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INCIDENT CLASSIFICATION,
INVESTIGATION AND
REPORTING
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.
February 2002
HEALTH, SAFETY AND ENVIRONMENT ADVISERS PANEL
1. MANAGEMENT SUMMARY 1
1.1 Purpose and Scope 1
1.2 Group Standards 2
2 Classification of Incidents 3
2.1 Work Related Activities 3
2.2 Injuries 4
2.3 Illnesses 4
2.4 Incidents Resulting in Asset Damage, Environmental Impact and/or Impact on
Company Reputation 4
2.5 Near Misses 5
2.6 Potential Incidents 5
2.7 High Risk Incidents 5
3 Investigation of Incidents 6
3.1 Responsibilities and Competence 6
3.2 Extent of Investigation 6
3.3 Investigation Process 6
3.4 Establishing the Sequence of Events 7
3.5 Analysis of Underlying Causes and Weaknesses in Management System 7
3.6 Incident Report and Follow up 8
3.7 Communication of Lessons Learned 9
4 Reporting of Incidents 10
4.1 Reporting Company 10
4.2 Reporting of Significant Incidents 11
1 MANAGEMENT SUMMARY
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 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 a Tripod analysis. 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 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 3.7) they shall report the findings and
learning to the business.
2 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.
Work related activities are defined as those activities for which management controls are
in place, or should have been in place. Incidents occurring during such activities must
be reported and will be included in performance statistics.
For consistency in the reporting practices of Group companies, the following activities
are considered to be work related, 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.
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.
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.
2.2 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 as described
in 2.4.
2.3 Illnesses
Occupational illnesses are not classified into severity classes, in the way that injuries are
classified into LWC, RWC, MTC and FAC. All identified occupational illnesses are
included in total reportable occupational illness data. The key performance indicator for
occupational illness is Total Reportable Occupational Illness Frequency (TROIF).
Near misses are incidents that under slightly different circumstances could have caused
illness, injury or damage to assets, the environment or company reputation, but did not
(incident has occurred).
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).
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.
High Risk Incidents (HRIs) are incidents for which the combination of potential
consequences and probability are assessed to be in the high risk (red shaded) area of the
RAM. HRIs can be incidents that result in injuries, illnesses or damage to assets, the
environment or company reputation, or they can be near misses.
HRIs should be thoroughly investigated and the lessons learned applied to prevent future
significant incidents. See also section 3.7.
3 INVESTIGATION OF INCIDENTS
The investigation should be carried out as soon as possible after an incident. The quality
of evidence will deteriorate rapidly with time, therefore delayed investigations are
usually not as conclusive as those performed promptly.
Documenting the sequence of events is a crucial step that provides the starting point for
analysis of underlying causes. A number of techniques are available to help visualise the
sequence of events.
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 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.
The purpose of this analysis is to establish the underlying causes of the incident, so that
actions can be taken to prevent recurrence, and also to understand the failures and
weaknesses in management systems that led to the incident. Although this analysis is a
separate activity from investigation of the incident, it is recommended to carry out the
investigation and analysis concurrently, so that they can support and build on each other.
Many methods are available for analysing the underlying causes of incidents, but some
of these do not recognise the concepts of latent (management) failures. The method
recommended in the Shell Group for analysis of HSE incidents is the Tripod
methodology. Shell businesses and business units apply two variations of Tripod.
Details of this method are available from Shell Global Solutions, OGCH/1.
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 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 the investigation of significant or high risk incidents reveals a significant learning
potential the lessons learned should be communicated within the business unit, and
where applicable, to the business. An incident is considered to have significant learning
potential when all the following criteria are met:
• The required controls are not standard industry practice or the incident involved a
combination of factors that are not commonly recognised;
• There has not been a previous communication in the past 3 years on the same
subject;
• The learning is widely applicable in the business or across industry.
Similarly, the business HSE adviser should decide if the lessons learned have value to
other Group businesses, and to industry in general. The learning should be
communicated through news forums, newsletters, cross industry working parties etc.
Additionally, when business HSE advisers receive the initial notification of a significant
incident, within 24 hours, they should consider the need to communicate the facts
known so far to the other business units in the same business and to other Group
businesses.
4 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. STASCO is only
operationally responsible for the STASCO managed fleet. The other fleets that are
included in the shipping sector, whilst reporting to STASCO, 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.
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.
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.
All work related third party fatalities resulting from assault, sabotage and theft should be
included in the statistics.
Non-accidental Death
Non-accidental deaths involving company or contractor employees shall be notified to
the business within 24 hours, 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;
• Identify work related causes or contributing factors that may provide the grounds for
corrective action and improvement;
• Establish whether management systems were in place to ensure that fitness of
personnel was in line with requirements for the people’s job.
This also applies to non-accidental deaths outside normal working hours where there is
reason to suspect a relationship between the death and events or exposures at work.
Examples:
Work related:
• Evidence that an individual has been exposed to high levels of a toxic chemical
during the course of his work;
• The individual had recently undergone major heart surgery and was not fit for work;
• The individual committed suicide and subsequent investigation showed that his
depression was mainly caused by work related stress factors.
Non-work related:
• Investigation has shown that an individual, who was previously found medically fit
for his duties, has died from the consequences of a heart attack.
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.
Business
One of the global Shell businesses, i.e. Exploration and Production, Oil Products, Gas
and Power, Chemicals, Renewables.
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.
The intention is to estimate the order of magnitude of the loss so that the incident can be
assessed on the RAM and the appropriate resources put into investigation. It should not
be necessary to conduct a detailed accounting of the full range of indirect costs.
Consequential business loss should be estimated on a 100% equity basis.
When consequential business loss results from an incident with impact on the
environment or company reputation, the consequences should be assessed under both
asset damage and the environmental/reputation categories of the RAM and the highest
rating used to determine the extent of investigation and follow up.
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 paid overtime and training but
excluding leave, sickness and unpaid 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 are included in statistics if
they are the result of failure or absence of management controls. (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.
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.
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.
Injury
Any injury such as a cut, fracture, sprain, amputation etc. that results from a single
instantaneous exposure.
This definition is different from the OSHA definition, which considers restricted work as
a lost workday case.
A single incident can give rise to several lost workday cases, depending on the number
of people injured as a result of that incident.
In the case of a fatality or permanent total disability no lost workdays are recorded.
Medical treatment does not include first aid even if a physician or registered professional
personnel provide this. (Refer to guidance 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 work related abnormal condition or disorder, other than one resulting from an injury
that is caused by or mainly caused by exposures at work. (50% or more probability that
the illness 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. (Refer to guidance and examples in
Appendix 4).
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).
When restricted workdays follow a period of lost workdays, the restricted workdays are
recorded in addition to the lost workdays, but the injury is recorded as a lost workday
case only.
A vehicle is defined as a car, van, light vehicle, heavy goods vehicle, road tanker, bus,
motorcycle or any unit under tow, e.g. trailers, caravans, mobile generators.
Significant Incidents
Incidents with actual consequences to the company that rate 4 or 5 on the RAM.
Third Parties
Persons or organisations that are not employed by or contracted to a company or
contractor.
Incident occurs
N Actual loss? Y
Work N
Near miss Related? Not reportable
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?
Lost
Y N
Workdays?
Y
Y Restricted N
work?
N Consequence
4 or 5? Y Medical N
treatment?
Y
Y
TROI LWC RWC MTC FAC
• Negative X-ray diagnosis or laboratory analysis, unless they lead to further treatment;
• Observation of injury during a visit to medical personnel;
• Administration of tetanus shots or boosters. These shots are often given in
conjunction with more serious injuries, therefore, injuries requiring these shots may
be included in the statistics for other reasons.
The material safety data sheets for those substances suspected of causing employee
illnesses should be checked to verify the relationship between the exposure and the
resulting symptoms.
A medical condition involving the musculo-skeletal system may be a work related injury,
an occupational illness, or a non-work related injury or illness.
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.
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.
3. Conditions occurring spontaneously at work without provocation from an external
force or work activity, e.g.:
• An employee turns his or her head to answer a question or gets up from a chair
and experiences sudden pain onset;
• An employee kneels to tie his or her shoelaces and experiences back pain;
• An employee coughs and complains that his or her back has “gone”.
• These events would not be considered as work related.
RSI is a medical syndrome caused by repetitive movements affecting the neck, upper
back, shoulders, upper and lower arm, elbow, wrist or hand, or a combination of these
areas. It is considered to be RSI if the effects are restrictive or lead to participation
problems.
Burns
Contact with heat, 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.
First degree burns are classified as first aid cases. Second degree burns are normally
classified as medical treatment cases. Third degree burns are always classified as medical
treatment cases.
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 reportable 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. Consequently, the kind of treatment given by the
doctor (none in this case) is immaterial, since all occupational illnesses are reportable.
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.
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 reportable 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.
Food Poisoning
Food poisoning cases arising from food furnished by the employer on the employer’s
premises should be reported as occupational illnesses. This is an exception to the general
rule that single incidents are considered as injuries.
Noise induced hearing loss should be classified solely on the criteria contained in the
SHC Noise Guide (1991).
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
Infected Laceration
The classification of a disorder resulting from medical treatment depends upon whether
the treatment was for work related purposes.
Recurrence of Symptoms
Companies are required to report each new occupational illness. 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
This category also includes benign tumours; eye conditions due to dust and toxic agents;
other (non-malignant) diseases of blood and blood-forming organs.
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
Although the assessment revealed that there were unlikely to be off-site complaints, there
was a potential safety problem on-site, therefore the incident should be considered as a
near miss and investigated.
As hydrogen sulphide went offsite in concentrations above the odour threshold, and
resulted in complaints, this should be considered as an incident with environmental and
reputation impact.
Example 3: Halocarbons
All accidental releases of halocarbons, i.e. CFCs and halon, should be considered as
incidents regardless of size of emission.
When a spill is not contained within the site or within the process system it should be
considered as an incident having environmental impact.
As the spill was contained within the site, and did not pose a risk to groundwater
systems because it was contained within impervious drainage channels, it was not
considered an incident with environmental impact. However, it should be reported as a
near miss and investigated to prevent recurrence.
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.
This was clearly an incident with environmental impact. The fact that the Authorities
were involved, and the incident attracted local media attention, means that it should also
be considered as an incident with reputation impact. The incident should be classified
and reported on basis of the highest RAM rating.
Complaints
Non-compliances
Although it was spotted before it went in to the landfill this incident should be
considered as a minor breach of statutory criteria, and therefore as an incident. As there
had been previous non-compliances on that landfill location which had come to the
attention of the local press, the impact on reputation should also be taken into account.
This was a clear non-compliance with the permit conditions and should be reported as
an incident.
The consequences of reputation incidents should be assessed using the RAM taking into
account the specific local circumstances and sensitivities.
Further examples of incidents inside and outside Shell that damaged the company’s
reputation can be found in the Group crisis management web-site at:
http://sww.shell.com/crisismanagement/.
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.
Important facts and data can be gained from observations made at the scene of the
incident, particularly if the location is kept undisturbed until the preliminary
investigation has taken place. Rescue operations or the presence of residual hazards may
necessitate moving some of the equipment, but this should be kept to a minimum.
Before disturbing the incident location photographs and/or video film should be taken.
Sketches can be used to document the physical relationship and distance between
people, tools and equipment. All relevant equipment, tools, clothing, PPE and other
material evidence should be identified and labelled. If critical equipment or tools have
been damaged or have failed they should be kept in a secure place pending more
detailed analysis.
Local legislation may prescribe that for certain classes of incident, e.g. fatality or motor
vehicle accident, nothing may be moved without prior permission from the relevant
authorities.
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.
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 such 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.
P9101 A On-line
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41
Appendix 11: Incident Report Layout for a
Significant Incident
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
a) Work Related
• Personnel travelling on company business using public or private transport from their
normal place of residence or regular place of work to a temporary place of work;
• Personnel travelling in company owned or arranged transport;
• Personnel travelling from temporary accommodation, e.g. base camp or hotel, to a
place of work.
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.
When an employee is travelling on company business the total period away from regular
place of work, including normal life activities, e.g. in a hotel and travelling by taxi to a
meeting, are considered to be part of employment. Any injury or illness occurring during
the business trip is considered to be work related.
In case of illnesses that materialise during business travel the normal criterion for
occupational illness should be applied, i.e. was the illness caused by or mainly caused
by exposures in the workplace?
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.
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:
• 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 are considered
to be work related if they result from failures in the management controls or to the
absence of management controls which should have been in place.
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.
Injuries from “acts of God” such as being struck by lightning while at work are
considered work related.
Incidents occurring during the course of employment that are due to someone’s wilful
act are reportable, whether or not they occur on company premises.
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.
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 paid overtime. This person’s exposure hours
would include all overtime periods. Any unpaid 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.
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.