IMS-PRO-002 VER 01 - Incident Reporting & Investigation Procedure

INCIDENT REPORTING &
INVESTIGATION PROCEDURE
Page 1 of 30 Date of Revision: 16-04-2021 IMS-PRO-002-VER 01

Document Issue Document
Issue Compiled By Approved by
Date Owner
Members of Rules & Chairman, Rules & Chairman, Rules &
00 02-06-2016 Procedures Sub- Procedures Sub Procedures Sub
Committee Committee Committee
Document Revision No. Revision Date Standard Document No.
0 02-06-2016 IMS-PRO-002
1 16-04-2021 IMS-PRO-002-VER 01
User Notes: - Controlled copy of the current version of this document is held at DLF Connect
Portal. Any printed / electronic copy of this document is uncontrolled. It is recommended that users
verify that they are using the latest version of the document at all times.
This document contains proprietary and confidential information of DLF Rentco and is intended solely
for the internal use of authorized Personnel. It should be treated as BUSINESS CONFIDENTIAL and
its external use or disclosure, unless specifically authorized is strictly prohibited.
* Procedure compiled by –
S. No Team Members DLF / FM S. No Team Members DLF / FM
1 Vikram Choube DLF 18 Manoj Chaudhary JLL
2 Venu Goud DLF 19 Vikas Yadav C&W
3 KVM Nagendra DLF 20 S Kalyan Kumar CBRE
4 Jitesh Nichani DLF 21 DP Singh DLF
5 Ramesh Chandra Joshi DLF 22 Govind Pillai CBRE
6 Kapil Shandilya DLF 23 S Thanigavel CBRE
7 Sujit Kumar DLF 24 Tejpal Aggarwal C&W
8 Sunil K Bhaduria DLF 25 Amit Kumar C&W
9 Dhiraj Singh DLF 26 Rajesh Kumar C&W
10 Nilesh Aakash Gokhe DLF 27 Kaushik Lahiri CBRE
11 KVM Nagendra DLF 28 Sumit Chaudhary CBRE
12 Hitesh Sitlani DLF 29 Sudipta Mukherjee CBRE
13 Pritam Kundu DLF 30 Ahmed Gufran JLL
14 Ashok Yadav DLF 31 Devender Khandelwal JLL
15 S Ramesh DLF 32 Paras Bhatnagar Lodhi
16 M Srinivasrao DLF 33 CM Tiwari Lodhi
17 K Sivakumar DLF 34 Piyush Chaudhary DLF

Table of Contents
S.No. Topic Page
1.0 Introduction 6
1.1 Intent and Purpose 6
2.0 Scope and field of application 6
2.1 Scope 6
2.2 Application 7
3.0 References 7
4.0 Responsibilities 7
5.0 Definitions 9
6.0 Investigation Process 11

6.1 Initial Response and Reporting 12
6.1.1 Initial Response 12
6.1.2 Initial Reporting 12

6.1.3 Classifying Incidents 12
6.1.4 The time limit and responsibilities for communicating all incidents 12
6.2 Formation of Incident Investigation Team 14
6.3 Determining Facts 15
6.4 Determining Key Factors 16

6.5 Determining the Systems to be Strengthened 16
6.6 Recommending Corrective and Preventive Actions 16
6.7 Documenting and communicating the findings 17
6.7.1 Documenting of Final Incident Investigation Report 17
6.7.2 Communication of learning 17
6.7.2.1 Communication with the facility 17

6.7.2.2 Communication beyond the facility 17
6.8 Follow-up 17
7.0 Management Systems 18

7.1 Support Resources 18
7.2 Management Records 18

7.3 Audit Requirements / Performance Metrics 18
7.4 Procedure Renewal Process 18

7.5 Deviation Process 18
7.6 Training and Communication Requirements 18

7.7 Contact 18
8.0 Retention Period 19
Annexure
Annexure -1: Incident Investigation Flow Chart 20
Annexure -2: Initial Incident Report Format 22
Annexure -3: Guidance for determining Key Factors 23
Annexure -4: Incident Investigation Report Format 26
Annexure -5: Incident Investigation – Action Taken Report (ATR) 30
Annexure -6: Incident Loss Damage Analysis 30
Abbreviations:
• DISH - Director Industrial Safety & Health (known as Factories Inspectorate)
• HOD - Head of the Department
• EHS -Safety, Health and Environment
• ER - Employment relations
• ERT - Emergency Response Team
• F - Fatality
• FAC - First Aid Case
• FH -Functional Head.
• FLE - Front Line Engineer

• IIR -Initial Incident Report
• IISC - Incident Investigation Sub-Committee
• IS - Indian Standards
• LWC - Lost Workday Case
• MTC - Medical Treatment Case
• NA -Not Applicable
• NMC - Near Miss Case
• NR -Not Required
• OHS - Occupational Health Services
• OTJ -Off the Job
• PPE - Personal Protective Equipment
• RA -Responsibility and Accountability
• RCFA –Root Cause Failure Analysis
• RWC - Restricted Workday Case
• SH -Section Head
• SI -Shift In-Charge
• UH -Facility Head
• CHS -Corporate Head Safety
• CMO -Chief Medical Officer
• SWP -Safe Work Procedure
• JSA - Job Safety Analysis
• L.I.F.E - Learning and Improving From Experience
• FM - Facility Management
• SPOC – Single Point of Contact
• KAM - Key Account Manager

1.0. Introduction
DLF RENTCO believes in conducting all its activities in a safe and environment friendly manner
to avoid harm to all interested parties. One important process that supports the drive towards this
goal is the Reporting and Investigation of Incidents. It is essential that lessons are learnt from past
incidents and measures are taken to prevent recurrence of incidents. Therefore, it is important
that all incidents are reported and thorough investigations are carried out in a scientific manner to
determine the key factors (physical, human and systems) that contributed to the incident so that
corrective and preventive actions are taken for continual improvement of the Occupational Health
,Safety and Environment Management system.
1.1 Intent and Purpose
This procedure is developed to outline the process for reporting, recording and investigating an
incident, recommending corrective and preventive actions and to communicate the lessons
learned to prevent recurrence of similar incidents in facilities across DLF Rentco.
The intent is to ensure that there is no ambiguity while reporting, classifying incidents, and injuries,
illnesses, providing immediate response, and investigation. It covers roles and responsibilities of
all personnel associated with Incident Investigation as well as the methodology required to
investigate effectively.
2.0. Scope and field of application

2.1 Scope:
This procedure is intended to provide a systematic, in-depth approach of incident investigation on

health, safety, and environmental including fire, with an emphasis on the following:
1. Management Responsibilities
2. Selection of the investigation team
3. Investigation process
(i) Loss Damage Analysis
4. Development of corrective and preventive recommendations
5. Communication of the investigation’s findings
6. Follow up system for the investigation’s findings
7. Audit the recommendations and their implementation
8. Management Systems.
Note that investigations of illnesses, particularly of the chronic occupational health type are to be
covered separately, as they typically are not related to specific as incidents.
This procedure does not apply primarily to acute or chronic illnesses.

Eg: Long term Ergonomic related , Noise induce hearing loss, Stress etc.,
Each facility (Buildings/ Office complex, Malls , Hotels etc.) must also be aware of and follow any
applicable regulatory requirement.

. 2.2 Field of application:
Across DLF Rentco including leased premises
2.3 Benefits of an incident investigation:
The incident investigation process contributes to the continuous improvement of EHS systems
and performance by:
 Identifying and implementing actions to prevent incident recurrence.

 Promoting an atmosphere of openness by improving communications and understanding
about the incident.
 Identifying conditions that, even if only indirectly related to the incident under investigation,
could potentially contribute to the occurrence of future incidents and providing an opportunity
to share this broadly.
 Providing input to the development and improvement of HSE policies, procedures,
guidelines, and standards.
3.0 References:
• HSE Policy
• DLF Safety Standards
• OH &S procedures and Sub- Procedures
• Engineering Guidelines
• Standard Operating Procedures
• Management Guidelines
4.0 Responsibilities:
Line management (Facility In charge i.e Building manager) across DLF Rentco has the
responsibility to implement this procedure.
Management shall establish the foundation for an effective incident investigation process through
leadership and commitment. Management has also the following specific responsibilities:
 Ensure that all incidents are reported.
 Create an atmosphere of trust and respect that leads to openness in the reporting and
investigation of incidents.
 Establish systems and procedures to assure an effective and efficient incident- investigation
process. Communicate the value of incident investigations as a tool to continuously improve
HSE systems and performance.
 Provide the resources and priority attention necessary for timely, thorough, and
comprehensive investigation

 Implement systems to ensure learning’s and recommendations of an investigation are acted
on to prevent recurrence. This includes communicating those learning’s and findings to all
who may benefit.
The following table defines the responsibilities of persons / Committees/ in the Incident
Investigation process:
All Facility Personnel -

Company & contract employees Report all incidents, including near misses.
and visitors
Ensure that all visitors understand that all incidents,
Hosts
including near misses, must be reported.
Ensure that incidents and near misses are investigated
Operation Head/CGCRM / GCRM
and a report is submitted within the defined time limit.
/ CRM / FM
Ensure that all recommendations are implemented in time
Supports and advises the line manager with incident
Head – Fire & Safety
investigation, including classification
Monitor status of injured persons, liaise with outside
FM – SPOC / KAM/ FM-Group hospitals and to provide medical assistance. Ensure legal
Coordinator compliance and report incidents to regulatory authorities.
Custodian of the incident information retained in the
Group Coordinator & BM Incident Investigation Report and ensures that the data is
validated. Communicate incidents & investigation reports
within the Facility as well as across all Facilities
for learning.
Communicate incidents for learning across the

Communications Sub Committee
organization.
HOD (HR) / FM Liaise with DISH for workmen compensation
II Sub Committee Review of investigation procedures and Preparation of
Learning and Improvements From Experience (L.I.F.E) and
share communication subcommittee for circulation across
DLF rentco.
IISC -Chairman & Members Review all incidents except low potential NMCs
Chairman R&P Sub Committee Custodian of this Document (II Procedure)

5.0 Definition:
Contractor:
Any non-DLF Rentco entity that provides materials and/or services described in a contract for
DLF Rentco.
Contract:
An obligation between parties, regardless of payment type (i.e., lump sum, unit
price/schedule rate, time and materials, or cost plus), that is enforceable by law; an
agreement between parties to furnish goods and/or services in return for compensation.
Contractor employee:
A person employed by a contractor to carry out work under the terms of a contract.
Temporary employee:
A person who has entered a contractual relationship directly with DLF RENTCO.
Employee: Employee will mean own and contractor employees
Hazard : Is a situation that has the potential to cause harm to a person, the environment or
damage to the property.
Risk: Risk is the probability (likelihood) of harm or damage occurring from exposure to a
hazard, and the likely consequences of that harm / damage
Health: A state of complete physical, mental, and social well-being. In the working
environment, there are two aspects: the effects of work on health and the effects of health
on work.
Indoor Air Quality: The condition of ambient air in a workspace.
Investigation team: A group normally led by line management, with representation or

input from the affected individual(s) and Safety, Medical, Environment, Fire, Security,
Quality or other specialists, as required.
Incident: Any event that could have or did result in
 Injury
 Environmental release
 Property damage.
 Adverse community reaction
Fatal:
Fatal Accident may be defined as the death of a person resulting from an accident caused
while performing his regular duties or while performing his work-related activities.
Note: Following categories are excluded:

1. Death arising from Natural Causes
2. Suicide
3. Inexplicable Personal Behavior of the person (Death during violence, murder etc.)
Lost workday cases (LWC)

If an employee is unable to work on a subsequent scheduled shift because of a work-
related injury or illness‚ the case is classified as an LWC. The shift on which the case
occurred is not counted as a lost workday. LWC shall be considered based on Doctor
prescription.
Restricted workday cases (RWC) An RWC is a case in which a work-related injury or

illness prevents the employee from working a complete shift (or from doing any tasks that
are part of his or her regularly scheduled job that may be performed or assigned) but
which does not result in lost workdays.
Medical treatment cases (MTC)
An MTC is a work-related case for which medical treatment is indicated but that does not
result in lost work or work restrictions.
First-aid cases (FAC)

Any injury that calls for only simple treatment using first-aid box medicine and does not call for
follow-up treatment by a health-care professional is a FAC. A case can be classified as an FAC
even if a health-care professional administers the first aid.
Near Miss Case (NMC)

An event could have resulted injury/fatal is a near miss case
Generally the following events are some examples of near miss when:
 A person trips over an object and falls to the ground but did not get injured.
 A person has to dive or jump out of the way to avoid a collision with a motorized vehicle, a
moving object like a suspended part on a conveyor or from an uncontrolled suspended load
 A person has to jump from a falling ladder
 Any emergency equipment (fire extinguisher, Air Pack, Oxygen sensor, eye wash, etc) fails
to operate properly when called on in an emergency.
Fire: A process in which substances combine chemically with oxygen from the air and typically
give out bright light, heat, and smoke; combustion or burning.
An unplanned combustion. Evidence of combustion includes flames, smoke, or charring.
(A Fire, which results in any one of the following, will be considered as a Major Fire incident:
• Involves or could have involved a fire induced FAC or higher category injury.
• Caused shutdown
• Loss / damage to property more than Rs. 5 lakhs.
• Lasted for more than 15 minutes.)

Property damage: Any incident which results in physical damage that may alter the shape, size ,
functionality, inherent characteristic, and appearance of the property.
Environmental incident
A distinct spill, leak, or release of a chemical or chemical mixture to the environment. Any
Environment incident which results in any one of the following will be considered as a Major
Environment incident:
- Impact on neighboring community

- Exceeds permissible environment limits
Occupational illness
A health condition caused by, precipitated by, contributed to, or aggravated by exposure to
workplace hazards over a period of time. Example is Musculoskeletal disorder or MSD
Occupational injury
A physical condition that results from an incident or a single, brief exposure in the workplace (e.g.,
burn, laceration or fracture).
6.0 Investigation Process:
Facility shall have investigation procedures and training in place before an incident occurs. This allows
for prompt implementation of the investigation process, including interviewing witnesses and preserving
evidence at the scene.
This is important because the quality and quantity of relevant information begins to diminish
rapidly following an incident. For example, eyewitnesses’ memories blur and dim as time passes,
and cleanup efforts can obliterate vital evidence.
There are eight step process of incident investigation
The steps involved in the incident investigation procedure are shown in the flow chart
attached as Annexure – 1.

6.1 Initial Response and Reporting
6.1.1 Initial response
Initial report : Initially the incident shall be reported to Building Fire / Security control room.
Area supervisor must take steps to preserve relevant evidence and information until the incident
investigation begins, in addition to the appropriate emergency response to the incident.
Steps that should be taken include the following:

• Barricading and securing of the scene, including protecting it from the weather.
• Collecting physical evidence and data records
• Recording (e.g., written, audio, or video) of key personnel.
If incident involves fatalities, serious injuries, or significant environmental impact, Facility shall:
1. Notify line management promptly
2. Consider activation of the facility site emergency response plan, or
3. Additionally, the Facility shall make appropriate immediate regulatory reporting if
required.
6.1.2 Initial reporting
All incidents must be reported promptly (24 hours), so that an appropriate response can be made
to IISC Chairman.
Initial reports should be brief and limited to a brief outline of the known facts (date, time, place,
what happened, and immediate actions taken). For the Initial Incident Report format, please refer
to Annexure-2.
From these initial reports, the Facility can identify Incidents that require comprehensive
investigation.
Facility that follows the above procedures and promote an atmosphere of learning, openness,
and trust in reporting incidents can probably expect an increase in the number of such reports.
This does not indicate a breakdown in systems but leads to opportunities to create a safe and
healthy work environment and to work towards safety excellence and the Goal of Zero incidents.
6.1.3 Classifying Incidents:
1. Fatal
2. Lost workday cases (LWC)
3. Restricted workday cases (RWC)
4. Medical treatment cases (MTC)
5. First-aid cases (FAC)
6. Fire
7. Near Miss Case (NMC)
8. Other case : Any incident other than above category incidents shall be considered as
OTHERS CASE
6.1.4 The time limit and responsibilities for communicating incidents relating to occupational
injuries and illnesses is as shown:

By
Sr. To Time Time
Category / By Whom Who To Whom
No Whom Frame Frame
Activity m
.
Internal Communication External Communication
Work related CGCRM/S MD / Immedia Head Family Within 2
Fatalities POC-FM/G National te -HR Members hrs
roup Head
Coordinato (BMS)/ Head Police Orally
r-FM Head HR/ -HR Within 2
Legal hrs.
Head DISH Orally
-HR Within 2
hrs.
1 Head DISH, Writing

-HR Police Within 24
hrs.
HR Governm In writing
Head ent as per
Authoritie requireme
s (All nt as
concern) required
– as by Law.
required
by Law.
Injuries , Building CGCRM/ Immedia N/A N/A N/A
RWC/MTC Manager GCRM/ te
Occupational CRM / FM -
Illness, Equipment SPOC/
2
Damage, Fire KAM/
incident, FM-Group
Environment Coordinato
release r
CGCRM/S Corporate Immedia N/A N/A N/A
Incident deemed POC/FM/G Communic te &
to have Major roup ation Continu
3 potential / media Coordinato ous
focus (only verbal r
Communication)
FM - Within
SPOC/ 24 hrs of
4 Near Miss Case, Building
FM-Group the NA NA NA
FACs, and Others Manager
Coordinato receipt
r of report

6.2 Formation of Incident investigating team.
The responsibility for forming the investigation team is as follows:
Incidents Team formation by Team leader
CGCRM / FM - SPOC in
consultation with National Head GCRM / FM –
Fatality Operations Group coordinators
GCRM / FM – Group
LWC- Serious injury, High Potential NMC Coordinator CRM / BM - FM
RWC, MTC, FAC, NMC (High Potential), CRM BM
FIRE , OTHERS
Note:
1.Team size should be 4 to 6 members
2. RCFA trained person is must in the team.
3. Team should be formed within 24 hrs of incident occurrence.
4. Investigation report should be released within 7 days from the date of the incident.
5. If the incident is having potential fatality, CGCRM / FM - SPOC in consultation with National
Head Operations will decide the team.
6. FM - SPOC / Group Coordinator correspond to the incident occurred of the
respective Location.
7. IISC Member must review the investigation report before submission
Forming the investigation team

The composition of the investigation team constitutes a critical factor affecting the quality of the
investigation. Appointing competent personnel to the investigation team is a management
responsibility and helps ensure a prompt and effective investigation. Refer above table for
formation of investigation team.
Team chairperson
The team chairperson should effectively perform the following tasks:
 Control the scope of team activities to ensure that a comprehensive and timely
investigation is performed
 Ensure appropriate team membership and participation
 Call and preside over meetings
 Apprise management of the status of the investigation
 Ensure the adequacy of the report.
For major traumatic events, including those involving death or serious injury, property damage, or
environmental impact, it is particularly important that the team chairperson function objectively
and without emotional involvement. In such cases it may be appropriate to select a Chairperson
from higher in the line organization or someone who is not directly assigned to or involved with
the area/Facility where the incident occurred.

Team membership
Team membership including the chairperson should include those who can contribute and play a
role in the investigation. Investigation team membership can vary according to the severity of the
incident involved and the resources available.
At least one member of the team should be experienced in incident investigation.
6.3 Determining the facts
A thorough and comprehensive search for the facts is necessary. Chronology of events & list of
people interviewed is to be documented. During the fact-finding phase, the investigation team
should thoroughly inspect and preserve physical evidence from the incident scene.
The team shall document all factual information to facilitate further review, investigation, and
reporting as necessary.
Where applicable, the incident team should perform the following tasks as part of the fact-
gathering phase of the investigation:
• Collect samples/relevant materials, noting conditions which may have affected the samples
• Preserve an accurate depiction of the scene through photographs, videotape, field sketches,
maps, and other graphic representations.
• Seek inputs from key personnel like operator / supervisor
• Obtain on-the-spot information from eyewitnesses. More extensive interviews from witnesses
should be taken as quickly as possible. These interviews should be conducted individually and
privately so that the comments of one witness do not influence those of another. Interviews
should be individually documented and confirmed by the interviewee.
• Examine key mechanical equipment (where relevant, as it is disassembled).
• Review all potential documentary sources of useful information. These may include as-built
drawings, operating logs, recorder charts, previous reports, procedures, equipment manuals,
oral instructions, change of design records, design data, electronic data, employee training and
performance records, computer simulations, and laboratory tests.
• Determine which incident-related items should be collected or preserved. When preliminary
investigation reveals that an item has been damaged or may have failed to operate correctly,
the investigation team should ensure that the item is preserved in an “as-found” condition or
that any subsequent repairs or modifications are documented. Where applicable, the team
should develop the chronology of events that occurred before, during, and after the incident
based on the above and other information.
• The focus of the chronology should be solely on what happened and what actions were taken.
List alternative chronologies when the status cannot be definitely established because of
missing or contradictory information. Note unconfirmed assumptions and take action to verify
them.
• List all known facts, not only related to incident significance, but pertinent background data,
specifications, and recent past and/or external events that could have an influence on the
overall system.
• Identify conditions or circumstances that deviated from normal, no matter how insignificant
they may seem:
 The effect of work cycles and work-related stress that could have an impact on
individuals' performance prior to an incident.
 The impact of social and domestic pressures related to individuals' behavior should not
be overlooked.
A factor to consider during an investigation is recent change. In many cases it has been found
that some change occurred prior to an incident which, combining with other causal factors already
present, served to initiate the incident. Changes in personnel, organisation, procedures,
processes and equipment should be investigated, particularly the hand-over of control and
instructions, and the communication of information about the change to those who needed to
know.
6.4 Determining key factors

Key factors of an incident must be determined, as they are essential for developing effective
recommendations to prevent recurrence. Even where factors seem obvious, the investigation
team should use formal analysis to avoid drawing premature conclusions. Comprehensive
investigations often identify underlying operating/managing systems that need to be
strengthened, as well as immediate physical and human issues. The investigation should be
considered an opportunity to make improvements, rather than to assign blame.
Guidelines for determining key factors are given in Annexure-3
6.5 Determining systems that need to be strengthened

Investigations should identify those systems that need to be strengthened in order to maintain
Facility and corporate attention on the continuous need to improve these systems. Typically these
areas for improvement flow from the key factors already identified and should be noted on
the investigation report.
6.6 Recommending corrective and preventive actions
Recommendations for corrective& preventive actions must be developed to address the key
factors.
While considering recommendation, the five steps for the system should be considered:
1) Elimination
2) Substitution/ Reduce
3) Isolation / Engineering control
4) Administrative Control - Procedures & Training
5) PPE
Also, the recommendation has three important parts:

1. A clear description of the recommended action to be taken to prevent recurrence
2. The name/position of the person responsible for implementation
3. A completion dates.

NOTE: Recommendations that need to be completed before operations resume should be clearly
identified. Other recommendations (e.g., longer-term system- related improvements or
evaluations) often require a completion date that extends beyond startup.
6.7 Documentation & Communication of Findings
6.7.1 Documenting of final Incident investigation report
The findings of the incident must be documented in an incident report. Reports should be written
so that, they are understandable by others who are not directly involved in the affected area.
Facility specific terminology should be avoided.
The Incident investigation report should be made in the format as prescribed in Annexure-5
6.7.2 Communication of learning
Communicating the results of incident investigations is a vital component to prevent recurrence.
6.7.2.1 Communication within the Facility:

The Incident Investigation Report must be shared and discussed with appropriate personnel
(SPOC - FM / Group Coordinator), learning must be shared with all employees, contractors’
employees from the affected area, as well as those whose job tasks are related to the incident
findings through Incident Investigation Sub Committee.
6.7.2.2 Communication beyond the Facility:

The building manager must send the complete incident investigation report promptly to FM
SPOC/ Group coordinator / CRM/GCRM/CGCRM, who will in turn communicate the relevant
details to the National Head Operations.
All HSE incidents’ learning’s must be shared through communications committee in the form
of L.I.F.E and, as appropriate, through relevant networks to other units, so that other units can
benefit from the results and learning’s of an investigation. While communicating the learning
from incident investigation in the form of LIFE or other means the personal information may
be kept confidential.
6.8 Follow-up system
Each Facility must develop and implement a system to address open recommendations. To
ensure prompt follow-up and closure of recommendations from an incident investigation report,
such a system must provide for periodic status reports to Facility management until all
recommendations are acted upon and closed out. Additionally, it is recommended that the system
include a verification of the implementation and effectiveness of the corrective action.
If a recommendation is to be declined by the concerned Facility as well as all other facilities, the
respective FM SPOC shall document, in writing & based on adequate evidence, that one or more
of the below conditions is true:
1. The recommendation is not applicable

2. An alternative measure would provide a sufficient level of protection.

3. The recommendation is not feasible (an alternative recommendation should be provided to
address the key factor)
4. The documentation shall be retained as part of the official record of the investigation.
5. In case of any investigation initiated by the Government authorities the concerned National
Head will provide all cooperation to the investigation.
Format for Incident Investigation close out report shall be as Annexure-6
7.0 Management System
7.1 Support Resources

Facility and corporate resources are available to assist in implementing this procedure.
7.2 Management Records
The concerned BM, to meet regulatory needs, must retain all Records and evidences.
7.3 Audit Requirements/Performance Metrics
Incident investigation is audited as part of the second-party EHS HSE audit
protocol. Facilities may track metrics for their internal use (e.g., key factors).
7.4 Procedure Renewal Process

This procedure shall be reviewed and revised as necessary and, at a minimum, not
later than three years from the date of incorporation
7.5 Deviation Process

The II Sub Committee Chairman must authorize deviations from this procedure for the
relevant Facility after consultation with the Head – Fire & Safety. Deviations must be
documented, and documentation must include the relevant facts supporting the
deviation decision. Deviation authorization must be renewed periodically and not later
than six months
7.6 Training and Communications Requirements
All employees to the level of line managers will be trained in the Incident Investigation
process and procedure. Periodic refresher training must also be conducted. The Training
Sub-Committee must also maintain all training records.
7.7 Contact
The contact for this procedure is the II Sub Committee.
Clarification/Interpretation regarding this procedure shall be referred to the Chairman -
IISC.
Key factors: Circumstances that contributed to or may be reasonably believed to have

contributed to the incident’s occurrence even though a clear causal connection cannot be
found. These factors include physical, human and systems that are found to be deficient or
otherwise capable of being improved.

Recordable: describes an injury or illness that is recorded and tracked by the IISC. Total
Recordable Cases (TRC) will be a sum of Fatality, LWC, RWC, MTC and FAC.
Reportable: All incidents (08 categories) shall be reported
Symptom: A non-observable (i.e. subjective) indication (e.g., pain, numbness, nausea, or
shortness of breath) of an injury or illness.
Work-related activity: All activities on DLF RENTCO’s premises. Also included are
activities performed by employees as part of DLF RENTCO’s business outside DLF
RENTCO’s premises (examples are: travelling on official duty, meetings at vendor/ dealer/
customer premises etc).
Wellness and work conditioning program - a course of actions aimed at promoting
employees’ health, well-being, and fitness for duty.
HSE: Health , Safety and Environmental
8.0 Retention Period :
Buildings shall be maintain final investigation reports throughout the lifetime from the incident
date.

Annexure – 1: Incident Investigation Flow Chart
INCIDENT /NEAR MISS OCCURS
PROVIDE FIRST AID & MEDICAL CARE, MAKE THE SITE SAFE
Communication
committee shall prepare Responsibility: Line
SUBMIT IIR in prescribed
and send Incident alert to format to IISC Chairman Manager (BM) (within 24
all Employees within 4 Hrs) **
days.
Department Head/Site I/C to
form Investigation Team Form team immediately after
incident (Not later than 24 Hrs)
FACT GATHERING & ‘WHY’ TREE
Collect facts/ evidence: Physical,

documentary & interview
IDENTIFY KEY FACTORS Why Tree Analysis;
Identify Key Factors:
Physical, Human &
DETERMINE CORRECTIVE System Causes
Reporting Heads shall ACTION
brief about the findings RECOMMENDATIONS
and action plan Within 07 days of incident
SUBMIT INVESTIGATION REPORT

Communication TO REPORTING HEAD WITH A COPY
committee shall prepare TO II COMMITTEE
companywide
communication basis final
approval
IMPLEMENT
CORRECTIVE ACTION
AUDIT
DOCUMENTATION &
All these tasks shall COMMUNICATION
be done by
respective Line
management teams.
MONITOR & FOLLOW UP
** In case of serious incidents (like fatality/ near fatality, Fire etc) intimation shall be sent to MD with a copy to HR
through respective reporting Heads at the earliest but not later than 1 hour.

Guidance for selecting members of investigation team
Possible candidates for membership in an investigation team vary depending on the nature of
the incident, and may include:
1. A senior member of typically becomes the chairperson from the area where the
incident occurred.
2. Engineering or maintenance personnel
3. An appropriate EHS office member (e.g., health, safety or environmental)
4. Incident controller
5. A first-line supervisor and or front line engineer from the affected area
6. Operations or maintenance personnel (e.g., an operator, technician, or mechanic).
7. Individuals who have firsthand knowledge of the incident
8. Research or technical personnel
9. Another member of supervision from an area not involved in the incident
10. As appropriate, and where the incident involved contract work, contractor employees
11. A person trained in “root cause” analysis technique
12. Other specialists or consultants (e.g. Corporate HSE, Fire Protection Group,
Environmental Group, Sourcing, Legal, External Affairs, or Medical)
For major, traumatic events, including those involving death/serious injury/major property
damage, or significant environmental impact, strong consideration should be given to participation
by UH and the Facility EHS head a member of Corporate EHS, consultants, or Legal.

Annexure – 2
Incident Report No (To be

IMS-PRO-002 Annexure-2 selected by IISC):
INITIAL INCIDENT REPORT (IIR)
Region (Select from Building (Select from Date of Incident Time of Incident (Select
dropdown list) dropdown list) (D-MM-YYYY) from dropdown list):
Incident Type (Select Area (Select from FM Partner (Select Incident Location (Type
from dropdown list) dropdown list) from dropdown list) Below)
Description of
Incident :
Likely Cause of
Incident :
Immediate
Corrective Action:
Employee Type (Select Company Name (Type Injury Nature Body Parts Injured
(Select from dropdown
from dropdown list) Below) (Select from dropdown list)
list)
Reporting Date Report Time

(AutoSelected): (AutoSelected) :
Incident Witnessed By (Type Below) : Incident Reported By (Type Below):
LWC- Lost work day case, RWC- Restricted workday case, MTC- Medical Treatment case,
FAC- First Aid Case, NMC- Near Miss case

Annexure-3 (Guidance for determining key factors)
A1 Endorsement of ‘root cause’ analysis

The investigator team then examines those factors to determine what may have contributed, in turn
to their occurrence. This step-wise approach will ultimately lead to the identification of factors that
may be at the “root” of other factors.
The Rentco nonetheless endorses the following “root cause” method of analysis as the preferred
approach to maximize the learning’s from incidents. It should be used to identify key factors.
As defined in the text of this document, key factors are those circumstances that may have
contributed to the incident’s occurrence even though a clear causal connection cannot be found.
These factors may include human, equipment, or management categories/systems that are found to
be deficient or otherwise capable of being improved.
Examples of key factors include the following:
 An operator did not properly follow the operating procedures.
 The fire water pump bearings failed, causing a shutdown of the fire water pump during a
fire. Pump bearings are not included in the Facility preventive or predictive maintenance
programs.
 Operator procedures for non-routine tasks are not included in the current operator training
program.
After an incident occurs, an investigation is held as soon as possible to determine all of the key
factors.
From the list of key factors, a list of recommendations, or follow-up actions, can be generated. When
the recommendations are implemented, the possibility of the same incident recurring is reduced.
A.2“Root cause” analysis

1. For each item that occurred, identify what events/situations may have caused or contributed to it
(“causes”).
2. Each of these can then be evaluated to identify what events/situations may have caused or
contributed to it, for example by asking “why did this happen?”
3. For each “answer,” again ask what events/ situations may have caused or contributed to it. At
some point the team needs to ask: “What management systems (e.g., training or auditing) were
lacking or otherwise capable of being improved?”
4. Continue looking for the “cause” of each possible factor identified until the endpoint is reached:
the most basic “cause” or “root cause”. Often, the endpoint is one of the system elements (e.g.,
training or operating procedures) that need to be improved. These endpoints are also considered
to be “key factors” and should be noted as such in the report.
5. Another possible endpoint is when a point is reached where the event cannot be controlled
internally by the location alone. In these cases, the investigation would involve outside
organizations as appropriate. In addition, the investigation would look at how to reduce effects
from external sources. (For example, a failure due to a defective part supplied by a vendor is not

simply out of the control of the Facility. Actions [e.g., quality control] can be implemented to
prevent this type of incident from occurring.)
6. After identifying all the key factors, the theories should be tested against the chronology and
other pertinent facts. The team may need to modify its conclusions to fit the facts.
7. Lastly, recommendations are developed based on the key factors identified.
A.3 Examples of a “root cause” analysis

Example 1
Incident: Employee slipped on wet spot on floor and sprained his ankle.
Questions asked by team: Response found:
Why was the floor wet? Leak from pipe.
Why did pipe leak? Corrosion.
Why did it corrode? Wrong material of construction.
When was wrong material installed? Original installation.
Quality assurance (QA) procedures were not
Why was wrong material installed? adequate. There is no requirement for inspection by
qualified personnel.
The team then recommended modifying the Facility QA procedure to require inspection and
documentation of the inspection of all new/modified equipment to ensure construction matches
design specifications.
Definition of Key Factors:
PHYSICAL FACTORS: Usually becomes apparent through observations – hardware, machines,

vessels, etc.
HUMAN FACTORS: Acting inappropriately or failing to act, intentional behaviour, mistakes, lack
of awareness, not knowing, etc.
SYSTEM FACTORS: Communications, procedure, training, documentation, policies, standards

of performance, etc.
Example 1: When climbing a scaffold ladder, a contractor employee fell and landed on his left
foot, which resulted in a knee injury to his right leg. The medical diagnosis was a multi fragment
fracture of the tibia and fibula bones at the knee joint. There was no impact to the operation of the
plant, facilities or environment. Surgery was required and full recovery expected
PHYSICAL FACTORS:
The Scaffold fell down:
• It was not secured
• Ladder position oriented over the scaffold long side
• Casters position oriented towards the most instable point
• Lack of casters secure pins
• Inadequate scaffold dimensions (base vs. height)
HUMAN FACTORS:

• Scaffold assembling and the use of it without proper training and training materials.
• Not installing the secure pins for fixing the casters to the scaffold.
• Failure to be concerned when they detected the instability problem.
SYSTEM FACTORS:
• Lack of formal training system for scaffolds assembling/ disassembling
• Deficiency on procedures for scaffolds, they do not include critical elements nor have
consistency with the corporate Scaffolds’ Scaffolds Safety for Scaffolds assembling/
disassembling use.

Annexure – 4: Incident Investigation Report Format
DLF RENTCO REPORT No
INCIDENT INVESTIGATION REPORT IIR-
Incident Title:
Classification FATAL LWC RWC MTC FAC NMC FIRE OTHER
Numbers
Details of Injured Company Employees Contractor Employees OTHERS
Numbers
Names of Injured Persons Employee code Company Nature of Injury

Age / Sex
/ Department
Location of Incident: IIR Number:

Date of Incident: Time of Incident:
Incident Investigation Incident Investigation
Initiated: (Date / Time) Report Submission:
List of Records Reviewed List of Persons
during Incident interacted during
Investigation: incident investigation
process:

Summary of Incident: (Report as fact only what you are clear is fact. Specify the status of anything
else you report, e.g. estimate / belief)
Chronology of Events:
List of Facts collected during Investigation:
Why Tree Analysis

Key Factors Identified:
PHYSICAL FACTORS:
HUMAN FACTORS:
SYSTEM FACTORS:

Systems that neds to be Reinforced:
Sr No. System Deficiency
Recommendations:
Implement
Sr No. Recommendation Responsibility Target Date ation to be
Verified by
Incident Investigation Completed On:
Approximate Cost of Incident:
Prepared by (Team Leader):
Investigation Team :
Reviewed & Approved by:
Supporting Photographs / Exhibits:

Annexure – 5: Incident Investigation – Action Taken Report (ATR)
DLF RENTCO FY
INCIDENT INVESTIGATION FOLLOW UP REPORT Quarter:
Date
Expected Implementati
Sr Report
Recommendation Responsibility Close out Status on Verified
No. No.
Date by
Annexure -6 : Cost of incident (Lost damage Analysis )
Loss Damage
Analysis Form.xlsx

IMS-PRO-002 VER 01 - Incident Reporting &amp; Investigation Procedure

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INCIDENT REPORTING &

Page 1 of 30 Date of Revision: 16-04-2021 IMS-PRO-002-VER 01

Document Revision No. Revision Date Standard Document No.

Page 2 of 30 Date of Revision: 16-04-2021 IMS-PRO-002-VER 01

S.No. Topic Page

6.0 Investigation Process 11

6.1.1 Initial Response 12

6.1.2 Initial Reporting 12

6.3 Determining Facts 15

6.4 Determining Key Factors 16

6.7.2.1 Communication with the facility 17

Page 3 of 30 Date of Revision: 16-04-2021 IMS-PRO-002-VER 01

7.2 Management Records 18

7.4 Procedure Renewal Process 18

7.6 Training and Communication Requirements 18

Annexure -5: Incident Investigation – Action Taken Report (ATR) 30

Annexure -6: Incident Loss Damage Analysis 30

• DISH - Director Industrial Safety & Health (known as Factories Inspectorate)

• HOD - Head of the Department

• EHS -Safety, Health and Environment

• ERT - Emergency Response Team

• FAC - First Aid Case

• FLE - Front Line Engineer

Page 4 of 30 Date of Revision: 16-04-2021 IMS-PRO-002-VER 01

• IISC - Incident Investigation Sub-Committee

• LWC - Lost Workday Case

• MTC - Medical Treatment Case

• NMC - Near Miss Case

• OHS - Occupational Health Services

• OTJ -Off the Job

• PPE - Personal Protective Equipment

• RA -Responsibility and Accountability

• RCFA –Root Cause Failure Analysis

• RWC - Restricted Workday Case

• CHS -Corporate Head Safety

• CMO -Chief Medical Officer

• SWP -Safe Work Procedure

• JSA - Job Safety Analysis

• L.I.F.E - Learning and Improving From Experience

• SPOC – Single Point of Contact

• KAM - Key Account Manager

Page 5 of 30 Date of Revision: 16-04-2021 IMS-PRO-002-VER 01

1.1 Intent and Purpose

2.0. Scope and field of application

This procedure is intended to provide a systematic, in-depth approach of incident investigation on

This procedure does not apply primarily to acute or chronic illnesses.

Page 6 of 30 Date of Revision: 16-04-2021 IMS-PRO-002-VER 01

2.3 Benefits of an incident investigation:

 Identifying and implementing actions to prevent incident recurrence.

Page 7 of 30 Date of Revision: 16-04-2021 IMS-PRO-002-VER 01

All Facility Personnel -

Communicate incidents for learning across the

Page 8 of 30 Date of Revision: 16-04-2021 IMS-PRO-002-VER 01

Employee: Employee will mean own and contractor employees

Indoor Air Quality: The condition of ambient air in a workspace.

Investigation team: A group normally led by line management, with representation or

Incident: Any event that could have or did result in

Note: Following categories are excluded:

Page 9 of 30 Date of Revision: 16-04-2021 IMS-PRO-002-VER 01

Lost workday cases (LWC)

Restricted workday cases (RWC) An RWC is a case in which a work-related injury or

Medical treatment cases (MTC)

First-aid cases (FAC)

IMS-PRO-002 VER 01 - Incident Reporting & Investigation Procedure

IMS-PRO-002 VER 01 - Incident Reporting & Investigation Procedure