2.5 Monitoring, Accident Investigation, NADOPOD Reporting, Record Keeping & Audit

Monitoring: knowing whether controls work

Planning and controls are only half of a management system. ISO 45001 clause 9 calls the other half performance evaluation: monitoring, measurement, analysis and evaluation, internal audit and management review.

Good sites track leading indicators, such as the percentage of inspections completed, the number of near misses reported and closed, and toolbox attendance. They also track lagging indicators, such as lost-time injuries. Where hours worked are known, an injury frequency rate is often calculated as (number of lost-time injuries x 1,000,000) / total hours worked.

NADOPOD 2004: what, when and how

Section 32 of OSHA 1994 requires notification. The NADOPOD Regulations 2004 (P.U.(A) 128/2004) give the details.

DOSH's NADOPOD guideline names the forms: JKKP 6 for notifying accidents and dangerous occurrences, JKKP 7 for occupational poisoning and disease, and JKKP 8 for the register. JKKP 8 records every case during the year, from minor cuts to fatalities, and is summarised for the annual return.

Serious bodily injury (First Schedule)

The First Schedule lists 11 categories, including:

• loss of a limb or joint
• fracture or dislocation of a bone
• permanent loss of sight or hearing in one eye or ear
• loss of consciousness from lack of oxygen or from absorbing, inhaling or ingesting a substance
• any work-related injury or burn requiring immediate admission to hospital for more than 24 hours

Construction-relevant dangerous occurrences (Second Schedule, Part I)

• Collapse or partial collapse of a scaffold more than 5 metres high that causes a substantial part to fall or overturn (item 1)
• Collapse or partial collapse of any part of a building or structure under construction, reconstruction, alteration or demolition, or of any temporary support, unless intended (item 2)
• An electrical short circuit or overload with fire or explosion that stops the plant for more than 24 hours (item 3)
• An uncontrolled release of a substance that could cause serious injury or damage to health (item 4)
• Explosion, fire or structural failure affecting the safety of a workplace or plant (items 5 and 6)
• Collapse, overturning or failure of a load-bearing part of a crane, derrick, winch, hoist, piling frame, lift, excavator or other lifting appliance (item 11)

Records and penalties

• Register: every employer and self-employed person keeps a register of all accidents, dangerous occurrences, poisonings and diseases, whether or not they were reportable (regulation 10(1)). Entries are kept for at least 5 years (regulation 10(2)), and an extract covering the year to 31 December is sent to the Director General before 31 January (regulation 10(3)).
• Penalty: contravening NADOPOD carries up to RM10,000 or one year or both (regulation 13).

Preserving the scene

Regulation 9 says that after an accident or dangerous occurrence causing death, serious bodily injury, or serious damage to plant or property, no person may disturb or interfere with any plant, substance or article involved unless authorised to do so, except as far as necessary to:

1. save life, prevent injury or relieve suffering
2. maintain public access to an essential service or facility
3. prevent further damage to property or the environment, or serious loss

In practice the SSS:

• makes the area safe without destroying evidence
• barricades the area and posts a guard
• photographs and sketches the scene
• lists witnesses
• impounds failed items such as slings, harnesses and couplers

Investigating to root cause

Four phases

1. Respond: give first aid, call emergency services, make the area safe, preserve the scene, and notify management and DOSH.
2. Gather evidence: use the "4P" checklist:
   • People: separate, early, open-question interviews with the injured person and witnesses
   • Position: measurements, photographs, weather and lighting
   • Parts: equipment, PPE and failed components, tagged and secured
   • Paper: HIRARC, method statement, permit, inspection records, certificates of fitness, training and competency records
3. Analyse causes with structured tools.
4. Act: define corrective and preventive actions, assign owners and dates, update HIRARC and procedures, share lessons, and verify effectiveness.

Levels of cause

5 Whys: keep asking "why?" until you reach a management system cause that, if fixed, prevents recurrence.

Fishbone (Ishikawa) diagram: group causes under people, plant and equipment, methods, materials, environment and management.

Avoid ending an investigation at "worker careless". As Section 2.2 explains, that describes the act, not the cause.

Records an SSS should know

Audit

An OSH audit is a systematic, independent and documented examination of whether the OSH management system meets its planned arrangements and criteria, such as ISO 45001, the client's requirements, the construction phase plan or the law, and whether it is effective.

A typical internal audit cycle:

1. plan the scope and criteria
2. hold an opening meeting
3. review documents
4. sample site evidence and interview staff
5. grade the findings
6. hold a closing meeting
7. issue the report
8. follow up corrective actions until they are closed

SHC Regulations regulation 15(b) requires the committee to consider safety audits submitted to it. Audit results also feed the PDCA Act stage.