Incident register under ISO 45001: which fields do you need?
An incident register under ISO 45001 is an overview of all accidents and near misses, with date, nature, consequence, cause and action. By law, you must at least keep a record of the accidents you reported and those that caused more than three days of absence. The standard also asks you to learn from incidents. You can only do that with a register that also records the cause and the follow-up. This page shows which fields belong in it. The legal rules come from the Netherlands Labour Authority (Nederlandse Arbeidsinspectie) . You will find the requirements of the standard at the requirements of ISO 45001, and which documents belong with them at mandatory documents.
On this page
You read what the Labour Authority expects from the employer, what the register looks like in a practical example, and which mistakes we see most often. On the side of the standard, this concerns chapter 10.2.
What must you report immediately?
First, the legal reporting duty, because that is where things often go wrong. According to the Netherlands Labour Authority , the employer must report an accident involving hospital admission, permanent injury or death immediately. A hospital stay of a few hours also counts as hospital admission. If it later turns out that hospital admission or permanent injury did occur, report it immediately at that point. Not sure whether an accident is reportable? Report it anyway. The Labour Authority decides whether it falls under the reporting duty.
You can report 24 hours a day, 7 days a week, by calling 0800-5151 or using the Labour Authority’s online form. Do not wait until your register is in order.
The register is different from the report. You keep it internally, and it must also include the accidents you did not have to report.
What the register contains as a minimum
The Labour Authority requires you to keep a register of all reported accidents and of accidents that caused more than three days of absence. As a minimum, you record the date and the nature of the accident. Employees may inspect the register. For an ISO 45001 system, you want more: the cause and the follow-up as well.
Example of a register
The example below is fictional. It shows the fields used by a manufacturing company with 120 employees.
| Date | Type | Description | Location | Injury and absence | Reported to Labour Authority | Cause | Measure | Owner | Closed on |
|---|---|---|---|---|---|---|---|---|---|
| 3 Feb | Accident | Finger bruised while replacing a blade | Line 2 | First aid, no absence | No | Blade not locked during changeover | Lock-out procedure and checklist | Line 2 team leader | 17 Feb |
| 11 Mar | Near miss | Pallet nearly falls off fork while loading | Warehouse | None | No | Load too heavy for the fork | Maximum load shown on the fork | Warehouse manager | 25 Mar |
| 22 May | Accident | Fall of two metres while climbing a racking | Warehouse | Hospital admission | Yes, immediately | Ladder not checked | Daily check of climbing equipment, supervision at racking | Prevention officer | Open |
Look at the last row. It is only closed once the measure is in place and its effect has been checked. The measure alone is not enough. The auditor asks for evidence that it works.
The fields you must not forget
- Date and time. Needed for the timeline and the absence overview.
- Nature of the incident. Accident, near miss or unwanted situation.
- Consequence for the person. Which injury, which absence, or none.
- Report. Whether you reported it and when.
- Cause. The actual cause, not just “employee was not paying attention”.
- Measure and owner. Who makes sure it does not happen again.
- Closing date. When was the measure checked for effect?
A near miss belongs in the register. Anyone who only records accidents misses the signals that teach you the most. See identifying hazards and assessing risks for how to link those signals to your risks.
Common mistakes
- Recording only accidents. Near misses then stay out of sight, and that is where you learn the most.
- Filling in the cause as “human error”. That is a starting point, not a cause. Keep asking: why was the error possible?
- Forgetting to link the report. An accident that had to be reported but was not is a serious shortcoming.
- Keeping the register only in the HR file. The prevention officer and management must also see it. See worker participation.
- No closing date. An open row from two years ago tells the auditor that follow-up does not work.
How do you use the register in the audit?
The auditor usually asks for the register of the past twelve months and for a few examples you can explain. Choose one accident and one near miss, and show how the cause was investigated and how the measure was checked. That shows the system learns. It is also a good moment to use the internal audit to test whether the register is complete.
Steps after an accident
The register only becomes useful when you use it at the right moment. After an accident, go through these steps:
- Look after the person first. Give first aid, call the emergency services if needed and keep the area safe.
- Report to the Labour Authority if required. For hospital admission, permanent injury or death, report immediately, by calling 0800-5151 or using the online form.
- Record the facts. Date, time, place, people involved and what happened. Do this the same day, while it is still fresh.
- Find the cause. Use a simple method such as the five whys. Ask the person involved and a witness.
- Choose a measure. Preferably one that removes the source, not only warns the worker.
- Appoint an owner and a date. Without these two, the measure is not finished.
- Check the effect. After an agreed period, check whether the situation is really safer. Only then close the row.
These steps also have an ISO 45001 side. The incident is input for the risk analysis, and the measure belongs in your operational control. See identifying hazards and assessing risks and emergencies for what applies to larger incidents.
Why near misses deliver the most
A near miss does not injure anyone, but it shows where the system is under strain. If a pallet nearly falls off the fork, the question is not whether someone should pay more attention. The question is why the pallet was so heavy and why nobody noticed the load was too high. That question leads to a better workplace, and that prevents the real accident.
Encourage employees to report near misses. This only works if reporting does not lead to punishment. A short verbal report, without a name if preferred, often works better than a form nobody fills in.
Link with the audit
At the audit, the auditor asks for an example of an accident and of a near miss. They want to see how you investigated the cause and how you checked the effectiveness. A register with only closed rows and a short description is not enough. The question then remains open whether the system works.
Frequently asked questions
Do I have to report every near miss to the Labour Authority? No. The reporting duty applies to accidents involving hospital admission, permanent injury or death. You record near misses internally.
How long do I keep the register? The Labour Authority page does not state a retention period. We have not confirmed one either. Set your own period and record it in your policy.
Is a paper register enough? It can be, as long as it is complete and easy to find. A digital register is easier for trends and follow-up.
What if there have been no accidents? Then you have a register with zero rows. That is not a problem, but record that you keep it and that nothing has happened.
Sources
- Netherlands Labour Authority: work accidents : reporting duty, registration and phone number.
- ISO: the 45000 family : the place of ISO 45001 in the family.