EPC Procedure for Incident Reporting
EPC Procedure for Incident Reporting
CT-EPC/017/SH/EPM/RPC-X/2023
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Date: Date: 2024.10.25 Date: 2024.10.25
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2024.10.23
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CONTENTS
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This procedure applies to CONTRACTOR’s personnel, to all SUBCONTRACTORS and their lower-
tier SUBCONTRACTORS, and their respective employees, or VISITORS entering the Project site. It
applies to all site activities and all Project areas, including lay-down areas and temporary
construction facilities.
This document covers the reporting requirements and the principles of accident investigation and
analysis that apply to the project during all the execution phases.
The purpose of this procedure is to control the basic elements required to maintain an
Accident/Incident and Near Miss investigation and reporting system and the implementation of the
relevant corrective action taken.
2 REFERENCES
Project References:
For the purposes of this Procedure, the following definitions/abbreviations shall apply:
3.1 DEFINITIONS
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Near Miss (NM) An unplanned on uncontrolled event or chain of events that has not
resulted in recordable injury or physical damage or environmental
damage but had the potential to do so in other circumstances.
Occupational Illness Any abnormal condition or disorder, or any Fatality other than one
resulting from an occupational injury, caused by exposure to
environmental factors associated with employment. Occupational
illness may be caused by inhalation, absorption, ingestion of, or direct
contact with the hazard, as well as exposure to physical and
psychological hazards. It will generally result from prolonged or
repeated exposure.
Occupational Injury Any injury such as a cut, fracture, sprain, amputation, etc., or any
Fatality, which results from a work-related activity or from an exposure
involving a single incident in the work environment, such as deafness
from explosion, one-time chemical exposure, back disorder from a
slip/trip, insect, or snake bite.
Physician A Physician or Other Licensed Health Care Professional is an
individual whose legally permitted scope of practice (i.e., license,
registration, or certification) allows him or her to independently
perform, or be delegated the responsibility to perform, the activities
described by this regulation.
Recordable A type of event, incident, injury, release, or other outcome which has
been determined to meet or exceed definitions, criteria or thresholds
for inclusion and classification in reported data.
Regular Job A Regular Job is one, which has not been established to
accommodate an injured employee. It should be an existing job or task
within the OWNER or CONTRACTOR’s organization, which the
injured person is deemed competent to perform.
Reputation The estimation in which persons or organizations are held; character;
good name.
Restricted Work Day Case Any work-related injury other than a Fatality or LWDC which results in
(RWDC) a person being unfit for full performance of the regular job on any day
after the occupational injury. Work performed might be:
• an assignment to a temporary job
• part-time work at the regular job
• working full-time in the regular job but not performing all the usual
duties of the job.
Where no meaningful restricted work is being performed, the incident
should be recorded as a Lost Workday Case (LWDC).
Risk Risk represents the probability that an undesirable event will occur,
combined with consideration given to the severity of the RISK
CLASSIFICATION - Risk classification is a rating system used to
represent the relative risk associated with a particular hazard. For the
Project, the risk rating system shall be as described in the procedure.
Third Party A person or organization with no business relation with the OWNER or
CONTRACTOR.
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Total Recordable Incidents The sum of Fatalities, Lost Workday Cases, Restricted Workday
(TRI) Cases and Medical Treatment Cases.
Total Recordable Incidents Is calculated by multiplying the number of TRI by 200.000 work hours
Rate (TRIR) according to OSHA, or per 1.000.000 work hours according to IOGP,
and then dividing that number by the number of labor hours at the
company.
Work-Related An injury must be considered work-related if an event or exposure in
the work environment caused or contributed to the resulting condition
or significantly aggravated a pre-existing injury. Work-relatedness is
presumed for injuries resulting from events or exposures occurring in
the work environment unless one of the following exceptions applies in
its entirety:
• Occurs when an employee or contractor is present in the work
environment as a member of the public. In case of a fatality, it will be
included in the third party statistics.
• Results solely from voluntary participation in a wellness program or in
a medical, fitness, or recreational activity, such as blood donation,
physical examination, flu vaccination, exercise class, racquetball, or
baseball etc. Where the activity is company-sponsored the
participation must be perceived by the employee as voluntary for this
exception to apply.
• Involves signs or symptoms that surface at work but result solely from
a non-work-related event or exposure.
• Is solely the result of eating, drinking, or preparing food or drink for
personal consumption (whether bought on the employer’s premises or
brought in): for example, if the employee is injured by choking on a
sandwich while in the employer’s establishment, the case would not be
considered work-related. Note: If the employee is made ill by ingesting
food contaminated by workplace contaminants (such as lead), or gets
food poisoning from food supplied by the employer, the case would be
considered work-related
• Is solely the result of doing personal tasks in the work environment
outside of the employee’s assigned working hours.
• Is solely the result of personal grooming, self-medication for a non-
work-related condition or is intentionally self-inflicted.
• Is the common cold or flu (Note: contagious diseases such as
tuberculosis, brucellosis, hepatitis A, or plague are considered work-
related if the employee is infected at work), and
• Occurs during a commute from the home to the normal place of work
or first stop unless the commute uses company-mandated transport.
3.2 ABBREVIATIONS
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CONTRACTOR/SUBCONTRACTOR Supervisor
It shall be the responsibility of all CONTRACTOR’s and SUBCONTRACTOR’s Supervisors to ensure
that all employees adhere to the requirements of this Procedure.
Employees
Employees must practice safe work habits and comply with the requirements of this procedure.
Furthermore they shall:
• Report to their Supervisors of any equipment defects or malfunctioning that may affect the
safe operation of the equipment.
• Advise their immediate Supervisor whenever unsure of the instructions received or where
concerned about the safety status of any task.
• Report straight to their immediate Supervisor all unsafe acts or conditions, near miss and
incidents occurred or seen.
5 INSTRUCTIONS
5.1 GENERAL
The commitment to careful reporting and investigation of accidents / incidents involving injury,
property damage, and production interruption is a major factor in accident prevention.
The incident investigation process provides the accurate, timely information needed to prevent
recurrences.
An “Incident Investigation Team” shall be formed to investigate.
The incident reporting policy of CONTRACTOR and that applies to the Project requires that:
• Every Incident is reported (see definition of an Incident)
• Incidents are reported promptly
• Key data are provided (injuries, persons involved, circumstances, outcomes, consequences,
HSE Management System failures)
• Incidents are investigated appropriately
• Lessons learned from the incidents are disseminated within the organization and the Project
• Recommendations resulting from investigations are under action.
In the event of serious incidents the “Emergency Response Team” (ERT) will be mobilized to assist
in rescue activities, firefighting etc.
For incidents with minor consequences the potential severity can still be very high.
Investigation of those cases may reveal as much about the deficiencies in HSE Management as
cases in which major injury resulted.
Isolated events, incidents with minor consequences and minor potential severity may provide little
learning, but the collection and analysis of data from many such incidents show trends, which may be
used to identify measures for improvement in the overall HSE performances.
When assessing the potential Severity of an incident use will be made of the IPM technique, in which
two parameters are combined:
• Potential injury or health effect / asset damage / environmental effect / reputation impact
(Consequences).
• Level of exposure / frequency of occurrence (Likelihood).
The investigation effort in terms of team composition and depth of investigation will be based on
actual and potential Severity.
All incidents will be classified according to the IPM Classification Table reported below for an easy
reference.
The potential consequences of incident will be assessed in respect to “People” (Injury), “Assets”
(Damage), “Environmental” (Effect) and “Reputation” (Impact).
The classification will be represented with the association of letters and numbers; for a complete
definition of the Consequences terms please refer to the “Appendix 2” of this procedure.
(e.g.: classification A1 for People means: Consequences = Slight health effect / injury; Likelihood =
Never heard of in industries)
The classification will be reported in the relevant section of the “Part 1” of the “Incident Notification
Form” “Appendix 1” of this procedure.
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Event or exposure
resulting in injury or
illness
(See note 1)
Note 1: Contagious diseases such as tuberculosis, brucellosis, hepatitis A, or plague are considered
work related if the employee is infected at work.
Note 2: Travel statuses are work-related if the employee is engaged in work activities “in the interest
of the employer”. Travels between the employee’s residence or temporary residence and the job
location are considered NOT work-related.
Injuries or illnesses caused by a motor vehicle accident and occurs on an OWNER parking lot or
OWNER access road, while the employees is commuting to or from work, are considered NOT work-
related.
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If a case ….
A death An illness
An injury which involves
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Note that not only the events clearly “work related” according to CONTRACTOR criteria shall be
reported to CONTRACTOR/OWNER, but also any other relevant event occurred for instance during
transportation from and to the site, during recreation activities outside the working hours, etc.
The Doctor/Nurse responsible for the emergency and first aid unit shall also inform immediately the
CONTRACTOR Site HSE Department in case of any emergency call received. To do so an adequate
fast and continuous communication channel shall be established (Phone, Mobile Phone) in between
the infirmary-first aid unit and the CONTRACTOR Site Organization.
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• For accidents resulting in a fatality or the hospitalization of one or more employees injured in
the same incident, for major Injuries or health effects to personnel (CONTRACTOR, OWNER,
SUBCONTRACTORS, others) participating the Project, including third parties if affected by
activities managed by CONTRACTOR (Major Injuries/health effects means that the injury can
potentially lead to an LTI or to a fatality or to a permanent disability, practically only First aid
cases and Medical Treatment cases are not included);
• Extensive or Major assets damage (even if the event does not produce injuries);
• Environmental Incidents that generate severe environmental damage and that could lead to a
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If the person(s) injured is directly hired by CONTRACTOR, the PD/PM and/or CONST functions shall
notify immediately HR.
In addition, in case of accidents resulting in a fatality or the hospitalization of one or more employees
injured in the same incident with a suspended prognosis, the PD/PM or CONST shall notify the
CONTRACTOR Managing Director immediately.
Injuries requiring a Doctor's care, recordable injuries (other than LTI and Fatalities) and restricted
work day(s) shall be reported to the Construction HSE Head of Department (COHSE) and CONST
(by phone or mobile phone, SMS) within four (4) hours of occurrence and a Preliminary
Incident/Near-Miss
Notification Form must be sent within 24 hours.
Other incidents involving property damage, incidents involving the public, fires and/or near-misses
will be reported to Home Office Construction HSE - Head of Department (COHSE) and CONST
within 24 hours of occurrence using a Preliminary Incident/Near-Miss Notification Form.
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life-threatening injuries or illnesses) and will submit a short, written report by end of the current work
shift.
If the incident involves a fire or fatality, CONTRACTOR will notify OWNER and Local Police to
determine which entity will investigate and control the scene. No person shall disrupt the fire scene
without police permission.
5.4.1 Reporting
All Incident Reports shall be notified in writing using the “Incident Notification Form” (refer to
Appendix 1 of this procedure) with supplementary information attached as necessary.
The Incident Notification Form - Part 1 (refer to Appendix 1) is sufficient for reporting minor or Near
Miss incidents, or accidents which have an agreed IPM classification in the categories A1, B1, C1,
D1 and E1 (refer to Picture 1: IPM Classification Table or Risk Assessment Matrix – RAM); for such
incidents a further full Incident Report will not be required (Part 2 and 3 are not required).
Uncompleted Action Points which result from immediate (that day) investigation, those may be
recorded in the narrative section of Part 1 for follow-up.
The Supervisor writing the Report, or the investigation team leader, must agree with the investigation
team on the initial IPM Classification.
Reports should be completed in the most convenient language (English or local language) for the
organization writing it and doing the immediate review; reports will be translated as necessary by the
on-going investigation process.
All Incidents Reports shall be reviewed with the HSM prior to issuance.
The HSM or his designee will return the “Incident Notification Form - Part 1” to the sender with the
Incident Report serial number added and confirmation of, or comment on, the IPM ranking and any
further report requirement. The HSM will request a work injury status report if appropriate.
Following final completion and release of the Form, where appropriate, the HSM will request a more
detailed investigation of the event be carried out. Part 2 and 3 of the Incident Notification Form might
be required.
Full details of events and the conclusions of the Investigation Team shall be included in the Incident
Notification Form with attachments as necessary.
Reporting will be in line with OWNER and CONTRACTOR corporate requirements.
5.4.2 Incidents requiring further Investigation
The Incident Notification Form - Part 2 and 3 (refer to Appendix 1) are required for reporting High
Potential Near Miss, Incidents or Accidents which have an agreed IPM classification falling in other
categories different than those cited in previous subsection.
For such events a complete Incident Report will be required (Part 1, Part 2 and 3) with all required
supplementary information or documentation attached.
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• Presence of witnesses
• Evidence of spills or release
• Odorous, discoloration
• Presence of unauthorized people
• Evidence of excessive forces
• Presence/absence of warning signs/notices
• Results of inspections
5.7.7 Preserving Physical Evidence
In many incidents components or equipment may be damaged, or have failed. In these cases, it is
best to lodge this equipment in a secure place pending more detailed analysis.
5.7.8 Conducting Interviews
People should be interviewed individually and be asked to go step-by-step through the events
surrounding the incident, describing both their own actions and the actions of others.
The value of a witness’ statement 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 him/her by making comments or
asking leading questions. This requires patience and understanding. If the investigation is a team
effort, great care should be taken not to make a witness feel intimidated by too many interviewers.
Experience has shown that a pair of interviewers can effectively conduct interviews and if
appropriate, the witness could be accompanied by an independent “friend”.
It should be remembered that an investigation team is often seen in a prosecuting role, and there
may be a reluctance to talk freely if people think they may incriminate themselves or their colleagues.
An investigator is not in a position to give immunity in return for evidence, but must try to convince
interviewees of the purpose of the investigation and the need for frankness.
At the end of an interview the discussion should be summarized - to make sure that no
misunderstandings exist. A written record should be made of the interview and this should be
discussed with the witness to clarify any anomalies. Any anomalies in the statement or conflicts with
other evidence should be clarified.
5.7.9 Records and Procedures
Documentation such as “as-built” drawings, inspection records, printouts, log-sheets or log-books,
maintenance records, work permits and time sheets may provide information relevant to the
investigation.
Written instructions and procedures 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 these can indicate the effectiveness of training and supervision. The
relevance and extent of application of procedures should be assessed during the investigation.
5.7.10 Conducting Special Studies
Incidents of an involved or complex nature often require the analysis of specialists to determine
causes of failure. Crane failures and explosions are examples of such incidents, where specialist
advice may be required. This should be rapidly identified and the specialists are involved early in the
site assessment.
5.7.11 Conflicting Evidence
It is not unusual for different witnesses to give different 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’s in quite important details. Investigators
should note any significant differences in accounts of an event. Faced with conflicting witnesses’
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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.
5.7.12 Identifying Missing Information
As the investigation progresses, the investigator(s) should begin to identify the sequence of events
and concentrate efforts on increasing their knowledge of areas of uncertainty.
5.7.13 Underlying Causes and Human Factors
As the extent of physical factors involved in an incident becomes clear, the investigator(s) should
shift the emphasis of their investigation and questioning to the underlying causes and to the reasons
for peoples’ actions. This will allow for ease of assessment when analyzing the incident.
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taken effect.
The quality of incident investigation and the effectiveness of the solutions implemented shall be
verified on a routine basis.
6 APPENDIXES
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PART 1
Complete for ALL incidents. Fax or E-mail to _____________ within 12 hrs.
Asset Near
Security Other
Injury* damage Environment Social/Reputation Miss
What and how incident/accident occurred: (Give any relevant personnel, injury and treatment details)
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Reporter Supervisor
Date Date
Name (Print) Name (Print)
Signed Signed
Slight Slight
Slight Slight
1 Injury Damage< 1S 1S 1S 1S 1S
Leak Impact
(First Aid) $500
Minor Minor
Injury Damage Minor Limited
2 2S 2S 2S 2D 2D
(MTC or $500- Leak/Spill Impact
RWC) $5,000
Major Localized
Injury Damage Localized Considerable
3 2S 2S 2D 2D 2M
(LTI) $5,000 - Leak/Spill Impact
$50,000
Disabled Major
Major
(PPD or Damage Major
4 National 2WS 2WD 2WD 2WM 2WM
PTD) $50,000 - Leak/Spill
Impact
$1m
Extensive Major
Fatality(s) Massive
5 Damage International 2WD 2WD 2WM 2WM 2WM
Leak/Spill
>$1m Impact
Use the highest assessment (nearest to the lower right-hand corner of the matrix) and report and investigate to the levels as
follows:
1 Only Part 1 report needed
2 Part 2 (& maybe Part 3) needed
W Probably needs additional Incident details beyond report form
S Investigation by Section Head
D Investigation by Department Head
M Investigation by Manager
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Company Name
Investigation
Insert team leader in position 1.
1 2 3
Investigation Team
4 5 6
Incident/Accident Analysis
Immediate Cause
1.
2.
3.
4.
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1.
2.
3.
Team Leader:
Name:
Position:
Signed:
Date:
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ACCIDENT AND INCIDENTS DE LINEAR-ALKYL-BENZENE – 4439-LH-PC-000000012
PROCEDURE LAB SHEET ISSUE
SKIKDA – ALGERIE
26 / 28 0
Harm to People
No. Description
Slight injury or health effects (including first aid case and medical treatment case
1
and Occupational Illness) - Not affecting work performance or causing disability
Minor injury or health effects (Lost Time Injury) - Affecting work performance, such
as restriction to activities (Restricted Work Case or Occupational Illness) or a need to
2
take a few days to fully recover (Lost Workday Case). Minor health effects, which are
reversible, e.g. skin irritation, food poisoning.
This document is Tecnimont’s S.p.A. property, and cannot be used by others for any purpose, without prior written consent
TCM IDENTIFICATION CODE
REPORTING AND INVESTIGATION OF REALISATION EN EPC D’ UNE
INSTALLATION DE PRODUCTION
ACCIDENT AND INCIDENTS DE LINEAR-ALKYL-BENZENE – 4439-LH-PC-000000012
PROCEDURE LAB SHEET ISSUE
SKIKDA – ALGERIE
27 / 28 0
0 Zero damage
The figures in the tables above should not be combined for deriving the value of a human life!!
K
Environmental Effect
No. Description
1 Slight effect - Slight environmental damage, within the fence and within systems.
Negligible financial consequences.
3 Localized effect - Limited discharges affecting the neighborhood and damaging the
environment. Repeated breaches of statutory or prescribed limit, or many complaints.
This document is Tecnimont’s S.p.A. property, and cannot be used by others for any purpose, without prior written consent
TCM IDENTIFICATION CODE
REPORTING AND INVESTIGATION OF REALISATION EN EPC D’ UNE
INSTALLATION DE PRODUCTION
ACCIDENT AND INCIDENTS DE LINEAR-ALKYL-BENZENE – 4439-LH-PC-000000012
PROCEDURE LAB SHEET ISSUE
SKIKDA – ALGERIE
28 / 28 0
Impact on Reputation
No. Description
1 Slight impact - Public awareness may exist, but there is no public concern.
2 Minor impact - Some local public concern. Some local media and/or local political
attention with potentially adverse aspects for company operations.
4 National impact - National public concern. Extensive adverse attention in the national
media. Effect on Regional / national policies with potentially restrictive measures
and/or impact on grant of licenses. Mobilization of action groups.
This document is Tecnimont’s S.p.A. property, and cannot be used by others for any purpose, without prior written consent