Standard Operating Procedure for Incident and Accident Reporting and Investigation in API Manufacturing
| Department | API Manufacturing |
|---|---|
| SOP No. | SOP/API/206/2025 |
| Supersedes | SOP/API/206/2022 |
| Page No. | Page 1 of 13 |
| Issue Date | 14/04/2025 |
| Effective Date | 16/04/2025 |
| Review Date | 14/04/2026 |
1. Purpose
To define a structured process for immediate reporting, thorough investigation, and effective resolution of all workplace incidents and accidents in API manufacturing, including near misses. This SOP ensures compliance with EHS standards, promotes employee safety, and drives continuous improvement through root cause analysis and preventive actions.
2. Scope
This SOP applies to all incidents
and accidents occurring in API production, warehouses, laboratories, maintenance areas, and administrative zones, including chemical exposures, equipment malfunctions, injuries, near misses, and environmental incidents.
3. Responsibilities
- Employees: Promptly report all incidents or unsafe conditions to supervisors.
- Supervisors: Initiate first-level documentation and notify the EHS team.
- EHS Officer: Lead formal investigation, conduct root cause analysis, and recommend CAPA.
- QA Representative: Verify procedural compliance and maintain documentation.
- HR Department: Coordinate medical attention, if required, and handle insurance-related processes.
4. Accountability
The Head of EHS is accountable for the implementation and effectiveness of the incident and accident management system, including corrective and preventive actions, closure timelines, and communication to stakeholders.
5. Procedure
5.1 Definitions
- Incident: Any unplanned event that does not result in injury but has the potential to do so (near miss).
- Accident: An unplanned event that causes injury, illness, or property/environmental damage.
5.2 Immediate Reporting
- Any person witnessing or involved in an incident/accident must inform their supervisor immediately.
- Initial details to be noted in the Incident Reporting Log (Annexure-1).
- Serious injuries must be reported to EHS, QA, and plant management within 30 minutes.
5.3 First Response and Containment
- Secure the area and prevent access to others.
- Provide first aid or medical attention as necessary.
- Isolate energy sources if equipment is involved (lock-out/tag-out).
- Take photographs and gather evidence before cleanup (where safe).
5.4 Formal Investigation
- EHS shall form an investigation team for moderate to major incidents.
- Use the Incident/Accident Investigation Form (Annexure-2) for:
- Sequence of events
- Personnel involved
- Witness statements
- Root cause analysis (5-Why/Fishbone)
5.5 Classification of Severity
- Incidents shall be classified as:
- Level 1: Minor incident – no injury or loss
- Level 2: Moderate – first aid injury/property damage < ₹10,000
- Level 3: Major – hospitalization, regulatory reportable, fire, or environmental damage
- Level 3 incidents must be reported to local authorities as per the Factories Act.
5.6 Corrective and Preventive Action (CAPA)
- Investigators shall define CAPAs based on root causes.
- Each CAPA must be assigned to a responsible person with target dates.
- Track CAPAs in the Incident CAPA Tracker (Annexure-3).
5.7 Closure and Review
- Close incident only after CAPA completion and verification by EHS and QA.
- Record final closure in the Incident Closure Log (Annexure-4).
- Serious incidents to be reviewed during monthly EHS Committee meetings (Annexure-5).
5.8 Training and Communication
- Lessons learned shall be communicated via toolbox talks and bulletin boards.
- Annual refresher training shall include real-life case discussions.
6. Abbreviations
- EHS: Environment, Health & Safety
- QA: Quality Assurance
- CAPA: Corrective and Preventive Action
- PPE: Personal Protective Equipment
- SOP: Standard Operating Procedure
7. Documents
- Incident Reporting Log – Annexure-1
- Incident/Accident Investigation Form – Annexure-2
- Incident CAPA Tracker – Annexure-3
- Incident Closure Log – Annexure-4
- EHS Committee Meeting Record – Annexure-5
8. References
- Factories Act, 1948 – Sections on Safety and Health
- OSHA 1904 – Recording and Reporting Occupational Injuries and Illnesses
- ICH Q10 – Pharmaceutical Quality System
- ISO 45001 – Occupational Health and Safety Management System
9. SOP Version
Version: 2.0
10. Approval Section
| Prepared By | Checked By | Approved By | |
|---|---|---|---|
| Signature | |||
| Date | |||
| Name | |||
| Designation | |||
| Department |
11. Annexures
Annexure-1: Incident Reporting Log
| Date | Location | Type | Reported By | Initial Action |
|---|---|---|---|---|
| 13/04/2025 | Solvent Area | Near Miss | Sunita Reddy | Area Isolated |
Annexure-2: Incident/Accident Investigation Form
| Incident ID | Type | Description | Root Cause | Investigator |
|---|---|---|---|---|
| INC-024 | Accident | Slip on wet floor | No caution signage | Rajesh Kumar |
Annexure-3: Incident CAPA Tracker
| CAPA ID | Action | Owner | Status | Due Date |
|---|---|---|---|---|
| CAPA-024 | Install caution boards | Maintenance | Completed | 15/04/2025 |
Annexure-4: Incident Closure Log
| Incident ID | Date | Closed By | QA Verified | Remarks |
|---|---|---|---|---|
| INC-024 | 15/04/2025 | EHS Officer | Yes | Closed |
Annexure-5: EHS Committee Meeting Record
| Date | Chairperson | Key Topics | Decisions |
|---|---|---|---|
| 01/04/2025 | Plant Head | Review of Incidents | Install additional safety posters |
Revision History:
| Revision Date | Revision No. | Details | Reason | Approved By |
|---|---|---|---|---|
| 01/01/2022 | 1.0 | Initial release | New SOP | QA Head |
| 14/04/2025 | 2.0 | Updated classification and annexures | Regulatory Update | QA Head |