Incidents vs. Nonconformities in OHSAS 18001:2007

One of these significant changes is the clarification of the role of incident investigation in an occupational health and safety management system (OHSMS).  In particular, incident investigation is now a separate subsection of section 4.5.3 — Incident investigation, nonconformity, corrective action and preventive action with its own specific requirements.

An incident is not the same as a nonconformity.

First, the definitions are not the same.  OHSAS 18001 uses the ISO 9000 and ISO 14001 definition of a nonconformity – the non-fulfillment of a requirement.  An incident is defined in OHSAS 18001 as a “work-related event(s) in which an injury or ill health (regardless of severity) or fatality occurred, or could have occurred.”  An accident is a particular type of incident in which an injury or illness actually occurs.  A near-miss is an incident where no injury or illness occurs.  Therefore, an incident can be either an accident or a near-miss.

An incident may relate to a nonconformity – but then again, it may not.  It is possible to have accidents and near-misses even if an organization has fulfilled its occupational health and safety management system requirements.  Similarly, an organization may have nonconformities, e.g. “paperwork” issues, which would not be considered incidents.

Not all incidents are the same

• Some incidents are catastrophic disaster events (i.e. emergencies) such as bridge collapses or explosion.
• Some incidents involve unseen hazards, e.g. exposure to chemical releases or biological agents.
• Some incidents involve human factors or behaviors, some involve equipment failure, some involve faulty procedures or processes, and some involve all of these.
• Some involve multiple injuries and deaths; in others, there are no injuries.

Therefore, an organization’s incident investigation procedure needs to be flexible enough to deal with a variety of different types of incidents.