputted to the Beta Tool software.
Summary
A brief summary of the report, giving the background of the incident, a description of the incident,
description of injuries, damage and loss, and outlining the causes established and the agreed actions.
Consequences
Details of persons injured, and the injuries in a form understandable to non-medical readers.
Description of the damage and loss, including an estimate of the cost of direct and consequential
losses.
Results of analysis
This section should include the results of the analysis of the findings, identifying the immediate and
underlying causes and weaknesses in the management system. The results are normally presented as
a Tripod tree.
When certain conclusions have not been fully established by the available evidence these should be
highlighted as tentative conclusions.
Action items
This section should include corrective actions for immediate causes (Tripod breached defences) and
improvement actions addressing the underlying causes and management system weaknesses (Tripod
latent failures). Action items should be achievable and measurable, and should specify action parties
and implementation times.
Appendices
Sequence of events.
Tripod tree and GFTs .
Other data needed to supplement the report, including photographs, and drawings.
Transportation of Personnel
Example 1:
An employee on a business trip travelled by taxi from an airport to the hotel where he would stay.
He was injured in a road incident during the taxi journey. The injury is work related.
Example 2:
An employee, who has a company vehicle for unrestricted personal use, was due to attend a business
meeting some distance away on a Monday morning. He decides to leave on the Friday and break the
journey by visiting friends. An incident occurred during the diversion from the normal route. The
resultant injury is not work related.
Example 3:
A ship’s crewmember was travelling ashore by launch for an authorised recreational trip. He was
expected to arrange safe transport. An incident occurred when the launch collided with another ship
and the crewmember was injured. The injury is work related.
When an incident occurs during travel in non company arranged transport and subsequent
investigation shows that company transport should have been provided, for example if incidents
during this activity could create a negative impact on the company, then the incident should be
considered work related.
Example 4:
An employee had to travel from home to the local airport for a weekly shift at a location upcountry.
The roads were known to be dangerous because of frequent armed robberies. If no company
transport was provided then a robbery involving an employee in private transport would be
considered work related.
Note: Example 4 is not work related under OSHA. Other situations involving company supplied
transport are still being clarified. Examples will be added when the information is available.
Injuries and illnesses that occur while an employee is working at home, including work in a home
office, will be considered work-related if the injury or illness occurs while the employee is
performing work for pay or compensation in the home, and the injury or illness is directly related to
the performance of work rather than to the general home environment or setting. For example, if an
employee drops a box of work documents and injures his or her foot, the case is considered work-
related.
If the injury or illness is related to non-work activities or to the general home environment, the case
is not considered workrelated. If an employee is injured because he or she trips on the family dog
while rushing to answer a work phone call, the case is not considered work-related. If an employee
working at home is electrocuted because of faulty home wiring, the injury is not considered work-
related.
If an employee voluntarily takes work home and is injured while working at home, is the case
recordable? No. Injuries and illnesses occurring in the home environment are only considered work-
related if the employee is being paid or compensated for working at home and the injury or illness is
directly related to the performance of the work rather than to the general home environment.
Example 1:
An employee sustained an injury in an offshore gymnasium during off duty time. If management
controls were not breached the injury is not work related. If the injury resulted from a failure of one
of the pieces of equipment it would be work related.
Example 2:
An outbreak of food poisoning occurred in a contractor’s construction workers’ camp. As the
outbreak clearly resulted from a failure in hygiene standards of food provided by the contractor the
illnesses would be occupational.
Example 3:
An employee sustained an injury or illness after checking into a hotel during off duty time. The
incident should be recorded and investigated for learning purposes but is not recordable for
statistical purposes.
Transportation of Product
Example 1:
A road haulier was working under a term contract to deliver product on the company's behalf. The
haulier worked for a number of other companies. An incident occurred during the time the haulier
was delivering product exclusively for the company. The injury should be included in the company
statistics, as should the associated exposure hours and the kilometres driven.
All incidents occurring within company managed locations or alongside company managed
pipelines.
Incidents which occur when company or contractor vehicles, including sub contractor or spot-
hire vehicles, are undertaking the following journeys, whilst subject to company management
control:
To a terminal or depot to load products;
From a terminal or depot to deliver products to a customer;
From a customer to a terminal or depot or to a contractor base or other predefined base,
to complete the journey;
To or from a workshop or garage for vehicle service or maintenance.
Incidents occurring in vehicle parking areas or other off-road situations, e.g. customer premises,
whilst subject to company management control.
Example:
An employee attended a course at a training school and sustained an injury. As the injury occurred
during the training sessions it is a work related injury. Had the injury occurred in the employee's
recreational time, and was not caused by a failure of management controls of the training centre, it
would not be work related.
The injury and the exposure hours should be included in the statistics of the company employing the
injured person. The training centre should investigate and follow up the incident and report the
findings to the employing company.
Illness caused or mainly caused by exposures occurring during the employee's meal period or other
off duty periods are not considered as occupational unless they result from exposures to hazards in
the work area.
Example 1:
An employee suffered food poisoning resulting from food provided by the employer. This case
would be considered an occupational illness.
Example 2:
An employee was sitting in the canteen and eating food that he had brought to work. He suffered
food poisoning. The case would not be considered an occupational illness.
Fitness Centre
Incidents involving employees at company physical fitness centres are not normally work related,
even though the company encourages participation in fitness programs and subsidises the costs of
participation. If participation is required as part of employment, then any resulting incidents are
work related. If an injury results from a failure of one of the pieces of equipment or other
management controls it would be work related.
Company premises include all employer controlled sports fields, tennis courts, golf courses, parks,
swimming pools, gyms, social clubs and other similar recreational facilities which are used by
employees on a voluntary basis primarily during off-work hours. The Company should maintain
management controls appropriate to the facilities, activities and participants. Injuries to employees,
their families or others should be recorded and investigated if they result from failures in the
management controls or to the absence of management controls which should have been in place.
The work related test is to be applied in determining recordability as either an employee or 3rd party
for statistical purposes.
Example 1:
The 3 year old child of an employee drowned in the swimming pool at a Company social club. The
requirement not to leave young children unsupervised had not been specified or applied in this case.
This would be considered a 3rd party work related fatality.
Injuries to employees participating in social events outside company premises are work related if the
events are organised by the company and the injuries result from a failure of management controls.
If injuries result wholly from the actions of the employees, e.g. falling from a bar stool, they are not
considered work related.
Example 1:
An employee on a business trip was mugged after leaving a taxicab on the way to check-in to a
hotel. The injuries sustained are work related.
Example 2:
Two workers had a fight at the worksite. Any injuries sustained are work related.
Horseplay
Example 1:
An employee was showing off by operating a forklift truck that he was not familiar with or
authorised to use. He lost control of the truck and struck a fellow employee. Although the employee
was engaged in a prohibited activity his injury and that of the fellow employee are considered to be
work related.
Appendix 13: Procedure for Reporting and Review of Significant Incidents
Example 1:
An office worker lives in a suburban area and travels to work by public transport. This person's
exposure hours would be the time spent at the office.
Example 2:
An office worker lives in a suburban area and travels to work in transport arranged by the company.
This person's exposure hours would be the time spent at the office. However, an injury occurring to
the employee in transport arranged by the company would be considered a work related injury.
Example 3:
An employee travels on company business but in own time outside normal working hours. This
person's exposure hours would be calculated on the basis of the normal working week.
Example 4:
An employee is working scheduled and recorded overtime. This person's exposure hours would
include all overtime periods. Any unrecorded overtime would be excluded.
Example 5:
An office employee is working unscheduled extra hours. Whilst in theory such working time should
be treated as in Example 4, it is generally not justified to keep records of such working time for
safety performance reporting. Hence, this person's exposure hours would be calculated on the basis
of the normal working week.
Example 6:
A company employee or contractor works on an oilrig or supply boat. Only the on duty hours are
included in the calculation of exposure hours.
Example 7:
A company or contractor organizational unit is not able to provide the actual exposure hours for a
month by the time required. Estimated exposure hours can be used. An acceptable method is to
report March, April and May exposure hours as Quarter 2 etc. A correction can be applied (if
available) before the final annual exposure hours are submitted.
Note:
On company owned or time charter tankers exposure hours are calculated on the basis of 24 hours
per day, rather than the usual hours on duty. This is in-line with maritime industry practice.