Table of Contents - AGL

1

HSE Incident, Near Miss and Hazard Management Procedure 2 AGL-HSE-PRO-012.1 Uncontrolled when Printed Version 6.0

Table of Contents

Table of Contents 2 1. Introduction 4 2. Scope 4 3. Accountabilities and Responsibilities 4

3.1 General Manager, Group HSE & Security 4 3.2 Head of Function 4 3.3 Head of Safety/Head of Environment, Health, Audit and Training 4 3.4 HSE Contractor Manager 4 3.5 Environment Manager 5 3.6 Health Safety and Environment Manager, Audit, Compliance and Training 5 3.7 Health and Safety or Environment Business Partner 5 3.8 Leader 5 3.9 Employees / Contractors 6

4. Event Types 6 4.1 Health and Safety Event Types 6 4.2 Environment Event Types 7 4.3 Regulatory Event Types 7

5. Incident, Near Miss & Hazard Management Process 8 5.1 Immediate Response 8 5.2 Leader Notification 9 5.3 Classification 9 5.4 HSE Event/Initial Brief 10 5.5 Immediate Notification Report 10 5.6 Notification Escalation Process 11 5.7 myHSE Recording 14

6. Investigations 15 6.1 General Requirements 15 6.2 Investigation Types 16 6.3 Low to Moderate Risk Investigations 16 6.4 High to Extreme Risk Investigations (High Potential Events) or Environment Regulatory Reportable 17 6.5 Investigation Reporting and Verification Process 17 6.6 Contractor Investigations 18

7. Management of Regulatory Issues 18 7.1 Notification 18 7.2 myHSE Recording 19

8. Training and Competency 19 9. Improvement Actions 19 10. Lessons Learnt and Hazard Alerts 20


11. Fatalities 20 12. Environment Related Community Complaints 21 13. Crisis Management Plan 21 14. Definitions 22 15. Referenced Documents 28 Appendix 1 – Reporting of HSE Events in myHSE 29 Appendix 2 – Hierarchy of Risk Control 30


1. Introduction This procedure provides information on how to achieve the minimum standards to ensure HSE incidents, near misses, hazards and regulatory issues are identified, reported and investigated in a consistent and effective manner at AGL.

2. Scope This procedure covers the requirements associated with the reporting, notification, risk classification and investigation of all HSE incidents, near misses and hazards.

The scope of this procedure applies to all AGL employees and contractors, contractor employees (and their sub-contractors) engaged by AGL to perform work. Refer to Appendix 1 for further guidance on the application of this procedure.

Work undertaken by offshore contractors is excluded from the scope of this procedure.

Australian Standard 1885.1 1990 (as amended) – Workplace Injury and Disease Recording Standard, forms the in principle requirements of this procedure for safety Events.

3. Accountabilities and Responsibilities 3.1 General Manager, Group HSE & Security

The General Manager, Group HSE & Security is responsible for:

• Ensuring processes are implemented to facilitate the capture and management of HSE hazards, near misses and incidents in accordance with this procedure; and

• Ensuring all escalations are completed in accordance with this procedure.

3.2 Head of Function

The Head of Function (Business Unit or General Manager) is responsible for:

• Ensuring adequate resources are available to implement this procedure; • Ensuring Leaders are aware of their roles and responsibilities in accordance with this procedure; • Nominating the Lead Investigator for all High Potential investigations; • Leading and encouraging the proactive reporting of all HSE hazards, near misses and incidents; and • Ensuring appropriate communications are developed as required and distributed within required

timeframes.

3.3 Head of Safety/Head of Environment, Health, Audit and Training

The Head of Safety/Head of Environment, Health, Audit and Training is responsible for:

• Leading and encouraging the proactive reporting of all HSE hazards, near misses and incidents; • Managing the development, implementation and maintenance of this procedure; and • Ensuring appropriate consultation in the development, review and approval of this procedure.

3.4 HSE Contractor Manager

The HSE Contractor Manager is responsible for:

• Leading and encouraging the proactive reporting of all contractor related HSE hazards, near misses and incidents within our supply chain;


• Evaluating and analysing investigation processes and outcome of investigations for all contractor related High to Extreme rated health, safety and environment hazards, near misses and incidents (High Potentials); and

• Reviewing the implementation of all improvement actions resulting from all contractor related High to Extreme rated health, safety and environment hazards, near misses and incidents (High Potentials) to ensure the identified improvement actions adequately address the root causes identified by the incident investigation.

3.5 Environment Manager

The Environment Manager is responsible for:

• Leading and encouraging the proactive reporting of all HSE hazards, near misses and incidents; • Assisting Business Unit Leaders with the management of environment hazards, near misses and incidents

in accordance with this procedure; and • Notifying the Head of Environment, Health, Audit and Training of High to Extreme rated environment

hazards, near misses and incidents (High Potential), within specified timeframes.

3.6 Health Safety and Environment Manager, Audit, Compliance and Training

The Health Safety and Environment Manager, Audit, Compliance and Training is responsible for:

• Maintaining a central register of ICAM trained investigators; and • Facilitating ICAM training in accordance with the AGL HSE Training Procedure

3.7 Health and Safety or Environment Business Partner

The Health and Safety or Environment Business Partner is responsible for:

• Leading and encouraging the proactive reporting of all HSE hazards, near misses and incidents; • Assisting the responsible Leader with the management of health and safety hazards, near misses and

incidents in accordance with this procedure; • Supporting the Head of Function to develop and distribute appropriate communications within required

timeframes; • Ensuring the Head of Safety or Head of Environment, Health, Audit and Training is notified for High to

Extreme rated health and safety incidents (High Potential), within specified timeframes; • Providing onsite support and assistance in relation to myHSE; • Participating in investigations, when required; • Assisting the Head of Function determine the number of trained Incident Cause Analysis Method (ICAM)

Investigators required on site; • Supporting the maintenance of a centrally administered register of trained ICAM Investigators; • Ensuring ICAM Investigators maintain minimum training requirements as per this procedure; • Where required, liaising with the applicable Root Cause Analysis (RCA) Co-Ordinator; and • Ensuring that effective improvement actions are identified and implemented for health, safety and

environment hazards, near misses and incidents to adequately address the root causes identified by the incident investigation.

3.8 Leader

Leaders are responsible for:

• Ensuring AGL personnel and Contractors under their leadership are aware of their roles and responsibilities in accordance with this procedure;

• Leading and encouraging the proactive reporting of all HSE hazards, near misses and incidents; • Verifying and carrying out the risk classification of a hazard, near miss or incident; • Developing HSE incident reports within specific timeframes;


• Establishing if a hazard, near miss or incident requires notification to regulatory authority(ies) in conjunction with the relevant Health and Safety or Environment Business Partner; and

• Notifying the relevant Health and Safety or Environment Business Partner and/or Head of Function of any High to Extreme rated Hazard, Near Miss or Incident (High Potential), within specified timeframes.

3.9 Employees / Contractors

Employees and Contractors are responsible for:

• Reporting all incidents, near misses and hazards to their Leader/AGL Contact immediately; • Entering information into myHSE or providing suitable information to AGL in the case of Contractors who

don’t have access to myHSE; and • Participating in investigations, when required.

Note: Only Contractors with an “A number” can enter incidents into myHSE.

4. Event Types For the purpose of this procedure, all HSE incidents, near misses or hazards are referred to as Events.

The three overarching Event Types associated with this procedure are as follows:

• Health and Safety; • Environment; or • Regulatory.

4.1 Health and Safety Event Types

Type Class Definition

Incident (INC)

Health and Safety

An Event that resulted in the injury or illness of a person requiring Lost Time, Medical Treatment, First Aid or Non-Treatment.

If the Event also resulted in motor vehicle damage, a permit breach, fire and/or property damage, these attributes would be classified as sub-categories to the Incident.

Near Miss (NM)

Health and Safety

An unplanned Event or error that did not result in injury, illness but had the potential to do so.

If the Event resulted in motor vehicle damage, a permit breach, fire and/or property damage, these attributes would be classified as sub-categories to the Near Miss.

Hazard (HZ)

Health and Safety

An observation or workplace situation or source that has the potential to harm the health and safety of people or damage fixed/mobile plant and equipment if not controlled.


4.2 Environment Event Types


Incident (INC)

Environment

An Event that resulted in:

• An uncontrolled or unauthorised discharge; • Unauthorised environmental impact or damage, or potential damage

(e.g. a spill to ground or a spill outside of a bunded area); • A breach of an environmental legal obligation or licence condition; or • A verified environment-related community complaint.

Near Miss (NM)

Environment An Event where no actual regulatory breach or unauthorised environmental impact occurred but there was potential for a regulatory breach or unauthorised environmental impact to occur, i.e. the event was a close call and could result in an incident in the future unless improvement actions are implemented.

Hazard (HZ)

Environment An observation, task, process or equipment that has the potential to be a source of future environmental harm if not controlled.

4.3 Regulatory Event Types


Regulatory Visit Regulatory A visit, arranged or un-announced, by a Regulatory Authority.

Improvement / Prohibition Notice

Regulatory Improvement notices – Written directions requiring a person to fix an issue within a specified time. The inspector will include information on the notice about what must be done to comply with the law. The person who receives the notice is responsible for achieving compliance with legislation or dealing with the immediate risk.

Prohibition notices – Written directions prohibiting any activity that will, or is likely to, involve an immediate risk to the health and safety of any individual or the environment. If a prohibition notice has been issued, the prohibited activity cannot recommence until an inspector certifies in writing that the risk has been remedied.

Infringement/ Fine or Prosecution

Regulatory An infringement, fine or prosecution that has been handed to AGL by a Regulatory Authority in relation to an Event.


5. Incident, Near Miss & Hazard Management Process The HSE Incident, Near Miss and Hazard management process comprises the following key steps:

5.1 Immediate Response

Following an Event, immediate actions must be taken by personnel at the scene of the Event (e.g. first aid, firefighting, spill containment) only if safe and practicable to do so.

This may include:

• Ceasing the operations or tasks directly related to the Event; • Providing first aid to injured persons (only by a suitably trained and competent person); • Contacting Emergency Services if required; and • Taking steps, if safe to do so, to make safe and preserve scene.

If the Event poses an imminent threat to people and/or the environment:

• All injured or potentially affected personnel should be removed from the area (if possible and safe to do so);

• The hazard should be rectified (only if possible and safe to do so); • If the hazard cannot be rectified, the area should be made safe to prevent further harm; • Other relevant AGL personnel and Contractors must be informed of the Event and any imminent threats;

and • Take steps, if safe to do so, to make safe and preserve scene.

The responsible Leader or most senior person at the scene must, in consultation with the relevant Health and Safety or Environment Business Partner, assess if the Event has the potential to be a Regulatory Reportable Event and ensure that:

• The scene of the Event is preserved (if safe to do so); • Witness statements are collected (where practicable); and • Photographic evidence is collected (where practicable or permissible).

For Events that require Emergency Response refer to the Emergency Preparedness, Response and Management Standard (AGL-HSE-STD-010) and local Emergency Response Procedures.

Immediate Response Leader Notification Classification

Immediate Notitification Report

and Escalation (if required)

HSE Brief(if required)

Significant Event Initial Summary

(if required)myHSE Recording


5.2 Leader Notification

It is the responsibility of the person involved in the Event to immediately notify their Leader or as soon as practicable following the immediate response. If the person involved is not capable of notifying their Leader due to injury or illness, then the person who is administering the assistance must contact the Leader responsible for the person involved.

5.3 Classification

Upon receiving notification of the Event, the responsible Leader must classify the Event, in consultation with the relevant Health and Safety or Environment Business Partner, to determine if it is:

• High Potential Event (deemed to be High Risk and above using AGL’s Fully Integrated Risk Management (FIRM) matrix);

• Potential Lost Time Injury/Illness or Medical Treatment Injury/Illness; • Regulatory Reportable; or • Voluntary Reportable.

Where there are conflicting views in relation to the classification of the Event, the Head of Safety and/or the Head of Environment, Health, Audit and Training will determine classification for the purpose of reporting.

High Potential Events

The responsible Leader must carry out a risk assessment on the Event in accordance with the HSE Risk Management Standard (AGL-HSE-STD-004.1) and in consultation with the relevant Health and Safety or Environment Business Partner.

The risk assessment must assess the Event based on potential consequence and likelihood. If the risk potential of the Event is deemed to be High, Very High or Extreme it will be classified as High Potential (HP) Event.

Potential LTI / MTI Incidents

If the Event resulted in an injury or illness, the responsible Leader must assess if the injury has the potential to become a Lost Time Injury/Illness (LTI) or Medical Treatment Injury/Illness (MTI) in consultation with the relevant Health and Safety Business Partner and Injury Management Coordinator (if required).

Regulatory Reportable Incidents

The responsible Leader must assess whether the Event meets the regulatory reportable criteria in consultation with the relevant Environment Manager, Health and Safety or Environment Business Partner.

Definitions of Regulatory Reportable Events, as prescribed by relevant State laws and regulations, are provided in the Obligations to Notify Regulatory Authorities Guideline (AGL-HSE-GUI-012.1).

If assessed as Regulatory Reportable, the relevant Head of Function or Health and Safety or Environment Business Partner must contact Group Legal as soon as possible after the Event occurs to confirm whether the Event triggers a legal obligation to notify Regulatory Authorities or if Legal Professional Privilege is required.

External statutory notifications must be completed to relevant external stakeholders and Regulatory Authorities, as directed by Group Legal, within statutory timeframes.

AGL will also complete required statutory notifications for Contractor incidents where the Contractor is working for AGL in accordance with contractual arrangements.


Voluntary Reportable Incidents

If, following advice from Group Legal, an Event is not determined Regulatory Reportable, a decision may still be made to report the incident to the Regulatory Authority on a voluntary basis.

The considerations and processes for this decision must be made in consultation with Group Legal, as set out in Section 2.2 of the Obligations to Notify Regulatory Authorities Guideline (AGL-HSE-GUI-012.1).

5.4 HSE Event/Initial Brief

A HSE Event/Initial Brief (Brief) may be used to communicate important health and safety or environment information to advise people of significant events and/or potential risks associated with a High Potential Event that may have an immediate impact at a local site and/or the wider business.

A Brief must be issued within 4 hours of the High Potential Event occurring, where practicable.

Details of the Brief need to include, but not be limited to:

• Relevance to e.g. all personnel, or Electrical workers; • Description of Event; • Immediate actions taken e.g. cease operations, toolbox to staff on incident; • Extent of injury / damage to people, plant and /or environment; and • Short term actions. E.g. Complete investigation.

The Head of Function is responsible for developing the Brief in consultation with the Health and Safety or Environment Business Partner, Head of Safety and/or Head of Environment and Group Legal (where applicable) in accordance with HSE Consultation and Communication Standard Methodology (AGL-HSE-SDM-006). The distribution of the approved Brief across AGL, operating sites and relevant Contractors (if required) will be coordinated by the HSE Manager Communications.

Note: In some cases, Events that require a Brief may be reportable to regulators or subject to Legal Professional Privilege and they must therefore be reviewed by Group Legal before distribution.

5.5 Immediate Notification Report

For actual or potential LTI, MTI, HP, ERR Events (including the receipt of a Fine or Infringement Notice) or Electrical Shock Incident, the Leader must complete the Immediate Notification Report (INR) using AGL-HSE-FRM-012.1 as a template.

If the Event is deemed to be an actual or potential ERR Electric Shock Incident or a Fine/Infringement Notice, the Leader must consult with Group Legal and the relevant Head of Safety, and Head of Environment, Health, Audit and Training prior to completing the INR.

If the Event is deemed to be actually or potentially reportable, legally sensitive or subject to legal professional privilege consultation must occur with Group Legal, Head of Safety, Head of Environment, Health, Audit and Training, the relevant Health and Safety or Environment Business Partner prior to sending the INR.

The INR must not contain any assumptions or opinions. Only statements of fact or information that can be verified.

If the status of an Event changes to a Fine or Infringement Notice an INR must be completed.


On completion of the INR, the responsible Leader must email the completed INR to the relevant Head of Business and/or General Manager, Health and Safety or Environment Business Partner, Manager HSE Systems and Analytics, Group Risk and Compliance Manager and Manager Government and Community Relations.

The relevant Health and Safety or Environment Business Partner must email the completed INR to the Head of Safety or Head of Environment, Health, Audit and Training.

The Business General Manager is responsible for emailing the INR and verbally contacting the relevant Executive General Manager, Chief of Staff and General Manager, Group HSE & Security immediately (for Electrical shock incidents or Very High-Extreme Events) or no later than 4 hours from being notified of the Event. The Executive General Manager will then notify the CEO, Group Legal (if not already done so) and the Executive Team immediately (for Electrical Shock Incidents or other Very High-Extreme Events) or no later than 4 hours from being notified of the Event.

The content of the INR is to be used as the basis of the oral briefing. The oral briefing is also to include consultation with the relevant Health and Safety or Environment Business Partner and the supervisor of the work (note: this may be the Contract Manager if a contractor is involved).

An oral briefing must also be carried out after 7 calendar days of the incident with all relevant stakeholders to track the progress.

5.6 Notification Escalation Process

The appropriate notification escalation process is dependent on the

Nature and Severity (risk ranking) of the Event and has been summarised as follows.


Notification Escalation Process Matrix

Nature of Event Potential Severity of Event

Low-Moderate High Very High - Extreme

Electrical Shock Incident

or receipt of Fine or

Infringement Notice.

Notify relevant Head of Business and/or GM, Health and Safety

or Environment Business Partner, Manager of HSE Systems and

Analytics, Manager Government and Community

[Responsible Person = Leader]

Notify HoS and/or HoEHAT

[Responsible Person = Relevant HSEBP]

Notify relevant EGM, Chief of Staff and GM GHSE&S

[Responsible Person = Business GM]

Notify CEO, ET and Group Legal (if required)

[Responsible Person = Relevant EGM]

Notify Board (if required)

[Responsible Person = Group Legal]

Potential or actual LTI,

MTI, Environment

Regulatory Reportable

Event.

Notify Head of Business and/or GM, Health and

Safety or Environment Business Partner, Manager of

HSE Systems and Analytics, Manager Government,

and Community

[Responsible Person = Leader]

Notify HoS and/or HoEHAT

[Responsible Person = Relevant HSEBP]

Notify relevant EGM, Chief of Staff and GM GHSE&S

[Responsible Person = Business GM]

All other Incidents, Near-

Misses or Hazards.

Notify relevant Leader and HSEBP

[Responsible Person = Reporting Person]

HSEBP = Health and Safety or Environment Business Partner

HoB = Head of Business

HoS = Head of Safety

HoEHAT=Head of Environment, Health, Audit and Training

GM = General Manager

GM GHSE&S = General Manager, Group HSE & Security

EGM = Executive General Manager

ET = Executive Team

CEO = Chief Executive Office

Immediate

No later than 4 hours from Event

By end of shift and no later than 24 hours from Event


The INR and notification escalation process is shown in the flowchart below.


5.7 myHSE Recording Initial Report

All Events must be entered into myHSE within 24 hours of the Event occurring (where practicable). This must be done regardless of the requirement to issue an Immediate Notification Report.

The information should be entered by the person involved, or if unable to do so, any other person that may have been involved in the Event or delegated the task of entering the information in myHSE by the person or involved person’s Leader.

Contractor incidents, near misses and hazards must be entered into myHSE by the Contractor or by the responsible Contract Manager or Delegate (if the Contractor does not have access to myHSE) in accordance with the terms of the contract.

Access to myHSE is through the GRID (AGL intranet) - https://grid.agl.com.au/HSE/Pages/myHSE.aspx - which also contains guidance videos on how to log an incident or near miss.

The person entering details of the Event must only state known facts. People’s names must only be included in the People tab but excluded from any of the text descriptions to ensure privacy is maintained.

On final submission, the person entering details of the Event must ensure the appropriate responsible Leader (which may be different to the person’s immediate Leader) is selected to ensure the correct workflows are initiated. The appropriate responsible Leader would generally be associated with the site or location where the Event took place.

Leader Verification

Once the Event has been logged in myHSE, a workflow will be triggered to the responsible Leader to complete the Leader Verification step.

The responsible Leader must complete this verification within three calendar days of receiving the workflow.

As part of the Leader Verification, the responsible Leader is required to review and verify the following details:

• Description of the Event is as accurate as reasonably possible • Appropriate Event Type: Incident, Near Miss or Hazard; • Appropriate Event Sub-Type: Motor Vehicle, Permit, Fire or Property Damage; • Work relatedness of Event (Health and Safety Events only); • Risk classification of Event; • Injury/Illness Type: Lost Time, Medical Treatment, First Aid or Register of Injury/Illness (Health and Safety

incidents only); • Injury/Illness Classification: TIFR or OIFR (Health and Safety incidents only) - see Section 5.7.2.1; • Is it Regulatory Reportable or Voluntary Reportable?; and • Assign Investigator - see Section 5.7.3.

Refer to Section 14 for definitions of the above items.

5.7.2.1 Classification of work-related LTIs and MTIs

All work-related LTIs and MTIs must be classified in myHSE as either TIFR or OIFR based on the criteria stipulated below:

https://grid.agl.com.au/HSE/Pages/myHSE.aspx


• TIFR: Any work-related LTI or MTI where work is determined to be a significant contributing factor and a point in time where the injury/illness occurred can be identified either from a single Event or a known period of time; or

• OIFR: Any work-related LTI or MTI caused by the aggravation of a pre-existing injury or illness due to a work activity or condition as well as a gradual onset injury or illness that can be attributed to the injured person’s work activities.

The aggravation or re-aggravation of a prior work-related injury/illness that was recorded in myHSE as a work-related incident must be attributed to the original incident and not re-entered in myHSE as a new injury or illness.

5.7.2.2 Review of Injury/Illness Classification

In some instances, the condition of an injured worker or treatment provided may change, or other information becomes available, that has the potential to change the initial classification given to an injury/illness.

Where this is the case, the relevant Health and Safety Business Partner is to complete the Injury/Illness Classification Review Form (AGL-HSE-FRM-012.3). Completion of the form ensures that a formal review and approval is undertaken before a final classification of the injury/illness is determined and myHSE is updated.

The Head of Safety or Delegate must approve the change in the injury/illness classification in consultation with the HSE Reporting and Analytics Manager. The approved form is to be uploaded into myHSE for recording purposes.

5.7.3 Assign Investigator

For Low and Moderate risk Events, the responsible Leader must assign an Investigator. Once selected, the Investigator will receive a workflow action to complete the investigation.

For High Potential Events, the workflow action will go to the Head of Function who is responsible for assigning the Investigator. Once selected, the Investigator will receive a workflow action to complete the investigation.

5.7.4 Health and Safety or Environment Business Partner Verification

Following the Leader’s verification step, the relevant Health and Safety or Environment Business Partner will receive a workflow action to verify the details of the Event. This workflow only applies to Incidents, Near Misses and Events that are deemed High Potential i.e. for Hazards that are risk ranked Low the HSEBP Verification step is optional.

If the relevant Health and Safety or Environment Business Partner believes the risk classification or injury classification of the Event needs to be changed or if other substantial changes are required, they must discuss the proposed changes with the responsible Leader before finalising.

If the risk classification is to be amended to High Potential, the Head of Function must be consulted before completing the verification.

The HSEBP verification must be completed within seven calendar days of receiving the workflow notification.

6. Investigations 6.1 General Requirements

The appropriate Leader and HSE Business Partner must determine the appropriate investigation method to be applied based on the risk ranking of the Event.


An investigation should commence as soon as possible or within two calendar days of the Investigator receiving the workflow to complete the investigation and where practicable must be completed within 14 calendar days of the Investigator receiving the workflow.

The Investigator may request a time extension to complete the investigation via myHSE. The request will generate a workflow to the relevant Health and Safety or Environment Business Partner, who will review and approve the request if appropriate.

6.2 Investigation Types

The Investigator must be competent in the application of the investigation method determined for a particular Event.

6.2.1 Basic Investigation

A basic investigation can be carried out by the responsible Leader (or Delegate) and requires the responsible Leader to ask why the incident occurred and document the findings in myHSE as well as any improvement actions, if required.

6.2.2 5-Whys

5-Whys is a tool that requires the Investigator to ask “why?” up to five or more consecutive times until the root cause of the Event is clearly identified. The 5-Whys Guideline (AGL-HSE-GUI-012.3) must be applied when carrying out this investigation method.

6.2.3 Root Cause Analysis (RCA)

RCA is a method of problem solving that identifies the root cause(s) of an asset fault or incident. Removing the root cause from the problem fault sequence should prevent the undesirable incident from re-occurring.

The use of the Apollo Root Cause Analysis technique, which incorporates Reality Charting, is the preferred technique to be used for these types of incidents across all AGL Group Operations Sites.

An Investigation may identify the requirement for completing a specific RCA depending upon the nature and circumstances of the Event. The Investigator or Delegate must be trained in the application of the Apollo Root Cause Analysis technique.

6.2.4 Incident Cause Analysis Method (ICAM)

The ICAM investigation tool identifies the personal and workplace factors and possible organisational deficiencies in the HSE management system that have contributed to the Event.

The Investigator must be trained in the application of the ICAM process. The ICAM Guideline (AGL-HSE-GUI-012.2) must be applied when carrying out the ICAM investigation method. The Investigator must prepare an investigation report using the ICAM Investigation Report Template (AGL-HSE-TMP-012.3).

6.3 Low to Moderate Risk Investigations 6.3.1 Investigation requirements

• The responsible Leader or Delegate may undertake or assign an Investigator to carry out the investigation;

• For Low Risk Events a Basic Investigation may suffice but for Moderate Risk Events the 5-Whys methodology must be followed as a minimum; and

• The responsible Leader or Delegate has the option to complete the investigation at the same time as completing the Leader Verification step without initiating a separate investigation workflow in myHSE.


6.4 High to Extreme Risk Investigations (High Potential Events) or Environment Regulatory Reportable

6.4.1 Investigation requirements

• The Head of Function must appoint the Lead Investigator from the register of competent ICAM Investigators in consultation with the Health and Safety or Environment Business Partner;

• Investigations must follow the ICAM methodology or for external parties an equivalent HSE incident investigation methodology must be used; and

• The Head of Function must include a member of the HSE team and relevant technical subject matter experts in the investigation team (e.g. electric contact incidents may require electrical specialist) to ensure the appropriate level of technical guidance and expertise is considered during the investigation.

6.5 Investigation Reporting and Verification Process 6.5.1 Low to Moderate Risk Investigations

For Low and Moderate Risk investigations, the Investigator must enter the results of the investigation (including all identified root causes of the Event), investigation report (if completed) and assign all improvement actions (with completion dates) into myHSE by the due date.

The responsible Leader should also verify that all safety-related defects and/or maintenance work orders initiated as part of the Event are either on-track for completion or have been completed.

6.5.2 High to Extreme Risk (High Potential) Investigations

For High Potential investigations, the Lead Investigator must enter the results of the investigation (including all identified root causes of the Event), upload the ICAM investigation report and any other relevant documentation, and assign all improvement actions (with completion dates) into myHSE by the due date.

myHSE has been configured with a two-step verification process to be applied for all High Potential Event investigations.

The first verification step involves the Head of Safety or Head of Environment, Health, Audit and Training to review and approve the investigation.

The timeframe allowed to complete the first verification step is 3 calendar days.

Once approved by the Head of Safety or Head of Environment, Health, Audit and Training , the Head of Function is required to review and approve the investigation. As part of this step, the Head of Function should also verify that all safety-related defects and/or maintenance work orders initiated as part of the Event are either on-track for completion or have been completed.

The timeframe allowed to complete the final verification step is 3 calendar days.

Once both verification steps have been completed, improvement actions will be assigned to their respective action owners.

If at any stage, the investigation is rejected, a workflow to resubmit the investigation goes back to the Lead Investigator for rectification.


6.5.3 Investigation Governance

For all investigations where significant changes to the investigation report have been proposed during the verification process, the proposed changes must be communicated to the Investigator for consultation and approval before finalisation. This excludes grammatical and/or formatting errors.

Where an Investigation Team has been convened, the proposed changes must also be presented to the Investigation Team for consultation and approval before finalisation.

6.6 Contractor Investigations

For Events involving a Contractor, the Contractor must complete their own investigation and provide a copy of the report to AGL, along with a plan to close out relevant improvement actions in a timely manner.

The responsible Leader must determine the Contractor’s competency to complete the investigation to AGL’s standard.

For all High Potential Events, investigations must follow the ICAM methodology or equivalent, as a minimum.

The Contractor must assign a competent person as an investigation facilitator for the application of the ICAM methodology or agreed equivalent investigation process. Subject to the terms of the relevant contract, if the Contractor is not considered competent to carry out an ICAM investigation, AGL will provide an ICAM facilitator to facilitate the process. The Head of Function will assign an AGL representative to assist with the investigation and ensure systemic issues relating to AGL operations are identified.

Note: On some occasions it may be necessary for AGL to carry out an independent ICAM investigation, however this should be determined on a case by case basis by the Head of Function in consultation with the Head of Safety or Head of Environment, Health, Audit and Training Manager.

7. Management of Regulatory Issues 7.1 Notification

For all improvement notices, prohibition notices, prosecutions or fines by a Regulatory Authority, the responsible Leader must notify the Head of Function and relevant Health and Safety or Environment Business Partner as soon as practicable.

The relevant Health and Safety or Environment Business Partner must notify the Head of Safety or Head of Environment, Health, Audit and Training immediately.

The Head of Function must notify the following (by email) within 24 hours of being made aware of the notice, prosecution or fine:

• General Manager, Group HSE & Security; and • Head of Safety (safety related events) or Head of Environment, Health, Audit and Training (environment

related events).

The management of regulatory issues is to be carried out in accordance with the Obligations to Notify Regulatory Authorities Guideline (AGL-HSE-GUI-012.1).


7.2 myHSE Recording

The responsible Leader or relevant Health and Safety or Environment Business Partner must enter the details in myHSE within 24 hours of the Regulatory Authority’s visit, notice, prosecution or fine, providing all details and any supporting material.

8. Training and Competency Formal training is required for Basic and 5-Whys (via the relevant Empower module) and ICAM Investigators (Lead ICAM Investigator Course).

Minimum competency are prescribed as follows:

• All persons undertaking Basic and 5-Whys investigations must have completed the relevant Empower module every two years;

• Within 12 months of completing the Lead ICAM Investigator Course, ICAM Investigators must facilitate at least one ICAM investigation and participate in a minimum of two other ICAM investigations (participation may include review of a completed ICAM investigation report performed by another ICAM Investigator); and

• On an annual basis ICAM Investigators are required to undertake or participate in at least one ICAM investigation. Participation may include the review of a completed ICAM investigation report performed by another ICAM Investigator.

Failing to meet the above minimum requirements, an ICAM Investigator will be deemed to be no longer competent to lead an ICAM Investigation (unless the Head of Function approves the Investigator, based on recognition of prior learning or experience).

An ICAM trained investigator may be re-appointed after participation in at least one ICAM Investigation.

The Health Safety and Environment Manager, Audit, Compliance and Training is responsible for maintaining a central register of ICAM trained investigators and facilitating ICAM training in accordance with the AGL HSE Training Procedure.

9. Improvement Actions The key objective of any investigation is to establish contributing factors and root cause(s) of the Event so that improvement actions can be identified and implemented to either prevent or reduce the likelihood of recurrence.

The Investigator must develop improvement actions designed to eliminate or mitigate the root cause(s) of the Event, including contractor Events.

Improvement actions must be developed in accordance with the guiding principles of the Hierarchy of Risk Control (see Appendix 2).

Each improvement action must contain specific instructions and be assigned to a person for implementation within a specified timeframe. The Investigator must enter all improvement actions in myHSE in accordance with the investigation reporting requirements stipulated by this procedure (refer to Section 6.5).


Note: Contractors improvement actions will be recorded and tracked to close out using Contractor management systems. The Contract Manager is responsible for verifying close out and effectiveness of the Contractor’s improvement actions.

The person assigned the improvement action has the opportunity to review the action, including timeframes, before accepting the assignment in myHSE. If changes are required (e.g. the timeframe is not achievable) the person can reject the action and a workflow to amend the action is generated back to the Investigator for action. Once accepted, the person is responsible for completing the action by the due date. The person assigned can request a due date extension from the relevant Health and Safety or Environment Business Partner. A clear justification must be provided before the extension is granted.

For all TIFR, ERR and High Potential Incidents evidence must be uploaded by the person assigned to the improvement action into myHSE to demonstrate the close out of the action.

The quality of incident reports and investigations will be monitored on a regular basis by the HSE Team to ensure:

• risk ratings are appropriate; • the investigation methodology applied is appropriate; • required documentation can be located and has been saved / recorded in the appropriate location; • root causes have been identified; • corrective actions address all root causes; and • actions have effectively managed the root causes.

10. Lessons Learnt and Hazard Alerts Lessons Learnt and Hazard Alerts are to be developed and distributed in accordance with AGL-HSE-PRO-006.1 Creating, Approving and Distributing HSE Communications.

11. Fatalities Any fatality is classified as a Notifiable Incident and must be reported to the appropriate Regulatory Authority(ies) in accordance with relevant legislation.

The notification requirements for a fatality are described as follows:

• The responsible Leader must immediately notify the Head of Function, Health and Safety Business Partner;

• The Head of Function must immediately notify the relevant Executive General Manager (EGM), EGM Group Operations, CEO, Directors of the relevant AGL entity and Group Legal;

• The CEO or delegate will determine whether the Crisis Management Plan is required to be initiated and notify the Crisis Management Team Leader as required;

• If the Crisis Management Plan is not required, the Head of Function or delegate must notify the relevant regulatory authority(ies) in consultation with Group Legal;

• AGL Legal Counsel must be engaged to ensure Legal Professional Privilege is applied to the Event and subsequent investigation; and

• Notification to the family of the deceased will be carried out by representatives of the State Police and is not to be done by any AGL representative. Any comments or response to media will be done in accordance with the relevant AGL procedure.


12. Environment Related Community Complaints Stakeholder and community complaints received by AGL must be logged and managed by the relevant AGL community/stakeholder relations team. All community-related complaints should be logged by the AGL community/stakeholder relations team in “Consultation Manager” or the community complaints database used by the AGL site(s).

Any environment-related community complaint received by AGL must be verified by the relevant Environment Business Partner to confirm whether the source of the complaint is likely to be related to AGL operations or activities.

If the outcome of the verification determines that the source of the complaint was likely due to AGL operations or activities, then the relevant Environment Business Partner or Delegate must enter details of the verified environment-related community complaint as an Environment Incident in myHSE and manage it in accordance with this procedure.

If the outcome of the verification determines that the source of the complaint was not likely due to AGL operations or activities, then the Environment Business Partner or Community Relations Representative must notify the complainant about this outcome.

The Environment Business Partner may also notify the relevant Regulatory Authority(ies) in accordance with site-specific external notification protocols.

13. Crisis Management Plan All site Emergency Response Plans should take into account the requirements of the Crisis Management Plan.

A three tiered escalation process has been developed to acknowledge that some Events will have more severe consequences to AGL than others.

Level 1 and 2 incidents may not reach the severity of a Crisis but should be monitored for potential escalation. The Emergency Response Plans in accordance with the Emergency Preparedness, Response and Management Standard (AGL-HSE-STD-010) should be implemented for:

• Level 1 incidents: Significant threat to the achievement of departmental objectives; and • Level 2 incidents: Significant threat to the short term profitability of the business.

A Level 3 incident is required to activate the AGL Crisis Management Plan. A Level 3 incident is an incident which causes a major detrimental threat to:

• AGL’s commercial profitability or assets; • AGL’s ability to operate its business (business continuity); • AGL’s customers; • AGL’s reputation or relationship with key stakeholders; • The environment; and • AGL’s employees, or the general public.

A Level 3 incident will require engagement of AGL’s most senior management, as well as internal and external subject matter experts.


If a Level 3 incident has occurred the first step is to notify the CEO who calls a Level 3 and appoints an Incident Commander. The Incident Commander mobilises the Crisis Management Team in accordance with the AGL Crisis Management Plan.

14. Definitions Term Type Definition

myHSE Health and Safety, Environment

myHSE is AGL’s fully integrated online platform for the reporting, classification and investigation of all HSE hazards, near misses and incidents.

Competent person

A competent person for any task means a person who has acquired, through training, qualification or experience, or a combination of them, the knowledge, skills and ability to carry out that task.

Contract Manager The person nominated to administer and supervise the overall direction and coordination of the contract and who is held responsible by AGL for this purpose. The Project/Contract Manager may also be a contractor. This term may be replaced with Program Manager, Contract Supervisor, Contract Administrator, Site Coordinator or other depending on the business location requirements and particulars of the works and/or contract.

Event Any HSE incident, near miss or hazard as defined in Section 4.1, 4.2 and 4.3 of this Procedure.

Electrical Shock Incident (ESI)

Health and Safety

Any incident where a person makes contact with a live conductor or electrical apparatus/plant or equipment.

Fully Integrated Risk Matrix (FIRM) FIRM is AGL’s Risk Assessment and Management Framework.


Term Type Definition

First Aid Injury (FAI) Health and Safety

First Aid is defined as:

• Using a legal over the counter non-prescription medication at non-prescription strength (Any medication prescribed by the medical practitioner and accepted by the Workers' Compensation insurer as a medical expense is considered medical treatment);

• Administering tetanus immunisations; • cleaning, flushing or soaking wounds on the surface of the skin; • Using coverings such as bandages, band aids, gauze pads; or using

butterfly bandages or Steri-Strips. (Other wound closing devices such as sutures, staples are considered medical treatment);

• Using hot or cold therapy; • Using any non-rigid means of support, such as elastic bandages,

wraps, non-rigid back belts etc. (Devices with rigid stays or other systems designed to immobilise parts of the body are considered medical treatment);

• Using temporary immobilisation devices while transporting an accident victim (e.g. splints, slings, neck collars, back boards etc);

• Drilling of a fingernail or toenail to relive pressure, or draining fluid from a blister;

• Using eye patches; • Removing foreign bodies from the eye using only irrigation or a cotton

swab; • Removing splinters or foreign material from areas other than the eye

by irrigation, tweezers, cotton swabs or other simple means; • Using finger guards; • Using massages or single session of physical therapy and/or

chiropractic treatment for precautionary purposes (Note: More than one session of physical therapy and/or chiropractic treatment would be considered Medical Treatment and classified accordingly); and

• Drinking fluids for relief of heat stress.

High Potential (HP) Health and Safety, Environment

Any Incident, Near Miss or Hazard that has been verified by the responsible Leader and relevant Health and Safety or Environment Business Partner as High or above Risk potential in accordance with the FIRM matrix.

Hierarchy of Risk Control (HoC)

Health and Safety, Environment

The ways of controlling risks ranked from the highest level of protection and reliability to the lowest as shown in Appendix 2.

Incident (INC)

Health and Safety

An Event that resulted in the injury or illness of a person requiring Lost Time, Medical Treatment, First Aid or Non-Treatment.

If the Event also resulted in motor vehicle damage, a permit breach, fire and/or property damage, these attributes would be classified as sub-categories to the Incident.



Environment An environment incident is classified as any event that resulted in:

• An uncontrolled or unauthorised discharge; • Unauthorised environmental impact or damage, or potential

damage (e.g. a spill to ground or a spill outside of a bunded area);

• A breach of an environmental legal obligation or licence condition; or

• A verified environment-related community complaint.

Near Miss (NM)

Health and Safety

An unplanned Event or error that did not result in injury, illness but had the potential to do so.

If the Event resulted in motor vehicle damage, a permit breach, fire and/or property damage, these attributes would be classified as sub-categories to the Near Miss.

Environment An environment near miss is classified as any event where no actual regulatory breach or unauthorised environmental impact occurred but there was potential for a regulatory breach or unauthorised environmental impact to occur, i.e. the event was a close call and could result in an incident in the future unless improvement actions are implemented.

Hazard (HZ)

Health and Safety

A health and safety hazard is any observation or workplace situation or source that has the potential to harm the health and safety of people or damage plant and equipment if not controlled.

Environment An environment hazard is classified as any observation, task, process or equipment that has the potential to be a source of future environmental harm if left unattended.

Injury/Illness Health and Safety

Injuries and illnesses are categorised as being:

• Register of Injury or Illness; • First Aid; • Medical Treatment Injury or Illness; or • Lost Time Injury or Illness.

Lost Time Injury/Illness (LTI)

Health and Safety

Any work related injury or illness that results in a fatality, permanent disability or time lost from work of one day/shift or more, as prescribed by a medical practitioner.



Medical Treatment Injury/Illness (MTI)

Health and Safety

Any work related injury or illness resulting in a person requiring medical treatment.

Medical treatment does not include:

• Visits to a health care professional solely for observation or counselling;

• The conduct of diagnostic procedures, such as x-rays and blood tests, including the administration of prescription medications used solely for diagnostic purposes (e.g. eye drops to dilate pupils); and

• First aid.

Register of Injury/Illness (ROI)

Health and Safety

A register of injury or illness is an Event where an injury/illness has occurred or it is not work related, but there is no requirement to carry out first aid or other types of medical treatment.

LTI or MTI (TIFR) Health and Safety

Any work-related Lost Time or Medical Treatment Injury/Illness where work is determined to be a significant contributing factor and a point in time where the injury/illness occurred can be identified either from a single Event or a known period of time.

Total Injury/Illness Frequency Rate - (TIFR)

Health and Safety

Total number of work-related LTIs and MTIs classified as TIFR in myHSE, recorded in a 12 month rolling period per million hours worked in that 12 month period.

LTI or MTI (OIFR) Health and Safety

Any work-related Lost Time or Medical Treatment Injury/Illness caused by the aggravation of a pre-existing injury or illness due to a work activity or condition as well as a gradual onset injury or illness that can be attributed to the injured person’s work activities.

Occupational Injury/Illness Frequency Rate - (OIFR)

Health and Safety

Total number of work-related LTIs and MTIs classified as OIFR in myHSE, recorded in a 12 month rolling period per million hours worked in that 12 month period.



Regulatory Reportable

Health and Safety, Environment

A Regulatory Reportable Incident is any Event that meets the notification criteria of a Regulatory Authority and may include:

• The death of a person • A significant injury or illness of a person as defined by relevant

Commonwealth and/or State health and safety legislation; • A dangerous incident as defined by relevant Commonwealth and/or

State health and safety legislation; • A dangerous incident as defined by relevant Commonwealth and/or

State Electrical, Gas and Petroleum legislation; • An Event that caused actual or potential material or serious

environmental harm; and • A Breach of an environmental licence condition.

Regulatory Authority Health and Safety, Environment

The relevant authority to whom each Regulatory Reportable incident, near miss or hazard must be reported.

Reporting Person Health and Safety, Environment

The person who identified and/or reported the incident, near miss or hazard to the responsible Leader or Delegate. This (should, where practical also) be the same person that entered the incident information into myHSE.

RCA Co-Ordinator Health and Safety, Environment

The RCA Co-Ordinator (Apollo Reality Charting) is responsible for the organisation of the RCA program at each Business Unit.

Voluntary Reportable Health and Safety, Environment

A Voluntary Reportable is any Event that is reported to a relevant Regulatory Authority, in consultation with Group Legal, even though it does not meet the mandatory notification criteria of the Regulatory Authority.

Work Environment Health and Safety

The work environment includes a place where one or more employees are working or are present as a condition of their employment. The work environment includes physical locations and equipment or materials used by the employee during the course of his or her work activities.



Work Related Health and Safety

A work related Incident, Near Miss or Hazard is anything that:

• Occurred as a result of AGL’s undertaking; • An injury or illness that has either been as a result or been

contributed to undertaking work activities related to employment; and • Work has been determined as a significant contributing factor and/or

is compensable (i.e. deemed to be work-related by relevant Regulator).

Any injury or illness occurring in a work environment that falls under one of the following exceptions is deemed to be non-work related:

• At the time of the injury or illness, the employee was present in the work environment as a member of the general public rather than as an employee.

• The injury or illness involves signs or symptoms that surfaced at work but result solely from a non-work-related Event or exposure that occurs outside the work environment and work was not a significant contributing factor.

• The injury or illness results solely from voluntary participation in a wellness program or in a medical, fitness, or recreational activity such as blood donation, physical examination, flu shot, exercise class, racquetball, or baseball (where the matter is determined to be non-compensable).

• The injury or illness is solely the result of an employee eating, drinking, or preparing food or drink for personal consumption (brought in or external from the site).

• The injury or illness is solely the result of an employee doing personal tasks (unrelated to their employment) at the work environment outside of the employee's assigned working hours.

• The injury or illness is solely the result of personal grooming, self-medication for a non-work-related condition, or is intentionally self-inflicted.

• The illness 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).

• The illness is a mental illness. Mental illness will not be considered work-related unless the employee voluntarily provides the employer with an opinion from a doctor or other licensed health care professional with appropriate training and experience (psychiatrist, psychologist, psychiatric nurse practitioner, etc.) stating that the employee has a mental illness that is work-related (as required by relevant state or territory Workers Compensation Legislation).


15. Referenced Documents

Document Number Document Title

AGL-HSE-STD-004 HSE Risk Management Standard

AGL-HSE-SDM-006 HSE Consultation and Communication Standard Methodology

AGL-HSE-STD-010 Emergency Preparedness, Response and Management Standard

AGL-HSE-STD-012.1 Incident, Near Miss and Hazard Management Standard

AGL-HSE-PRO-006.1 Creating, Approving and Distributing HSE Communications

AGL-HSE-FRM-012.1 Immediate Notification Report Form

AGL-HSE-FRM-012.3 Injury/Illness Classification Review Form

AGL-HSE-FLO-012.1 Incident, Near Miss and Hazard Management Flowchart

AGL-HSE-GUI-012.1 Obligations to Notify Regulatory Authorities Guideline

AGL-HSE-GUI-012.2 ICAM Guideline

AGL-HSE-GUI-012.3 5-Whys Guideline

AGL-HSE-TMP-012.3 ICAM Investigation Report Template

AGL-HSE-SDM-012.3 Contractor Reporting Standard Methodology

Group Operations RCA Standard Root Cause Analysis Standard

Safe Work Australia Code of Practice - How to manage work health and safety risks


Appendix 1 – Reporting of HSE Events in myHSE

Incident Location Who got injured or caused incident?

AGL employee Contractor employee Subcontractor employee Visitor

Work site owned and controlled by AGL Yes Yes Yes Yes

Work site owned by AGL and controlled by PC (other than

AGL)

Yes Yes Yes No

Work site owned by 3rd Party and controlled by AGL (as

PC)

Yes Yes Yes Yes

AGL may also be required to report Incident to Owner

Work site owned by 3rd Party and controlled by PC (other

than AGL)

Yes

(as Contractor to PC)

Yes

(as Subcontractor to AGL)

Yes No

AGL may also be required to report Incident to PC

Work site owned by member of the public and controlled

temporarily by Contractor (not construction project) e.g.

residential site for rooftop solar, battery or meter

installation.

Yes

(if on site)

Yes

(as Subcontractor to AGL)

Yes No

Notes: - PC = Principal Contractor

- Contractor must be engaged by AGL to perform work.

- Subcontractor must be engaged by Contractor (as per above requirement).

- An estimate of hours worked for Contactors and Subcontractor must be reported to AGL monthly.

- If Yes, the corresponding LTI, MTI, ERR or High Potential Event will be included in AGL’s employee and contractor HSE statistics.

- Incidents must be deemed ‘work-related’ in accordance with AGL definitions. Otherwise they may be recorded in myHSE as non-work related (for due diligence purposes) but excluded from AGL’s

HSE statistics.


Appendix 2 – Hierarchy of Risk Control

Date post:	19-Nov-2021
Category:	Documents
Upload:	others
View:	2 times
Download:	0 times