Professional Documents
Culture Documents
MANAGEMENT PROCEDURE
DATE: 22 JULY 2020
LIST OF APPENDICES
APPENDIX 1 : REVISION AMENDMENTS ......................................................................................... 10
APPENDIX 2 : INCIDENT ACTION AND INVESTIGATION GUIDE ................................................... 12
APPENDIX 3 : REPORTING INCIDENTS IN WESTERN AUSTRALIA .............................................. 13
APPENDIX 4 : CLASSIFICATION OF NEAR MISSES AND POTENTIAL CONSEQUENCES ......... 16
APPENDIX 5 : CATEGORIES OF CONSEQUENCE .......................................................................... 19
APPENDIX 6 : SPILLS MATRIX .......................................................................................................... 20
LIST OF FIGURES
Figure 1 - Basic Event Investigation Process .......................................................................................................... 5
LIST OF TABLES
Table 1 – Incidents and Verbal Reporting Responsibilities ..................................................................................... 3
Table 3 – Recommended Training for Investigation Team...................................................................................... 8
2. SCOPE
This Procedure applies to all persons on an IGO site, office or exploration area, including all contract
personnel and visitors.
3. DEFINITIONS
Term Definition
Incident • An occurrence arising out of, or in the course of, work that could or does
result in injury, illness, or damage
• An occupational injury or illness is an abnormal condition or disorder
Injury whose cause is attributed to exposure factors associated with
employment. Refer to IGO Injury & Illness Classification and
Reporting Procedure
Near Miss • A Near Miss is defined as an unplanned event that did not result in injury,
illness, or damage – but had the potential to do so.
Serious Injury
• Refer to IGO Injury & Illness Classification and Reporting Procedure
4. PROCEDURE
4.1 Incident Response
In the event of an emergency, follow the site’s emergency procedure.
The responding front line supervisor identifies and implements immediate actions and isolate
damaging energies to make the area safe and to prevent escalation of the incident. Other
considerations include:
All incident and near miss events will be reported using IGO’s online incident reporting system
INX InControl 24 hours in which the incident occurred. Any person involved or witness to the
incident event can submit the event in INX InControl. Overall responsibility of the incident
event in INX is with the Job Supervisor.
Where there is no immediate access to INX, a formal initial event notification shall be
completed as an intermediate step. There are several IGO approved initial event notification
formats including:
For remote exploration projects, the initial INX Event Report must be completed by the person
designated as the ‘Sched Phone Operator’ as soon as practical after verbal notification of the
event.
For contractors that do not have access to INX, the IGO representative responsible for the
Contractor must ensure the incident event is recorded and managed in INX.
1
Every electric shock or burn to a person and every dangerous occurrence involving electricity
2
The Exploration Manager is both the Department Manager and Registered Manager for the Exploration Department in circumstances where a
specified Registered Manager is not appointed to an Exploration Project.
An incident is an event where “something happened and there was a consequence”, Near
misses are events “where something happened but there were no consequences” or
“something was about to happen”.
Potential consequence is the worst credible consequence given the same event reoccurred,
(the residual risk rating is applied), Appendix 4 - Classification of near misses and potential
consequence.
IGO’s Injury and illness definitions and statistical reporting requirements are detailed in the
IGO Occupational Injury and Illness Classification and Reporting Procedure. This is
inclusive of non-work related reporting requirements.
The final accountability for a decision regarding safety incident classification rests with the
General Manager of the site (or their equivalent). It is expected that this accountability will be
delegated for routine situations to the HSEC Manager. It is strongly advised that this day-to-
day responsibility is with one (1) person only to ensure consistency in injury classification.
If there is any debate regarding the classification, the issue should then be referred to the
Head of HSEQ & Risk.
Evidence will develop the timeline, or chain of events of what happened based on the
gathered facts. In addition to physical evidence remaining at the scene, preserving evidence
includes:
Note: Human Resources are to be notified in the event IGO is approached by a trade union
representative(s) intending to exercise their right of examining an incident site involving a
member of the specific union.
• Release of the incident scene by line management (and the DMIRS or other statutory
bodies as relevant). Individuals should seek confirmation of this from their Supervisor
if they are unsure
• Completion of the required corrective actions
• Completion of the personal risk assessment process as described in the IGO Safety
Risk Management Procedure
• The conditions that influenced the event (e.g. environment, task design, culture), in
order to change them to prevent reoccurrence
• What influenced the behaviours (in the context of systems and conditions) that were
causal or contributory to the incident i.e. plants, tools and activities can be designed
to reduce mistakes and manage risk better
All investigation teams should act as soon as possible after an incident. The Investigation
Team Leader, in consultation with line management and the site HSEC Manager (or
equivalent) determines the size and composition of the investigation team (where required).
Refer to summary in Appendix 2: Incident Action and Investigation for guidance.
The scale and intensity of effort should be proportionate to the significance of the incident and
the learning potential. Purely basing an investigation on severity may not reveal the factors in
less severe incidents that eventually lead to serious events. The criteria for selecting events
with higher learning value may include:
• Investigation Team Leader who is independent from the immediate area where the
incident occurred
• Facilitator with the skills, experience, operational knowledge and incident investigation
competency
• Workgroup representatives that know how the work is done or the equipment involved
• Site HSEC Advisor depending on investigation type
• Elected Safety Representative for the area depending on incident impacts
• Subject matter experts (technical expertise dependent on the nature of the incident)
• IGO senior management, as required
The Appointed Electrical Supervisor (where applicable) must be a member of the investigation
team for any events involving electricity.
4.6.2 Analysis
Regardless of the investigation methodology adopted for data organisation of the data
collected, the analysis by the investigation team should aim to be:
• Deep, searching for causal and contributing factors or ‘areas of interest’ (if utilising 5
why methodology) based in management systems, leadership and culture as well as
physical and human causes
• Broad, searching for factors that contributed to the event, and missed opportunities to
prevent the event, as well as those things that directly caused it
• Spend sufficient time to understand the causes of the incident
• Explain human behaviour in the context of systems and conditions that apply to many
people, not make a judgement on the individual’s actions or decisions (i.e. understand
the systems and conditions that led the individual into a situation and could lead
others in to the same situation)
− E.g. exploration of Work-As-Done, Work-As-Normal and Work-As-Written
• Theories or hypothesis must be supported by evidence
• Address the root causes, contributing factors (causes can be linked to actions in INX)
or ‘elements of interest’ (if utilising the 5 whys)
• Make resulting actions SMART (Specific, Measurable, Achievable, Relevant,
Timebound) and sustainable
• Apply the hierarchy of controls to assess if recommendations are reliable and
sustainable
Recommendations for discipline or just culture should be avoided as they are not the objective
of the investigation team and have potential to undermine trust in future investigations. Simply
present the facts of what happened and how widespread issues might be. It may be
appropriate to make recommendations to reinforce expectations or standards that weren’t met
during the incident, but decisions on discipline are for the line management of those involved
to decide.
For corrective actions and controls that are either the outcomes of an ICAM investigation or
affects a critical control, once the desired outcome has been achieved through
implementation, monitoring of the system(s) must be ongoing to verify effectiveness.
The Department Manager responsible for the area in which the incident has occurred is
responsible for ensuring that the investigation is completed and monitoring the implementation
of corrective actions within the specified timeframe in INX InControl.
• Early notification that an incident has happened, with minimal details available at the
time (mandatory for Significant Incidents, must be approved by the Registered
Manager)
• Information on a hazard, that can be used to raise awareness / educate and
encourage front-line personnel to take short-term action or change behaviour
• Information that an operating site can use to judge the level of risk presented by a
hazard, and to decide on appropriate action
• Instructions to operating sites to determine level of risk and take action to manage risk
Any of these may be issued as soon as learning from an event becomes clear, including:
• A set of key performance indicators, appropriate to the incident categories noted in this
Procedure, are communicated to the Executive Leadership Team (ELT) and the IGO Board of
Directors
• An annual review and data analysis of incidents and near misses for the incident categories to
identify trends and common lessons
8. ACCOUNTABILITIES
Role Responsibility
• Ensure all incidents and near miss events involving personnel under their
Job Supervisor direction are notified, reported, investigated, recorded and appropriate
corrective actions implemented in accordance with this Procedure
Investigation • Must coordinate the investigation to the appropriate level and engage
Team Leader investigation team members
• Ensures investigations and the associated corrective actions are completed in
a timely manner. This specifically includes data capture in INX
Department
Manager Note (1) The Exploration Manager is both the Department Manager and Registered
Manager for the Exploration Department in circumstances where a specified
Registered Manager is not appointed to an exploration project
9. RELATED DOCUMENTS
Referenced and Related Documentation
• IGO Common Management System Standard 14 – Incident Management
Internal • IGO Occupational Injury and Illness Classification and Reporting Procedure
• IGO Safety Alert Template
• Department of Mines and Petroleum, 2013, Accident and incident reporting —
External guideline (3rd edition): Resources Safety, Department of Mines and Petroleum,
Western Australia.
The following events are listed under the MSI Act 1994 as occurrences to be reported:
In any of these events, the District Inspector for the region should be immediately notified. Notification
should be submitted in a notifiable incident report via SRS but, if the responsible manager considers
that the incident is serious, the written notification should be preceded by a phone call. This must be
done as soon as is practicable after the facts are known.
Notification must be provided regardless of whether an injury occurred, and/or whether or not there was
any damage to property.
Note: A Potentially Serious Occurrence is an IGO classified Serious Potential Incident (SPI). For the
purposes of interpreting this requirement see Appendix 4.
INX must be available for inspection at all reasonable times. Persons authorised by the MSI Act 1994
to inspect or make requests of information contained in INX are:
Under Section 72 of the Environmental Protection Act 1986, IGO is required to notify the CEO of the
Department of Environmental Regulation (DER) regarding the discharge of waste or pollutant spills that
are likely to cause pollution, material environmental harm or serious environmental harm. Discharges
may be a consequence of an emergency, accident or malfunction.
It is a requirement that the DER CEO is notified as soon as practicable by either verbal or electronic
notification, followed by written notification as soon as practicable after the discharge has occurred.
Regulation 5K of the Environmental Protection Regulations 1987 prescribes the details of the
discharge and its impact which are required to be reported to the CEO. The prescribed details are:
• The time and the address of the premises on or from which the discharge occurred
and a map of the premises showing the location of the discharge
• If the discharge of the waste was a result of the operation of equipment or otherwise,
the name of the person operating the equipment or otherwise responsible for the
discharge of the waste
• The composition of the waste
• The quantity of the waste discharged
• Whether or not the discharge caused pollution and if so, the nature and extent of the
pollution
• The action taken by the occupier of the premises to minimize the effect on the
environment of the discharge of waste
• Whether or not the waste involved in the discharge has been removed, dispersed,
destroyed, disposed of or otherwise dealt with, and if so, the manner in which the
waste was removed, dispersed, destroyed, disposed of or otherwise dealt with
When determining the severity and consequence of an environmental incident, the IGO Consequence
Assessment Table should be used (see Appendix 5: Categories of Consequence). For incidents
classified ‘Major’ and above the Environment Department should be contacted to determine which
regulatory agencies may need to be informed.
In addition to reporting electrical occurrence to DMIRS, all electrical accidents must be reported directly
to the Network Operator (if known) or via the Department of Building and Energy (1800 678 198).
• That results from a sudden discharge of electricity or that otherwise has, or is likely to
have, an electrical origin; and
• That causes, or is likely to cause, danger to life, a shock or injury to a person or loss
of or damage to property
Electrical accidents include electric shocks, electrical injuries, fatalities, incidents that cause danger to
life or loss or damage to property (for example damage due to fire or over/under voltage).
Classification Definition
Serious Potential An incident for which the worst credible potential consequence is
Incident determined to be a fatality or permanently disabling injury
An incident for which the worst credible potential consequence is
High Potential
determined to be a Serious Injury (an LTI of greater than 2
Incident
weeks), or a permanent partial disabling injury
All other unplanned safety related event that did not result in
Near Miss
injury, illness, or damage – but had the potential to do so
It is accepted that the evaluation of the potential consequences of a safety incident is inherently
subjective. However, the following matters must be considered:
• The level of damaging energy that was released or potentially released in the incident
• The number of additional controls, checks or processes that would have needed to fail and so
result in impacts on people
Potential Incidents
High Potential Incidents include:
1. All incidents for which the worst credible potential consequence is assessed as being
a Serious Injury (an LTI of greater than 2 weeks), or a permanent partial disabling
injury
2. Those incidents automatically defined as High Potential Incidents (HPIs) below:
Not all SPIs are reportable to the authorities as per local law (e.g. those risk rated ‘Major’ or lower).
Where the likely potential outcome is risk rated ‘Catastrophic’, i.e. a fatality, permanently disabling
injury, irreversible or widespread health impacts the SPI must be reported to DMIRS.
Type of Consequence
Financial Loss or
Health Safety Environment Community & Reputation Compliance
Exposure
• Very serious widespread social impacts causing site
closure
5 - Catastrophic
material - no symptomatic disease • Serious Injury (LTI of greater than • between $10M to $100M
• A material threat to listed species • Protestors on IGO property as identified by a Company officer
• A localised outbreak of infectious 2 weeks) • loss of between 15% and
• Destruction or a credible risk of • External arbitration required requiring disclosure and for which no
disease among numerous employees. • Permanent partial disability 25% market capitalisation
destruction of listed biological • Limited short-term national media focussing on the immediate remedy is available, or
• Numerous employees demonstrate
communities Company activities or impacts • Breach of Code of Conduct, or
Severity of Consequence
• Chronic exposures that require an • A credible threat to listed species or • Infringement/disregard of cultural heritage/sacred • between $500k to $10M
as identified by Company officer for
extended period (> 2 weeks) of alternate • Lost time injury (LTI) ecosystems locations • attributable loss of market
which no immediate remedy is
duties to alleviate symptoms. • Nuisance impact (e.g. dust, noise) • Strong community complaints/reaction: a threat to capitalisation but <15%
available (> 1 month), or
to neighbours resulting in a operations; small scale protests near operating sites
• Major non-compliance with Company
complaint(s) or investigation by a • Isolated national media on the event
policy or procedures
Regulator • Local media attention
• Injury requiring medical treatment • Significant environmental impact • Minor social/cultural impact than a month to remedy, or
• Exposures that require a short period (MTI) and/or (between 1 and 10 ha) within IGO • Damage or loss of minor community asset • Statutory non-compliance identified
(<2 weeks) of alternate duties to alleviate • An injured person required to property. • Minor infringement of cultural heritage • between $20K to $500K by Company officer requiring external
symptoms complete alternative or restricted • Impact to flora/fauna localised and • No media coverage or some isolated local media disclosure
work duties (RWI) contained (single animals and plants) discussion • Non-compliance with Company
policy or procedures, requiring more
than a month to remedy