Incident Reporting Investigation Fy19 20 Aug 20

Incident Reporting, Notification, and
Review Procedure
1. Purpose and Scope
1.1. The purpose of this procedure is to require incident reporting and notification
and to aid the University of Notre Dame in preventing or mitigating future
incidents through the use of an incident investigation process. Incident
investigations require identifying incident causes and developing corrective
actions that address those causes.
1.2. This procedure applies to all workplace injuries/illnesses, environmental

releases, and near misses that occur with faculty, staff, students, and visitors at
the University of Notre Dame.
2. Responsibilities
2.1. Faculty, staff, and student employees shall comply with this procedure, report
all incidents in a timely manner including property damage or near miss events
regardless of the extent of incident, and participate in the incident investigation
process as appropriate.
2.2. Deans, Provost, Department Heads, Center/Institute Directors, or Designees

shall:
2.2.1. Enable enforcement of these requirements and take prompt, effective
corrective action when necessary.
2.2.2. Identify resources needed to address risk mitigation efforts that exceed
the ability of the responsible personnel.
2.2.3. Make appropriate notifications of incidents occurring in their college,
center, department, unit, etc.
2.3. Department Managers, Supervisors and others in supervisory roles shall:

2.3.1. Ensure all personnel reporting to them receive communication that this
procedure shall be adhered to within their area(s) of responsibility.
2.3.2. Implement immediate corrective actions such as retraining if it is
discovered that this procedure is not being followed.
Approval Date: January 2017 Incident Reporting, Notification, & Review Procedure SAFE016
Revision Date: August 2020 Owner: Director, RMS
Page 1 of 22
2.3.3. Participate in all incident investigations that occur within their area of
responsibility or that occur to personnel reporting to them.
2.3.4. Make appropriate notifications within their organization of incidents
occurring in their area of responsibility.
2.3.5. Ensure the Safety Incident Reporting form is completed for all workplace
injury accidents occurring to personnel working for them.
2.3.6. Assign training as required by this procedure.
2.4. ND Police / Fire shall:

2.4.1. Make appropriate external notifications as required by local, state, or
federal mandate.
2.4.2. Make internal notifications to ensure the appropriate level of University
leadership is notified.
2.4.3. Inform Risk Management & Safety (RMS) or the RMS on-call staff
member during off-hours of all incidents, as required by this procedure.
2.4.4. Take control and/or command of an incident scene depending on type and
severity.
2.4.5. Facilitate or participate in incident investigations and root cause analysis
(RCA) of incidents pertinent to their area of expertise.
2.4.6. Input incident reports into the On-Base system when complete.
2.5. Risk Management and Safety (RMS) shall:

2.5.1. Make appropriate external notifications as required by local, state, or
federal mandate.
2.5.2. Make internal notifications to ensure the appropriate level of University
leadership is notified.
2.5.3. Maintain Federal and State record keeping requirements.
2.5.4. Assign incident investigations in accordance with this procedure.
2.5.5. Facilitate or participate in incident investigations and root cause analysis
involving incidents pertinent to their area of expertise.
2.5.6. Coordinate the incident investigation program and provide technical
expertise as necessary.
2.5.7. Assist in developing Safety Alerts and forwarding them to affected groups.
2.5.8. Track incident report corrective actions to closure.
2.5.9. Report incident information and the status of open corrective actions to
University leadership.
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2.5.10. Notify the Wellness Center at (631-2371) of any work-related injury
resulting in transportation to an emergency room when the Wellness
Center may not have knowledge of the incident.
2.6. The University Health Services (St. Liam’s Hall) shall contact RMS as soon as
reasonably possible after any incident that may warrant an investigation (e.g.
student injured in a lab, student fall from height).
2.7. The Wellness Center shall contact RMS within one hour or as soon as
reasonably possible after any University employee reports a work-related Tier 1
or Tier 2 injury, illness or campus accident.
3. Definitions
3.1. Accident – An unplanned work-related event resulting in injury or illness,

equipment or property damage, or an environmental release. An accident does
not necessarily include equipment failures that are the result of electrical,
mechanical or structural failures not caused by human intervention and that are
controlled by system shutdown, malfunction or safety devices.
3.2. Critical Infrastructure – Systems and assets, whether physical or virtual, vital to
the safety and health of ND faculty, staff, students, visitors, or contractors and
the continuity of research, teaching, or business operations. Examples of
critical infrastructure include:
● Electrical (generation, transmission and distribution).
● Telecommunication (phone, internet, etc.).
● Water (chilled water, potable water, wastewater/sewage and storm
water).
● Heating (steam, condensate, and natural gas).
3.3. Environmental Release – An unplanned release of chemical, biological,

radioactive materials, or petroleum products to the air, water, or ground.
3.3.1. Water is defined as any natural (above or below ground) or manmade
waterways, e.g., lakes and sewer systems.
3.3.2. The ground is defined as soil, outdoor paved area, or uncontained areas
inside buildings such as floors, bench tops, etc. Spills inside buildings
include releases that could have resulted in contamination to the air, water
Page 3 of 22
(e.g., sewer), or soil. Secondary containment areas such as a dike or
laboratory ventilation hood are not included in this definition.
3.4. Incident – An event that either did or could have (near miss) resulted in injury or
illness, equipment or property damage, or an environmental release.
3.5. Near-miss (good catch) – An unplanned work-related event or condition that

could have reasonably resulted in injury or illness, equipment or property
damage, or an environmental release. A near-miss can be any severity tier.
3.6. Root Cause(s) – Personal or job factors that allow unsafe behaviors to occur or
unsafe conditions to exist.
3.7. Reportable Environmental Release – Any release of a hazardous substance to

the environment in an amount equal to or greater than a regulatory reportable
quantity. A release is defined as any spilling, leaking, pumping, pouring,
emitting, emptying, discharging, injecting, escaping, leaching, dumping, or
disposing into the environment.
3.8. Student Employee – Any student who receives compensation from the
University of Notre Dame for performing work activities.
3.9. Tier 1 (Critical Incident)

3.9.1. Any incident resulting in:
● A fatality on University of Notre Dame property.
● A fatality to a University of Notre Dame faculty, staff, or student while
traveling on University business.
● A fire, explosion or other failure reasonably expected to cause greater
than $25,000 in loss or results in the cancellation of multiple classes,
research activities, or a major campus activity.
● Critical infrastructure failure affecting daily operations. This is not
intended to necessarily include end-of-service life failures (e.g. pump,
water main, etc.).
● National media attention.
3.9.2. Police or security events resulting in:
• Shots being fired (does not include training or animal euthanasia).
• Life threatening incident.
Page 4 of 22
• University property damage or theft reasonably expected to cause
greater than $25,000 in loss.
• Large disturbance or riot with significant impact to University operations.
3.10.Tier 2 (Significant Incident)
● A life threatening or serious work-related injury, illness, or accident
resulting in hospitalization amputation, or loss of an eye or a near-miss
that could have resulted in these outcomes.
● A faculty, staff, or student exposure to a biological Class 3 or
unprotected contact (e.g., needle stick with a Class 2 biological hazard).
● A fire, explosion or other failure reasonably expected to cause between
$5,000 and $25,000 in loss or any extended interruption of teaching,
research, or other activities.
● A fire resulting in the discharge of a fire suppression system or the use
of a fire extinguisher to control or extinguish the fire.
● A reportable environmental release to the air, water, or soil.
● On-scene local media attention.
● Regulatory agency contact.
● Threats to public health that could impact the larger community (e.g.
communicable disease or foodborne illness outbreak).
3.10.2. Police or security events:
● Property damage or theft resulting in $5,000 to $25,000 in loss or any
extended interruption of teaching, research or other activities.
3.11.Tier 3 (Minor Incident)

● Faculty, staff, or student injury or illness requiring medical treatment or
evaluation at a medical facility.
● Faculty, staff, or student injury or illness not requiring evaluation at a
medical facility or one that was self-treated.
● Fire or other failure reasonably expected to cause less than $5,000 in
loss.
● Police or security events not listed as Tier 1 or Tier 2.
4. Incident Reporting
4.1. Injury / Illness (Refer to Appendix E for flow chart)
Page 5 of 22
4.1.1. In the event of a work-related injury or illness requiring treatment,
personnel are required to immediately seek medical evaluation.
• For injuries or illnesses requiring emergency medical care, call 911 (from
a campus phone) or 574-631-5555 (from a mobile phone) to receive
emergency medical response from the Notre Dame Fire Department
(NDFD).
• If emergency transport to the emergency room or Wellness Center is
necessary or requested, NDFD shall evaluate to determine the
appropriate mode of transportation and ensure transport is provided.
• If emergency transportation to an emergency room is required for a
member of the general public injured at the University of Notre Dame,
NDFD shall evaluate to determine the appropriate mode of
transportation and ensure transport is provided.
• For minor injuries or illnesses incurred during work hours or University-
sponsored events, faculty, staff, or student employees shall contact their
supervisor, if able, and report to the Wellness Center. If after hours, use
the Wellness Center’s on-call option by calling 574-634-9355 and
selecting the on-call option. As a final alternative, seek treatment at the
St. Joe Regional Medical Center (SJRMC) Emergency Room. Contact
NDFD for assistance.
4.1.2. Faculty, staff, and student employees shall report all incidents to their
immediate supervisor or designee (Example: Department/Unit Head, PI,
Lab Manager, Supervisor, etc.) immediately upon discovery or
knowledge of an incident or after receiving medical attention.
4.1.3. Upon notification of an incident, the supervisor shall ensure that the
condition, hazard, or area is isolated or the hazard is eliminated to prevent
further incident(s).
4.2. In event of a fire, any environmental spill or release, or security matter,

employees shall contact NDPD at 911 (from a campus phone) or 574-631-5555
(from a mobile phone) or activate the building fire alarm as appropriate.
4.3. Campus Safety Notification Requirements

4.3.1. Tier 1 (Critical Events)
• NDFD or NDPD shall immediately notify the VP of Campus Safety &
University Operations and RMS.
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• The VP of Campus Safety & University Operations shall immediately
notify:
➢ Executive Vice President,
➢ Provost,
➢ VP of Communications (for campus notification as deemed appropriate
by the VP of Communications), and the
➢ Division VP or Office of Research / Dean of the area involved.
4.3.2. Tier 2 (Significant Incident)
• NDFD or NDPD shall notify the VP of Campus Safety and RMS as soon
as practical.
• The VP of Campus Safety shall notify the following individuals as soon
as practical during business hours:
 Executive Vice President, and the
 Division (A)VP or Dean of the area involved.
4.3.3. Tier 3 (Minor Incident)
• RMS shall notify department heads of recordable injuries.
4.4. Department Notification Requirements:

4.4.1. Tier 1 (Critical Events): The manager or supervisor shall immediately
inform the VP/Dean, department head, center/institute director, or
department/unit manager for incidents within their area of responsibility.
4.4.2. Tier 2 (Significant Incidents): The manager or supervisor shall inform
the appropriate department head, center/institute director, department/unit
manager as soon as reasonably possible.
4.4.3. Tier 3 (Minor Incident): The manager or supervisor shall inform the
appropriate department head, center/institute director, department/unit
manager or designee of the incident within one business day of incident
knowledge.
4.4.4. If a Department Safety Coordinator is informed of an incident, he/she will
initiate notifications as indicated above.
5. Incident Investigations Requirements
5.1. An investigation shall be conducted for all Tier 1, 2 and 3 incidents.

Investigations of near-miss cases may be assigned depending on the incident’s
severity.
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5.1.1. Incidents shall be investigated following this procedure or as directed by
Campus Safety.
5.1.2. Fire investigations shall be directed by NDFD.
5.1.3. Police/security events shall be investigated as directed by NDPD.
Examples include: Campus crimes, motor vehicle crashes, and public or
residence accidents.
5.2. Incident investigations shall be initiated as soon as reasonably possible

following the event or upon receiving knowledge that an event has occurred.
5.3. Except as noted in 5.1.2 and 5.1.3 incident investigations shall have a
documented root cause analysis with corrective actions addressing the causes
(Appendix C). The VP of Campus Safety & University Operations has the
authority to suspend this requirement.
5.4. Reporting format.

5.4.1. Except as noted in 5.1.2 and 5.1.3, all incident investigations shall be
documented in the On-Base system using the Investigation Complete
Form.
5.4.2. Due to their complexity, the following incidents shall be documented using
the Incident Investigation Report (Appendix D or similar format) and
attached to the On-Base form:
• Tier 1 and 2 incidents.
• Injuries incurring lost time.
• Recordable injuries that occur in a lab.
• Other incidents deemed necessary by RMS.
5.5. Investigation Process (Refer to Appendix E for Tier 1 & 2 process flow chart)
5.5.1. A team approach shall be used when conducting internal incident
investigations.
5.5.2. Criminal or fire incident investigations shall be managed by the jurisdiction
having authority.
5.5.3. Tier 1 (Critical Incidents) and Tier 2 (Significant Incidents)
• For fire and police incidents, the scene shall remain secured until it is
approved for access by NDFD / NDPD. Only at that time will NDFD /
NDPD permit key personnel entry for fact finding. Key personnel shall
be identified by Campus Safety.
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• The incident investigation shall be led by Campus Safety personnel or by
others at the request of Campus Safety.
• All photographs used as evidence for Tier 1 incidents shall be taken by,
or at the direction of, NDPD.
• Once evidence is gathered and the scene is safe, the area may be
released to the department or area owner (manager, supervisor, etc.).
Every effort will be made to return the area back to the owning
department/unit as quickly as possible
• The incident investigation team shall include (at a minimum) the area
supervisor or the employee’s immediate supervisor/manager and
Campus Safety. At least one team member shall have knowledge of the
process involved. The employee(s) involved in the incident shall not be a
member of the team.
• The team shall conduct the investigation to determine the incident’s root
cause(s) and identify corrective actions to prevent recurrence.
• The team leader shall provide daily progress reports to the VP of
Campus Safety & University Operations for Tier 1 (Critical Incidents) and
other incidents as identified by the VP of Campus Safety & University
Operations.
5.5.4. Tier 3 (Minor Incidents)

• It is required that the Manager or Supervisor responsible for the
employee or the Manager or Supervisor responsible for the area where
the incident occurred initiate/lead the incident investigation.
• The team leader shall identify team members. At least one team
member shall have knowledge of the process involved. The employee(s)
involved in the incident shall not be a team member.
• The team shall conduct the investigation to determine the incident’s root
cause(s) and identify corrective actions to prevent recurrence.
5.5.5. Fact Finding

• The incident investigation shall be conducted as a fact-finding exercise
and not as a fault-finding mission.
• The incident scene shall be visited as quickly as possible to collect and
document evidence.
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• The incident area shall be carefully controlled. In some cases, it may be
necessary to isolate and/or barricade the area pending the investigation.
Contact NDPD as necessary for scene control.
• In some cases, pictures, diagrams, and other means should be taken to
record evidence.
• Interviews shall be conducted with personnel involved in the incident,
including witnesses, as soon as possible. These interviews should be
conducted with each person individually and be documented. If a
person involved in the incident is not immediately available, he/she
should be interviewed as soon as practical or be asked to write their
statements and provide to the lead investigator.
• Evidence for Tier 1 incidents shall be secured by NDPD or the authority
having jurisdiction. Evidence for Tier 2 and 3 incidents shall be retained
at the discretion of the team leader.
5.5.6. Corrective Actions

• Specific corrective actions shall be developed to address the incident’s
root causes so that similar events can be prevented.
• Each corrective action shall include the name of a person responsible for
completing the item and a target date.
• Where feasible, corrective actions shall be developed using the following
hierarchy of controls:
➢ Elimination of process or activity,
➢ Substitution of less hazardous materials, processes, operations or
equipment,
➢ Engineering controls (i.e. redesign, machine guards, ventilation
systems),
➢ Warnings and Administrative controls (i.e. signage, changes to work
procedures, training, job planning, rotating and scheduling), and
➢ Personal protective equipment (e.g., hearing protection, gloves).
5.5.7. Written Report

• All workplace injuries shall be documented using the RMS Safety
Incident Report (See Appendix A). This shall be completed by the
Manager or Supervisor responsible for the employee within 48
hours of the injury or knowledge of the injury.
Page 10 of 22
• Investigations shall be completed within five (5) business days of the
investigation being assigned.
• Tier 1 (Critical Incidents) and Tier 2 (Significant Incidents) investigations
shall be documented using the Incident Report Form (Appendix D).
Campus Safety leadership may elect to use a different investigation
process for certain events.
• All incident investigations shall be entered in the On-Base system using
the Investigation Complete Form (Appendix B). Appendix C (Root Cause
Analysis Forms) defines root cause categories and provides formats for
documenting the investigation’s root cause analysis.
• For investigations requiring additional time, the departmental Safety
Coordinator or the manager/supervisor responsible for completing the
report shall notify the Department Head / Manager and RMS. A reason
for the delay and expected completion date shall be provided.
5.6. Communication – In order to create an atmosphere of information sharing and

learning, a safety alert shall be created for all Tier 1 (Critical Incidents). The
safety alert shall be disseminated to affected departments by RMS and posted
on the RMS web site.
5.7. Contractors, Minors, Volunteers, Visitors, and Visiting Researchers

5.7.1. Contractors – Contractors shall be instructed to report all incidents to their
ND project manager or contact. The ND project manager shall perform
notifications as outlined in this procedure and consult with University of
Notre Dame legal counsel on Tier 1 events prior to taking action. If
counsel supports, the ND project manager or contact shall ensure all Tier
1 events are investigated by the contractor company and the incident
report is provided to RMS.
5.7.2. Minors, Volunteers, Visitors, and Visiting Researchers – The ND individual
responsible for the minor, volunteer, visiting researcher, or visitor shall
ensure that medical treatment is sought if needed. Reporting and
investigations shall follow as directed in this procedure.
6. Training
6.1. Supervisors shall be trained initially and every two years thereafter on how to
conduct and document incident investigations. Supervisor training is available
through complyND (RMS-Conducting Incident Investigations).
Page 11 of 22
6.2. Employees shall receive annual training on the provisions of this procedure.
Training shall minimally include seeking medical treatment and reporting
requirements. Training is available on complyND (RMS-Incident Reporting and
Access to Medical Records).
7. Audit and Program Review
7.1. RMS shall perform a documented annual program evaluation.
7.2. The annual evaluation shall include a review of the following:

● This procedure to determine if it is complete and current.
● Appropriate incident reports and injury logs to determine if reports were
completed for all required cases.
● Incident Investigation Reports to ensure their accuracy, including: (a)
root-cause identification, (b) identification and completion of corrective
actions.
● Training records to determine if all required training was appropriately
conducted and attended.
7.3. All actions that are necessary to improve the process shall be documented and
acted upon.
8. Records required by this procedure shall be retained per the University’s records
retention schedule. This includes:
8.1. Incident Investigations (including evidence)
8.2. Audit and program review documentation.
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Revision History
History Effective Date

Procedure published January 2017
Procedure revised
• Modified injury tiers (3.9 – 3.11)
• Formalized RMS responsibility for notifying
departments of recordable injuries (4.3.3)
• Specified that near-miss incidents may require
investigation (5.1) April 2020
• Clarified incident investigation documentation (5.4)
• Updated incident investigation team composition
(5.5.3, 5.5.4)
• Updated links to current On-Base forms
Procedure revised
• Added discharge or a fire suppression system or
August 2020
extinguisher to Tier 2 incidents (3.10.1).
Page 13 of 22
Appendix A
Safety Incident Reporting Form
Link to Form: Safety Incident Reporting Form
Page 14 of 22
Appendix B
Investigation Complete Form for Safety, Environment, Good Catch
Link to Form: Investigation Complete Form for Safety, Environment, Good Catch
Page 15 of 22
Appendix C
Root Cause Analysis Forms
Management System Root Cause Worksheet
The management system deficiencies below should be used to help identify and categorize
the causes from a “Why Tree”. Compare the root causes to the “Explanation” column, if the
statement is true, identify that “Category” in the Management System Root Causes
section of the Incident Investigation of the On-Base form.
Multiple Root Causes and Categories are Acceptable and Likely

Category Explanation
Responsibility and Responsibility was not properly assigned or personnel were not
Accountability held accountable to their responsibilities.
Planning or a risk assessment was not conducted or inadequate.
Planning and Risk
The assessment did not include applicable life cycle phases or
Assessment
process verification.
The resources (personnel, equipment, time, etc.) were not
Resources
adequate.
The current design was not analyzed for risk therefore it used
Design Review and
incorrect specifications & was built so that it was inadequate for
Management of
the intended service. A change occurred without proper review
Change
or analysis to implement effective controls.
The risk reduction controls (including elimination, engineering
Controls controls, warnings, administrative, or PPE) were not proper for
the task either due to not being properly identified or specified.
Equipment & The equipment, parts, or materials procured created a hazard or
Materials were not as analyzed for risk, were defective, or did not meet the
Procurement specifications.
The contractor safety program was not established or was
inadequate to identify, evaluate, and control health and safety
Contractors
risks from contractor activities or to the contractors from the
organization’s activities.
Emergency A process was not developed or was inadequate to identify,
Preparedness prevent, prepare for, and/or respond to emergencies.
Training was not available, timely (initially or refresher) or not
Training
adequate or verified to be effective to achieve requirements.
Communication was ineffective due to no communication; late
Communication
communication, no shift change process or process not used.
Page 16 of 22
Inspections & PM were not in accordance with procedures,
Inspections,
manufacturer’s or experience-based recommendations or
Assessments &
governing standards & were not adequate for the conditions.
Preventative
Exposure assessments or occupational health assessments
Maintenance
were not conducted as required or did not identify the risks.
Documents and The required documents (procedures) were not developed or
Records maintained.
Incident The incident investigation process is not in place or did not
Investigations investigate or analyze previous similar events.
The corrective and preventative action process was not
Corrective and implemented or did not address non-conformances, hazards, or
Preventative Actions new hazards to an acceptable risk level. The process did not
ensure effectiveness of corrective and preventative actions.
Personnel actions, activities, and decisions were not in
Human Actions accordance with procedures, training, or standards. Examples:
Taking shortcuts, Deliberate violation of procedure, Horseplay.
Page 17 of 22
Why Tree Form
Page 18 of 22
5 Why Form
Define the Problem
1. Why is
That?
2. Why is
That?
3. Why is
That?
4. Why is
That?
5.
Page 19 of 22
Appendix D
Incident Report Form
Incident Investigation Report

University of Notre Dame
Location:
Department:
Manager or Supervisor:
Date/Time of Incident:
Date Incident Discovered:
Type of Incident:
Date Investigation Began:
People Interviewed:
Team Members:
Description of Event:
Time Line of Events:

Date Time Event
Findings / Information:
Root Causes:
Corrective and Preventive Actions:
Responsible
Action Target Date
Person
Approvals:
Name Signature Date
Page 20 of 22
Appendix E
Flow Charts
Page 21 of 22
Page 22 of 22

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Incident Reporting, Notification, and

1. Purpose and Scope

1.2. This procedure applies to all workplace injuries/illnesses, environmental

2.2. Deans, Provost, Department Heads, Center/Institute Directors, or Designees

2.3. Department Managers, Supervisors and others in supervisory roles shall:

2.4. ND Police / Fire shall:

2.5. Risk Management and Safety (RMS) shall:

3.1. Accident – An unplanned work-related event resulting in injury or illness,

3.3. Environmental Release – An unplanned release of chemical, biological,

3.5. Near-miss (good catch) – An unplanned work-related event or condition that

3.7. Reportable Environmental Release – Any release of a hazardous substance to

3.9. Tier 1 (Critical Incident)

3.11.Tier 3 (Minor Incident)

4.1. Injury / Illness (Refer to Appendix E for flow chart)

4.2. In event of a fire, any environmental spill or release, or security matter,

4.3. Campus Safety Notification Requirements

4.4. Department Notification Requirements:

5. Incident Investigations Requirements

5.1. An investigation shall be conducted for all Tier 1, 2 and 3 incidents.

5.2. Incident investigations shall be initiated as soon as reasonably possible

5.4. Reporting format.

5.5.4. Tier 3 (Minor Incidents)

5.5.5. Fact Finding

5.5.6. Corrective Actions

5.5.7. Written Report

5.6. Communication – In order to create an atmosphere of information sharing and

5.7. Contractors, Minors, Volunteers, Visitors, and Visiting Researchers

7. Audit and Program Review

7.1. RMS shall perform a documented annual program evaluation.

7.2. The annual evaluation shall include a review of the following:

8.1. Incident Investigations (including evidence)

8.2. Audit and program review documentation.

History Effective Date

Link to Form: Safety Incident Reporting Form

Management System Root Cause Worksheet

Multiple Root Causes and Categories are Acceptable and Likely

Define the Problem

Incident Investigation Report

Time Line of Events:

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