incident management procedure - aecom safeguard€¦ · incident management procedure...

© AECOM RestrictedIncident Management Procedure (S3[APAC]-004-PR1)Revision 0 May 8, 2018PRINTED COPIES ARE UNCONTROLLED. CONTROLLED COPY IS AVAILABLE ON COMPANY INTRANET. 1/15

APAC

Incident Management Procedure S3[APAC]-004-PR1

1. Purpose and Scope

a. The purpose of this procedure is to establish requirements for timely reporting, notification, and investigation of SH&E incidents. The procedure applies to all AECOM APAC based employees and operations.

2. Procedure

2.1 Roles and Responsibilities

a. The following sections outline the roles and responsibilities of different workplace parties with relation to incident reporting, notification and investigation within the AECOM APAC region.

2.1.1 Employee

a. In an emergency/life-threatening situation, use the appropriate local emergency phone numbers and seek immediate support from local first responder’s e.g. ambulance for medical care, police for security related events etc.

b. Immediately notify his/her Supervisor that an incident (including a Near Miss) has occurred, the circumstances involved, the nature and extent of the injuries/illness, and whether medical treatment may be required.

c. Except for emergency situations, affected employees should discuss their injury/illness status with their Supervisor and SH&E Manager, and/or project SH&E professional prior to obtaining medical treatment. Note in some locations in APAC employees are not required to notify AECOM before seeking treatment but employees should be notified of this requirement during induction so they understand AECOM requires notification so we can ensure they receive the appropriate level of support.

d. Do not discuss the incident with members of the news media or legal representatives (except AECOM Legal Counsel or your personal legal advisor) unless directed to do so by AECOM management. Refer to Appendix 2 - Incident Reporting Notification Flowchart.

e. Do not make statements pertaining to guilt, fault, or liability.

f. Complete online reporting (e.g., IndustrySafe,) within 24 hours of the event occurring.

2.1.2 Project Manager/Supervisor

a. In an emergency/life-threatening situation, use the appropriate local emergency phone numbers and seek immediate medical care for the employee.

b. Address any immediate corrective actions required to make the scene safe. Consult with the local SH&E Manager and management if guidance is required.

c. The Incident Reporting Notification Flowchart in Appendix 2 outlines the notifications which must occur in the event of an incident. It is mandatory for these notifications to occur.

d. If an incident occurs on a client-controlled site, management will ensure that appropriate client notifications are made within the required time frames as per contract. These notification requirements will be documented in project-specific planning documents. IndustrySafe does not automatically perform this function; the Project Manager must provide this to the client.

e. Drug and alcohol testing shall be performed in accordance with the business group drug and alcohol (substance abuse) testing program, or in the absence of one, in-line with client and project requirements.


f. Complete an initial incident notification using IndustrySafe if employee is not capable/incapacitated and any other applicable documentation and attach to the on-line report such as:

i. Police Report

ii. Photographs of incident scene

iii. Witness statements

iv. Regulator specific forms based on the relevant jurisdictional (country and/or state) requirements e.g. requirements set by the SafeWork, Department of Labour, WorkSafe or Environmental Agencies

v. Timeline of events

vi. Incident investigation developed in line with section 2.4 of this procedure.

g. Based on the severity of the event initiate investigation in line with the requirements set out in section 2.4.1 of this procedure.

h. Where there is potential for criminal, civil or regulatory action against AECOM or any of its employees or sub-contractors refer to critical incident response in section 2.4.12

2.2 SH&E Manager

a. Upon receipt of an incident report, either verbally or through IndustrySafe, ensure the following:

i. Persons involved have received that appropriate level of care

ii. Regional Corporate Counsel is consulted to determine if incident follow up requires professional privilege to be applied (severity 3 incidents). Note some regions automatically notify Regional Corporate Counsel of all recordable incidents.

iii. Where appropriate, the Regional SH&E Director is consulted to determine if critical incident response protocols in section 2.4.12 are to implemented based on the magnitude of the incident (higher impact/disruption severity 3 incidents)

b. Ensure that incidents logged in to the IndustrySafe system are reviewed for accuracy and completeness. Consideration is to be given to the classification of the incident and the severity risk rating provided.

c. Refer to Appendix 2 - Incident Reporting Notification Flowchart around notification requirements. If required, notify regulatory agencies of the incident and complete any external reporting requirements.

d. Perform an incident investigation in line with section 2.4 of this procedure.

e. Ensure electronic entry of incident information into IndustrySafe and coach Supervisors and Employees on completing investigations.

f. Ensure the IndustrySafe notification is circulated to the relevant parties (e.g. Project Manager, Group Director etc.). See Appendix 2 - Incident Reporting Notification Flowchart

g. Enter corrective actions as a result of incident investigation into IndustrySafe and monitor to completion.

h. Ensure incidents are closed in a timely manner.

2.3 Incident Reporting and Notification

2.3.1 Incident Notification – Internal

a. As outlined in Appendix 2 - Incident Reporting Notification Flowchart, all incidents including recordable injuries, first aids, property damage, security, environmental release and High Potential Near Misses, the AECOM Employee / Supervisor must notify the AECOM Project Manager immediately.

b. Verbal notification techniques may include sending emails, text or voices messages as long as receipt of the notification is acknowledged.


c. If verbal notification is not acknowledged, voice-to-voice contact must be continued until it is. If line management or a member of the project team can’t be contacted.

d. Following internal AECOM notifications Supervisors/ Project Managers are to ensure that clients are notified in accordance with their reporting requirements and after available facts / information to aid in the preliminary classification has been obtained.

e. The Supervisor/Project Manager is responsible for ensuring incidents are reported using IndustrySafe within:

i. In the case of a fatality, travel security breach, or missing person, immediately, and

ii. In the case of all other incidents within 24 hours

f. If employees do not have access to the internal IndustrySafe system, reports can be submitted using the following methods:

i. A hardcopy Incident Notification Form submitted to the Regional SH&E Manager via email who will input into IndustrySafe as appropriate.

ii. All staff can access the public web form (https://www.industrysafe.com/aecom/incidents/)

iii. For ANZ based staff - A public form submitted through the web based Safety for Life App (available at (https://anzgeo.com/safetyforlife/)

2.3.2 Incident Notification - Regulatory Agencies / Insurers

a. Safety Regulators

i. Local jurisdictional legislative requirements for notification of incident are highlighted in the Regional Health and Safety Management Plans.

ii. Timeframes for notification to the regulator are defined in Appendix 2 - Incident Reporting Notification Flowchart

b. Insurers

i. The Regions Workers Compensation Insurer must be notified by the Regional SH&E Manager, or where relevant the HR department, in each of the following cases:

· All Recordable Injuries;

· Journey Claims, if accepted by the insurer within the jurisdiction to which the injury relates

· ‘Report Only’ cases that have the potential to be compensable in future, for jurisdictions that allow early reporting of claims that haven’t yet required treatment.

ii. The timeframes for notification of a claim or potential claim to the insurer is outlined in the Regional Health and Safety Management Plans. As a guide a maximum of five days is seen as best practice.

2.3.3 Incident Notification – Emergency Services / Local Authorities

a. The staff member phoning the emergency services will then become the point of contact / liaison officer between the emergency services and the injured worker.

2.4 Incident Investigation

2.4.1 General Requirements

a. When determining whether an Incident or Near Miss should be investigated, please refer to the table below:

b. N.B. The table below sets out the minimum requirements that should be carried out for particular types of incidents. Investigations can be initiated by a Country or Region to a stricter standard where required (e.g. with consideration of the potential consequence within the AECOM standardised risk matrix).

https://www.industrysafe.com/aecom/incidents/

https://anzgeo.com/safetyforlife/%05Q%03


Severity LevelSafety & Health Environment

PropertyDamage

Public Image/Reputation Near MissActual Potential

1 LOWFirst Aid Injury only(treated locally/on-site).

Small chemicalrelease containedonsite

</+$1K USD IndividualComplaint

Could haveresulted in anyActual orPotentialSeverity Level1.

2 MEDIUM Medical Treatment Release below thereportable limit

$1K - $10KUSD

Community orlocal attention


3 HIGHLost/Restricted work

Long term injury/illnessPermanent Impairment

Fatality, Multiple MajorIncidentsRegulatory reportableincident

Release at/abovenotifiable limit

Onsite impactrequiring remediation

Offsite impactrequiring remediation

>$10K USD

StructuralCollapse

Ownerintervention

Mediaintervention

Governmentintervention


c. Following the investigation review teleconference call the Asia President and APAC COO and Business Line / Regional Managing Directors, under the direction of APAC AECOM Legal, shall issue a final Investigation Report to members of the AECOM Global Executive Management Team

d. Corrective actions identified by the investigation process must be formally tracked to closure by the relevant Regional SH&E Director.

2.4.2 Severity Level 1

For incidents classified as severity 1, or generating a risk score of low on the IndustrySafe system, an incident investigation should be considered and should be:a. Managed at site (office or project) by work group,

b. Consider involving AECOM SH&E personnel or subject matter experts for consultation, and

c. Completed within the incident investigation tab of the IndustrySafe system

2.4.3 Severity Level 2

For incidents classified as severity 2, or generating a risk score of medium on the IndustrySafe system, an incident investigation is recommended and should be:a. Managed at site (office or project) by work group,

b. Consider involving AECOM site and country level SH&E personnel or subject matter experts for consultation, and

c. Completed using PART A and PART C (minimum) of Incident Investigation Report, with findings and corrective actions recorded in the IndustrySafe system.

2.4.4 Severity Level 3 (including high potential incidents)

For incidents classified as severity 3, or generating a risk score of high on the IndustrySafe system, an incident investigation is a mandatory requirement and should be:


a. Managed by the region’s SH&E team.

b. Regional SH&E Manager to contact the Corporate Counsel to discuss need to establish legal privilege on all actual or potential severity 3 incidents. Note some regions automatically notify Regional Corporate Counsel of all recordable incidents.

c. For severity 3 incidents of significant magnitude (based on severity or likelihood to cause disruption to the business), the Regional SH&E Manager is to contact the Regional SH&E Director to determine if critical incident protocols are to be implemented (section 2.4.12).

d. All communications regarding severity 3 incidents must strictly adhere to the requirements set within the communication protocol set out in Appendix 3 - Internal Communication Protocol regarding Severity Level 3 Incidents

e. Completed using PART A, PART B and PART C of Incident Investigation Report with findings and corrective actions recorded in the IndustrySafe system.

f. An Executive Incident Review must be prepared by the local SH&E Manager and operations and presented to the Global Safety Lead and regional executives,

g. An investigation review teleconference call must be held for any Fatality or Serious SH&E Incidents. The purpose of the call will be to review the preliminary investigation report,

h. The investigation review conference call will be arranged by the APAC President and APAC COO

i. Required participants for the call will include:

· The Regional Chief Executive / Regional COO, Executive and Business Line / Regional Managing Directors (as appropriate);

· Regional/APAC AECOM Legal where there is possible litigation issues against AECOM;

· Responsible Supervisor or Project Manager of the injured/involved employee;

· Regional SH&E Director.

· Chief Safety Officer

ii. Other participants may include, at the discretion of the Asia President and APAC COO:

· APAC/Regional HR Representative(s);

· Relevant subject matter experts; or

· Members of AECOM Enterprise Management Team.

2.4.5 Training for Persons Conducting Incident Investigations

a. All persons conducting incident investigations categorised as severity 2 or 3 (see section 2.4.1) are to be suitably trained and competent in incident investigation/root cause analysis.

b. Training for conducting incident investigations is to be a certified external training course or a sufficient internally developed training course approved by the Regional SH&E Director or their delegate.

2.4.6 Conducting the Investigation

Section 1 of the Incident Investigation Report contains guidance on conducting an investigation using section 2 of the Incident Investigation Report. The guidance on how to conduct an investigation is based on the Incident, Cause, Analysis, Method (ICAM).The following actions and considerations should also be adopted when investigating an incident.a. Following an incident, immediately determine the sources of evidence. Evidence may include a listing of people,

equipment, and materials involved; a recording of environmental factors such as weather, illumination, temperature, noise, ventilation; and physical factors such as fatigue and medical conditions.

b. The investigation process will include interviews with those involved or those directly witnessing the event.


i. When interviewing any employees in relation to a Severity Level 3 incident, all employees must be given the option of having their local SH&E representative present at the time of the interview.

ii. Any employee statements (witness or involved) gathered during an interview in relation to an incident investigation is to be made by the employee without interference from any other person. The statement is to be made on the Incident Statement Form and signed by the employee.

iii. Consideration must be given to the circumstances of the interviewed employee’s involvement during all incident investigations.

iv. The AECOM Employee Assistance Program’s independent service provider should be discussed with the interviewee and methods of access through Human Resources or via the AECOM Intranet.

c. The investigation team lead should ensure that investigation tools are available (e.g., cameras, protective equipment, tape measures, marking devices, etc.).

d. Store evidence (e.g., witness statements, photographs, documentation, etc.) that is collected during the investigation in a secured folder and/or locked location.

e. If photos are taken, a photo log should be created as the photos are taken during the investigation.

f. Release of the investigation report outside of AECOM may only be authorised by the Regional SH&E Director (or designee).

2.4.7 Producing the Investigation Report

a. As above in section 2.4.1, the Incident Investigation Report should be used to record and complete for any severity 2 or 3 incident investigation.

b. Investigation reports will:

i. Identify the critical factors involved in the incident

ii. Develop direct and contributing causes to identify the root cause(s) of the incident.

iii. Evaluate causes associated with human activities, physical causes, and systems causes

iv. Identify corrective actions, and assign a responsible party and due dates.

2.4.8 Executive Incident Reviews

a. Executive Incident Reviews will be conducted in accordance with Safety, Health & Environment Management System Manual (S2-001-SM1) & Tier II Global Requirements.

2.4.9 APAC Recordability Review Process

a. For any Recordable Injury the Regional SH&E Managers will engage with the APAC SH&E Director to ensure the correct classification is provided, including capturing of lost time.

b. Where it is unclear if the incident is recordable under the U.S. OSHA definition, the Vice President, Corporate SH&E, Management Solutions and Chief Safety Officer will be consulted on incident investigation findings to confirm rulings on Recordability classifications. Additional parties e.g. Occupational Health professionals may also be consulted as needed.

2.4.10 Corrective actions

a. Following the completion of the incident investigation and development of corrective actions, it is critical that the requirements for preventing a recurrence of the event be implemented prior to re-starting the activity

b. Safety corrective actions must be documented on the Incident Investigation Report and then also must be entered into IndustrySafe as a corrective action linked with the incident. Actions will have an assigned party responsible for close out by a specified completion date.


2.4.11 Key Business Learning’s

a. Where appropriate key learning’s from the incident investigation should be translated into a ‘Lessons Learnt’ document for the business to use.

b. Any key learning’s from the incident investigation are communicated back to the affected staff in a timely manner. Approval to circulate outside of AECOM should be sought from the Regional SH&E Manager.

c. The Regional SH&E Director has the discretion to request a ‘Lessons Learnt’ as needed.

2.4.12 Critical Incident Response

a. Upon escalation of an incident to a critical status, the Regional SH&E Manager will assist to bring together a Critical Incident Response team, consisting of relevant senior leaders, to manage the situation. Note this requirement should also be outlined in Regional Resilience Plans in consideration of Disruptive Events and Incidents and various response teams briefed on the requirements of this plan and their role.

b. Members of the Critical Incident Response Team for a region should consist of the following AECOM representatives:

i. Chief Executive/ COO/and Regional Executive and Business Line/Group Directors

ii. Regional External Affairs Director- will manage media relations on behalf of AECOM

iii. Regional Human Resources Director

iv. Regional SH&E Director

v. Regional Corporate Counsel

vi. Any other regional support as required (i.e. IT, Communications, Property etc.)

vii. APAC or Global executive support as is required.

c. The Critical Incident Response Team will manage the incident response until the conclusion of the incident, or until the incident is deemed to have been adequately controlled.

d. The Critical Incident Response Team will ensure that an appropriate incident debrief and review takes place, and that support (counselling, EAP) is provided to those who may have been impacted by the incident.

e. Notification of Next of Kin (NOK) for fatalities is the responsibility of the Police and the Critical Incident Response Team. The Project Manager should ensure that the Police and Critical Incident Response Team are provided with the details of the persons NOK information.

3. Terms and Definitions

See Appendix 1 – Terms and Definitions

4. References

a. OHSAS 18001: Occupational Health and Safety Management Specifications

b. Safety, Health & Environment Management System Manual S2-001-SM1

c. Local relevant regulations e.g. safety regulator incident reporting requirements

5. Records

Below is a list of the official records that are generated and support this procedure:

a. Incident Notification Form S3[APAC]-004-FM3

b. Incident Statement Form S3[APAC]-004-FM2

c. Incident Investigation Report S3[APAC]-004-FM1


d. Lessons Learnt Template S3[APAC]-004-FM4

6. Appendices

a. Appendix 1 - Terms and Definitions

b. Appendix 2 - Incident Reporting Notification Flowchart

c. Appendix 3 - Internal Communication Protocol regarding Severity Level 3 Incidents

7. Change Log

List the change history pertaining to this document including if it was identified differently throughout its life-cycle:

Rev # Change Date Description of Change Location of Change

0 May 8, 2018 Initial Release All


Appendix 1 Terms and Definitions: Adapted from OHSAS 18001

a. Critical Incident

Any ‘High Potential’ event that has resulted in actual significant harm or fatality or any otherevent or situation that creates significant risk of trauma to the physical or mental health,safety or wellbeing of any person or major environmental damage, including but not limitedto missing person(s), suicide attempt, hostage situation, bomb threat, major structuraldamage, natural disaster, highly contagious or deadly disease epidemic, large scalepollution event or environmental degradation with irreversible impacts.

b. Environmental Incident An unexpected sudden occurrence, including a major emission, fire or explosion leading toserious danger to the public or potentially serious pollution of or detriment to theenvironment, whether immediate or delayed. Examples of an environmental incidentinclude (but not limited to):· Release / emission· Gas· Liquid· Solid· Waste· Damage / harm to· Soil· Waterways· Flora· Fauna

c. Fatality Loss of life of any AECOM employee, AECOM subcontractor personnel, client personnel ormember of the general public where AECOM is in control of site or directly involved with theactivities that led to the fatality. Where unsure of relationship ensure incident is reportedanyway to ensure visibility of incident with AECOM management.

d. First Aid A minor occupational injury (work related), which after one time first aid treatment andsubsequent observation allows the worker to return to normal duties on the same day or atthe start of the next scheduled shift. Initial treatment may be provided by a:· Person with formal first aid qualifications;

Or work performed by one of the following people that is not beyond normal first aidtreatment or solely for diagnostic purposes:· Qualified nurse; or· Health Extension Officer/ Paramedic or equivalent.· Some examples of treatments for first aid injuries are:· Cleaning, flushing or soaking wounds on the surface of the skin;· Using hot or cold therapy;· Using wound coverings such as bandages, band aids, gauze pads, etc. or

using butterfly bandages or steristrips (other wound closing devices such assutures, a staple etc. is considered medical treatment);

· Using any non-rigid means of support such as elastic bandages, wraps,non-rigid back belts (devices such as rigid stays or other systems designedto immobilise parts of the body are considered medical treatment);

· Using temporary immobilisation devices while transporting an accidentvictim. Splints, slings, neck collars, backboards, etc.;

· Drilling of a fingernail or toenail to relieve pressure, or draining fluid from ablister;

· Using eye patches;· Removing foreign bodies from the eye using only irrigation or cotton swab;· Removing splinters or foreign materials from areas other than the eye by

irrigation, tweezers, cotton swabs or other simple means;· Using finger guards;


· Using massages (physical therapy or chiropractic treatment are consideredmedical treatment);

· Drinking fluids for the relief of heat stress;· Having a doctor prescribe medication for a work related injury on a one-time

basis as a precautionary measure which does not require a follow up visit tothe doctor (e.g. one time prescription for pain relief);

· Using non-prescription medication at non-prescription strength.

e. High Potential Any incident having the potential to be a ‘Fatality’ or ‘Serious Injury’ if the circumstances hadbeen slightly different must be counted as ‘High Potential’; all others must be counted as‘Low Potential’.

f. Incident Classification/Categorisation

For the purpose of reporting and analysis, SH&E Incidents within the AECOM system mustbe classified as one of the following:· Environmental· First Aid· Near Miss· Non-work (not related to work)· Property Damage· Recordable Injury (medical treatment beyond first aid)· Report only (injury / illness with potential future compensation claim)· Security

g. Incident Notification Form(S3APAC-004-FM1)

Form used to document incidents which shall be completed when there is no internetaccess to the on-line incident management system (e.g., IndustrySafe). Incident NotificationForms shall be completed within 24 hours of any incident, or immediately in the case of anincident involving a fatality, travel security, or missing person.

h. IndustrySafe AECOM’s Online Incident Management System

i. Journey Claim Journey claims are those claims arising out of travel for work purposes that are deemedcompensable under the relevant jurisdictional legislation. Journey claims will be determinedby the Regional SH&E Manager in consultation with the relevant jurisdictional insurer ifrequired. For more information please refer to local Health and Safety Management Plans.

j. Lost Time Days (LTD) Number of full days where workers are absent from work because of LTI. Count only thedays the employee would have worked.If a single injury involved both days away from work and days of restricted work activity,stop counting the days of modified work activity or days away from work once the total ofeither or the combination of both reaches 180 days.

k. Lost Time Injury/Illness Any occupational injury which results in at least one full day absent from work beyond theday or shift it occurred (does not include time travelling off site for injury diagnosis). Adoctor’s certificate must be provided.

l. Medically Treated Injury (MTI) Any occupational (work related) injury requiring medical intervention by a doctor (orequivalent) on or off site that allows the worker to return to normal duties on the same dayor at the start of the next scheduled shift.If an employee is sent to a doctor as a precaution and the doctor determines the injury fitsany of the following descriptions, the injury does not count as a ‘Medically Treated Injury’(MTI):· No treatment was required;· The visit to a doctor or health care professional was solely for observation or

counselling;· The procedures provided by the doctor were diagnostic procedures only,

including administering· prescription medications that are used solely for diagnostic purposes;· The treatment required by the doctor can be described as first aid treatment

as listed in above classification· for first aid; and


· The doctor determines the injury was not work related.An injury must not be counted as both an MTI and ‘Lost Time Injury’ (LTI). If an MTIbecomes an LTI, it is removed from the MTI category. The same is true if an MTI becomesa ‘Modified Work Injury’ (MWI) – it is only counted as an MWI.

m. Modified Work Days (MWD) Is the number of days where workers abstain from their regular duties and perform somealternate duties because of an MWI. Count only the days the employee would havenormally worked.If a single injury involved both days away from work and days of restricted work activity,stop counting the days of modified work activity or days away from work once the total ofeither or the combination of both reaches 180 days.

n. Modified Work Injury (MWI) orRestricted Work Case

Any occupational (work related) injury requiring the worker to abstain from his/her regularduties (may be reactive or proactive) as assigned by a doctor, nurse, physiotherapist,supervisor, or equivalent. The employee is still capable of going to work and performingsome other value adding duties.A person with a first aid injury as per the above definition assigned alternate duties as aprecaution, is not counted as an MWI as long as the alternate duties are for less than five(5) consecutive work days or seven (7) calendar days.

o. Near Miss An incident that has the potential to cause harm but resulted in no injury, loss or damage(e.g. slip/trip on office stairs that resulted in no injury or equipment starting in work area thatshould have been locked out, etc.).

p. Non-Work Related Injury Non-work related injuries or illnesses are those that are deemed to have occurred outside ofthe course of employment. Non-work related injuries and illnesses will be determined by theRegional SH&E Manager in consultation with the relevant jurisdictional insurer if required.For more information please refer to local Health and Safety Management Plans.

q. Notifiable Incidents Any incident that requires notification to the Regulators in the particular jurisdiction wherethe incident occurs. Local Safety, Health, and Environment Management Plans outline theoverarching legislative framework that establishes what a notifiable incident for that locationis.

r. Recordable Injury/Illness A work-related injury or illness that results in the following.· Fatality;· Medical treatment beyond first aid;· Days away from work;· Restricted work or transfer to another job;· Loss of consciousness; and/or· A significant injury or illness as diagnosed by a physician or licensed health

care professional.

s. SH&E Incidents The following events or situations as applied to AECOM employees and/or AECOM-controlled operations are considered SH&E Incidents:· Any injury or illness to an AECOM employee or subcontractor, even if it

does not require medical attention. This would include work-relatedinjuries/illnesses that have become significantly aggravated by the workenvironment.

· An injury to a member of the public, or clients, occurring on an AECOM-controlled work site.

· Re-occurring conditions such as back pain or cumulative trauma disorders(e.g., carpal tunnel syndrome).

· Fire, explosion, or flash that is not an intended result of a planned event(e.g., remediation process, laboratory procedure).

· Any incident involving company-owned, rented, or leased vehicles (includingpersonal vehicles used for company business).

· Any failure to comply with the requirements of a regulatory permit issued toAECOM.


· Any notice of violation or notice of non-compliance received from aregulatory authority.

· Property damage resulting from any AECOM or subcontractor activity.· Unexpected release or imminent release of a hazardous material.· Confirmed or suspected chemical or biological exposure.· A safety-related complaint from the public regarding AECOM activities.· SH&E-related incidents that could result in adverse public media interest

concerning AECOM or an AECOM project.· Any inspection by a safety, health, & environmental enforcement agency.

t. Security Incident Any security related incident that could cause harm to or is associated with an AECOMemployee in the course of duty. Refer to Global Security and Resiliency Group resources onEcosystem for additional information.

u. Serious SH&E Incident Any SH&E incident that meets the criteria set out in section 2.3.1 of this procedure for aSeverity 3 (actual) or High Risk (potential) incident. These types of incident included, but arenot limited to, the following:· Fatality;· Any amputation· Hospitalisation for treatment.· Absence from work for more than 30 calendar days due to work-related

injury/illness.· Any single event resulting in more than one employee requiring medical

treatment.· Any SH&E-related consent agreement/order/lawsuit or enforcement action

seeking more than $10,000 or alleging criminal activity.· Any spill or release of a hazardous material that is reportable to a

government agency.· Any Notice of Violation resulting from failure to operate within the

requirements of a government permit or consent.· Near-miss incidents that, in the opinion of the Regional / Business Line

Manager, Regional SH&E Manager, Regional Managing Director, SH&EManager may have otherwise resulted in any of the above.


Appendix 2 Incident Reporting Notification Flowchart – ANZ Example


Incident Reporting Notification Flowchart – SEA Example


Appendix 3 Internal Communication Protocol Regarding Severity Level 3 Incidents

a. It is important that communication within AECOM be carefully managed following a Severity Level 3 incident.

b. It is preferable for any initial communications (i.e. communication which occurs within the first hour of an incident occurring) from AECOM employees, or contractor or subcontractor personnel to be conducted by telephone, until such time as an AECOM staff member is appointed as central point of contact to avoid confusion and unnecessary documentation. If you witness a serious incident, you should contact your Project Manager or Direct Supervisor by telephone immediately. The direct supervisor is to then notify the Regional SH&E Manager or if not available the Regional SH&E Director.

c. In some cases, it will be appropriate for a Severity Level 3 incident response and investigation to be carried out under legal professional privilege. This will occur where AECOM contemplates actual or anticipated legal proceedings arising from an incident and is seeking legal advice on its position. Where an investigation is conducted under legal professional privilege, it is important to ensure that all communication is also copied to AECOM internal and/or external legal and is marked "Confidential and subject to legal professional privilege".

d. Before creating any written documentation relating to a Severity Level 3 incident, AECOM employees should contact the AECOM Project Manager or Direct Supervisor to ascertain how communication should be handled in relation to that particular incident.

e. AECOM employees should be aware that all written communication (including emails) and documents created as a result of the incident can be obtained by government agencies and used to form part of an investigation into the incident. For this reason, AECOM employees should always record factual information only and resist speculation as to the cause of an incident in any documentation.

f. Interacting with Agency representatives

i. When interacting with a representative of a government agency in your capacity as an AECOM employee, you are representing AECOM. The expectation is that you will be co-operative and polite at all times.

ii. Generally AECOM will be required to promptly comply with requests made by government agencies.

iii. If you are visited by such a representative, such as local government agency inspector, or receive a request for information or documents, whether in relation to a workplace incident, or as part of a routine visit, you should:

§ Make contact with the relevant Regional SH&E Manager or internal legal as soon as possible for guidance in complying with the request;

§ Avoid speaking to inspectors over the phone (all communications should be in writing where practicable);

§ Do not give answers which make assumptions, or are based on guesswork or hearsay; and

§ Stick to the facts – do not give your personal opinion or any information based on anything other than factual information.

g. If you are asked to participate in an interview with a government agency or Environmental Protection agency, you will have certain rights, which vary from State to State. Generally, you will have the right to legal advice before attending such an interview. If you receive a request for an interview (whether formal, or informal), you must immediately notify the relevant Regional SH&E Manager/Regional SH & E Director.

h. General powers of Regulatory agencies

i. Regulatory Inspectors (i.e. local Safety and Health Agencies Environmental Agencies) and investigators have broad powers to carry out their functions. Despite these powers, you should follow the above guidelines at all times, particularly before providing any agency with AECOM documentation.

ii. For more information please contact Regional Legal Counsel.

incident management procedure - aecom safeguard€¦ · incident management procedure...

Documents