Incident reporting contract requirements

Incident Investigation. Employers are required to investigate as soon as possible (but no later than 48 hours after) incidents that did result or could reasonably have resulted in catastrophic releases of covered chemicals. The standard calls for an investigation team, including at least one person knowledgeable in the process involved (a contract employee when the incident involved contract work) and others with knowledge and experience to investigate and analyze the incident, and to develop a written report on the incident. Reports must be retained for five years. 

The regulation states The report must be reviewed with all affected personnel whose job tasks are relevant to the incident findings, including contract employees where applicable. The aim of this clause is to ensure that all affected employees understand why the incident occurred and what actions could prevent a recurrence. While the regulation does not specifically define the methods to comply with this requirement, it is imperative that the review is prompt and complete. In almost all cases, the review requires personal meetings, either individually or in small groups, to thoroughly review the incident and recommend corrective actions. 

Because accidents must be reported to supervisors immediately, all laboratories must post a list of emergency telephone numbers. Although generic accident report forms are available (Fig. 19.2), it is recommended that the winery develop its own forms to document accidents as well as those used by supervisors conducting accident investigations. Required information includes names and telephone numbers of the injured and witnesses, the date, time, and location of the incident, a description of the incident, the involved department(s), and the contract person and telephone number. 

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