Accident investigation and near-miss reporting (VCA)
Under VCA, you report and record every accident, near miss and unsafe situation, and you investigate them to prevent them from happening again. This is set out in chapter 11 of the VCA checklist 2026/6.1 . Question 11.1 covers reporting and recording, and question 11.2 covers investigation. Both are must-questions for VCA*, VCA** and VCA Petrochemie.
The law applies as well. Under article 9 of the Arbowet (Dutch Working Conditions Act) , you report serious workplace accidents immediately to the Nederlandse Arbeidsinspectie (Netherlands Labour Authority) . On this page you can see how those two requirements fit together, how to set up an accident investigation and what the VCA auditor wants to see.
What must you report under VCA and what must you report to the Labour Authority?
The difference is simple. The law only requires you to report serious cases, while VCA wants to see everything, including near misses and unsafe situations.
| What happens? | Netherlands Labour Authority | Certification body (VCA) | Own register (VCA) |
|---|---|---|---|
| Accident resulting in death, permanent injury or hospital admission | Report immediately (Arbowet art. 9) | Report immediately, if it involves an employee within the scope of your VCA certificate | Yes |
| Accident with more than three working days of absence | Include in the accident register | No | Yes |
| Accident with absence, adapted work or first aid | No | No | Yes |
| Near miss | No | No | Yes |
| Unsafe situation or act | No | No | Yes |
| Damage or environmental incident without injury | No | No | Yes |
Reporting to the certification body is new in VCA 2026/6.1. Question 11.1 now requires serious incidents involving employees within the scope of your certificate to be reported directly to your certification body. VCA defines a serious incident as an incident that must be reported to the Netherlands Labour Authority under the law.
Not sure whether an accident must be reported? The Netherlands Labour Authority says: report it anyway. You can report day and night on 0800-5151 or through the online reporting form . A short hospital stay also counts.
The six categories of VCA incidents
VCA requires your register to be classified into fixed categories. Use the definitions from the checklist, so that everyone counts in the same way.
| Category | VCA definition | Example |
|---|---|---|
| Accident with absence or time lost | Injury that leads to one working day or more of absence, not counting the day of the accident | Fitter breaks a wrist and is off work for two weeks |
| Accident with adapted work | Injury without a day of absence, but temporary different work | Sprained ankle, one week of warehouse work |
| Accident without absence | Injury requiring medical treatment or first aid, with no absence | Cut that is stitched, back at work the next day |
| Near miss | Undesired event that, under different circumstances, could have led to injury | Scaffold board falls next to a colleague |
| Unsafe situation or act | Situation or act that could lead to injury or damage | Open trench without barrier; working on a ladder without a footing |
| Other VGM (safety, health and environment) incidents | For example material damage or an environmental incident | Leaking hydraulic hose on an excavator |
How do you set up an accident investigation under VCA?
Question 11.2 requires an investigation procedure that matches the (potential) seriousness of the incident. A near miss with a falling board therefore gets a different investigation than a broken leg. Your procedure must contain at least three things.
| VCA requirement (question 11.2) | Example in your procedure |
|---|---|
| Investigation focused on causes | ”We look for the underlying cause, not for someone to blame.” |
| Time limit for completion | ”Accident with absence: investigate within 5 working days. Near miss: within 10 working days.” |
| A person responsible for the investigation | ”Accident with absence: VGM officer (VGM-functionaris). Other incidents: site manager of the project.” |
After that, you determine corrective measures and carry them out, with someone who monitors the schedule. Where needed, you adjust your RI&E (risk inventory and evaluation) and your task risk analysis (TRA). Finally, you share the lessons internally, for example in a toolbox meeting.
For the cause analysis, you can use a simple method, such as asking “why?” five times. Read more about root cause analysis and the 5 whys method.
Example of a VCA investigation report
Below is a fictitious report of a near miss at a scaffolding company. It shows how to get from “what happened” to a measure that prevents recurrence.
| Field | Entry |
|---|---|
| Date and location | 2 October 2026, new build at Havenkade, north façade |
| Category | Near miss |
| What happened? | While finishing the building, a scaffold coupler fell from a height of 12 metres onto the walkway. Nobody was walking there. |
| Potential severity | High: fatal injury possible |
| Investigator and deadline | VGM officer, completed within 5 working days (potentially serious) |
| Why? | Answer |
|---|---|
| Why did the coupler fall? | It was lying loose on the work floor and was knocked off. |
| Why was it lying loose? | There was no material bin on that floor. |
| Why was there no material bin? | It was not included in the TRA for finishing work. |
| Why was the walkway open? | The barrier had been removed earlier that day for a delivery. |
| Root cause | Finishing work had not been prepared as a separate task with its own measures. |
| Measure | Responsible | Deadline | Status |
|---|---|---|---|
| Create a TRA for “finishing scaffolding” with a material bin and a fixed barrier | Site manager | 9 October 2026 | Completed |
| Remove a barrier only with the site manager’s approval | Project manager | Immediately | Completed |
| Toolbox talk on falling objects for all crews | VGM officer | October | Planned |
VCA incident figures and the IF calculation
VCA uses the incident frequency index (IF): the number of accidents with absence per million hours worked. If you do not know the exact number of hours worked, VCA uses 1,600 hours per full-time employee.
IF = (number of accidents with absence × 1,000,000) / number of hours workedFor example: 25 full-time equivalents (FTE) × 1,600 hours = 40,000 hours. Two accidents with absence give an IF of (2 × 1,000,000) / 40,000 = 50. Count temporary agency workers and other temporary employees as well.
The auditor checks the accident statistics at every audit. You communicate the figures to your employees at least once a year (question 11.1), and they return in the management review (question 1.6).
What does the VCA auditor want to see for incidents?
- A reporting procedure or form, and employees who know how to report
- A register classified into the six categories
- Current examples of how you communicate your accident figures
- An investigation procedure, investigation reports and an overview of corrective measures
- Evidence that lessons have been shared, for example in toolbox meeting records
No reports at all is a red flag for an auditor, not a compliment. It usually means people are not reporting. A healthy company has many reports of near misses and unsafe situations.
Frequently asked questions about accident investigation under VCA
Do I need to report a near miss to the Labour Authority?
No. The reporting duty under the Arbowet applies to accidents resulting in death, permanent injury or hospital admission. You record and investigate near misses for VCA.
How do you encourage people to report near misses?
Make reporting easy, for example with an app or a card in the van. Give each reporter feedback within a week. Discuss good reports in the toolbox meeting, without names if the reporter prefers that.
Does an accident involving a subcontractor count towards my IF?
The IF covers the company or unit being certified, including temporary workers. A self-employed person who works under your authority also counts, according to appendix B of the checklist.
More information
- VCA workplace inspection - Finding unsafe situations before anything happens
- Task risk analysis (TRA) - Adjusting after an incident
- VCA 2026/6.1: what changes? - All changes
- Netherlands Labour Authority (Nederlandse Arbeidsinspectie): workplace accidents - Reporting duty and accident register