Accident/Incident Investigation Policy

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1.0 INTRODUCTION The purpose of this policy is to identify the duties, roles, and responsibilities of workplace parties so that an effective and immediate Accident/Incident Investigation program is in place. This will include identifying the root causes of all contributing factors of every negative event and making the necessary recommendations to prevent reoccurrence. 2.0 APPLICABILITY All Beer Store (TBS) and Brewers Distributers Ltd. (BDL) employees, temporary employees and contractors working at TBS/BDL are expected to abide by this policy as a condition of their employment or contract. TBS/BDL recognizes that all Health and Safety accidents and incidents must be reported and investigated. 3.0 DEFINITIONS Accident: A preventable, unplanned, work related event, or exposure, or series of events/exposures that result in personal harm and/or damage. Critical injury: an injury of a serious nature that meets one or more of the following criteria: places life in jeopardy; produces unconsciousness; results in substantial loss of blood; involves the fracture of a leg or arm but not a finger or toe; amputation; burns to a major portion of the body; and/or the loss of sight in one or both eyes. *Corporate health and safety must be contacted immediately if a critical injury occurs First Aid: an injury where a first aid attendant or first responder attends to the injury and does the following: cleaning minor cuts, scrapes, or scratches; treating a minor burn; applying bandages, dressings, cold compress, cold pack, ice bag, splint; changing a bandage or dressing after a follow-up observation visit; and any follow-up for observation purposes only. Health Care/Medical aid: includes services requiring the professional skills of a health care practitioner (i.e., a doctor, nurse, chiropractor, physiotherapist or dentist) and services provided by hospitals and health facilities. Incident/Near Miss: An event or action that did not result in an injury to a person or property damage. An event that under different circumstances could have resulted in physical harm to an individual or damage to the environment, equipment, property and/ or material. Investigation Team Any individual that witnessed the negative event. The supervisor or manager of the location will take the primary lead in accident investigation. To the extent possible, the Health and Safety Representative/Joint Health and Safety Committee Member should be included in the investigation process. Lost Time: An injury or incident that prevents the employee from returning to work for their next scheduled shift. Personal Injury: Any event or action that results in physical harm to a person. The event may not require first aid or health care but impairs the ability of a worker from performing tasks pain free. If the injury could potentially escalate toward receiving first aid or health care, it must be categorized as a personal injury. Property Damage: Includes any physical damage to equipment, facilities, materials, product, property, tools, etc., regardless of ownership (i.e., including damage to third-party, public, or other non TBS/BDL property).

Root Cause Analysis (RCA) A method of accident prevention where more complex incidents are investigated to find the most elemental cause(s) to prevent reoccurrence. Site Manager For the purposes of this policy Site Manager includes Store Managers, Distribution Centre Managers, Supervisors and any other salaried position. Workplace Violence The exercise of physical force by a person against a worker, in a workplace, that causes or could cause physical injury to the worker; An attempt to exercise physical force against a worker, in a workplace, that could cause physical injury to the worker; and/or a statement or behaviour that it is reasonable for a worker to interpret as a threat to exercise physical force against the worker, in a workplace, that could cause physical injury to the worker. 4.0 RESPONSIBILITIES & ACCOUNTABILITIES 4.1 Managers and Supervisors (Site Managers) shall: Ensure an effective Accident/Incident Investigation Policy is implemented and followed; Participate in the Accident/Incident Investigation, including signing appropriate reports; Management personnel are specifically responsible for completing AI reports; Ensure corrective measures are taken to prevent reoccurrence; Ensure Modified Duties are offered in writing to all worker injured in the workplace; and To the extent feasible, notify the Joint Health and Safety Committee/Health and Safety Representative of all work related accidents/incidents. 4.2 Workers shall: Immediately report to Site Manager/designate the accident/incident; Immediately report to the Site Manager/designate any incidents, property damage or unsafe work situations and provide necessary details to the supervisor; Notify the Site Manager immediately where medical attention is required; Actively participate in the investigation; and Participate in the Return to Work Program. 4.3 Wellness Services Shall Assist locations when required, based on nature of injury; Follow up when report is identified as health care and/or lost time; and Require all supervisors/managers to accurately complete entire A/I report. 4.5 Joint Health & Safety Committee/Worker Health & Safety Representative shall: To the extend possible, participate in investigations, and completion of appropriate documentation; Review incidents at regularly scheduled JHSC meetings; Make recommendations to prevent recurrence of similar accidents or incidents; and Ensure that Accident/Incident Investigations are carried out as required by this policy. 4.6 Corporate Health & Safety Review all Accident/Incident Investigation Reports and follow up as required; Ensure recommendations are appropriate and that preventative and corrective actions have been taken; Assist or provide direction as needed for implementation of corrective actions; Fulfill responsibilities if a Critical Injury occurs; and Provide necessary support as required.

5.0 REPORTING PROCEDURE Where a worker is involved in an accident in the workplace, the worker must report the event to their Site Manager immediately. This includes all incidents and events including property damage. If medical attention is necessary the employee is to notify their Site Manager prior to seeking medical attention. Failure to report any of the above is a violation of company policy that may result in disciplinary action. The Site Manager/designate is required to report the accident/incident through the Employee Portal A/I Report Form within 24 hours. Facts about the accident must be recorded on an Accident/Incident Investigation Report. Once the report is submitted it will automatically be sent to representatives from various departments. The Site Manager, Worker and JHSC Representative/Worker Health and Safety Rep, where possible, shall complete the investigation together. The report will include information on the cause of the accident and possible corrective actions. In conducting the accident/incident investigation and completing the Accident/Incident Investigation Report Form the Manager shall ensure the following has been completed. Assessment of the Scene Inspection of the site, equipment, material that were involved in the accident/incident; Site must be secured in the case of a critical injury; Sketches, drawings or photos can be used as tools to assist the investigators. Interviewing Interview employee(s) involved; witnesses Interview must be documented; Interview should be conducted as soon as possible; and Interview should be conducted one-on-one in a quiet place. Identifying Contributing Factors Factors to consider are; people, equipment, material, environment, process. The goal of the investigation is to find the underlying root cause(s) which will prevent these situations from reoccurring in the future. In many cases there will be multiple root causes. Completion of Report Record all findings of the accident/incident investigation on the Accident/Incident Investigation Report form. Ensure each applicable section of the form is complete. Make recommendations for corrective action, responsibilities must be assigned and with a due date. The completed report must be signed by the Supervisor, investigating team, person involved, and management. Operator Training Required Persons involved in the Accident/Incident Investigation process (supervisors, managers, JHSC members, designated worker safety representatives) will undergo formal, comprehensive training which will include the following: Incident investigation principles and procedures; Cause analysis and remedial corrective actions; and Investigation report writing and follow-up.

Completion of Accident/Incident Investigation Report Sections: Retail / Logistics (Top of the page) Check off appropriate boxes. Section 1 Details of Injury / Illness Please ensure all applicable categories are properly identified. Refer to definitions above. Personal Injury includes any physical harm to a worker regardless of first aid or health care. If health care, workplace violence or lost time is checked a complimentary document from Wellness Services will open. This document MUST be entirely completed. It will become part of the AI report. Is this injury/illness a Recurrence (are you aware of a pre-existing injury similar to the current one)? Section 2 General Information Complete general employee information. Ensure appropriate dates and times are indicated. If delay occurred please indicate reason for time lapse. For Logistics locations, if event occurred at a licensee the logistics use only section must be completed. Section 3 Description of Injury/Illness Identify body part affected. Indicate cause and nature of injury. If event or reason for accident is not listed please ensure it is recorded in the other section. Section 4 Description of Accident/Incident Use section to indicate in detail what happened. Include any sequence of events that led up to the accident. Attach separate page if additional space is needed. Task being performed must be indicated. Include any underlying reasons that contributed to this event. Answer questions that contain why. Section 5 Contributing Factors/Conditions Check off all potential reasons the event occurred. If items are not addressed, place reason in the other section. Section 6 Personal Protective Equipment Indicate PPE required and worn. Section 7 Property Damage (If Applicable) Describe the property which was damaged during the incident and nature of the damage Date reported and date discovered (if different). Section 8 Corrective Action & Prevention List in order of priority all actions that have been or will be taken to prevent reoccurrence. Include the person responsible for ensuring the corrective action is conducted and implemented and the date as to which it will be completed. This important section MUST contain actions or suggestions to prevent similar future events. Check if there is a Safe Operating Practice (SOP)/Job Hazard Analysis (JHA) that covers this task. Check if the SOP/JHA is adequate for the task conducted. Identify which Safe Work Practices will be reviewed with employees. Section 9 Witnesses / Co-Workers Provide names and phone numbers of all persons who witnessed or have information concerning the accident. All coworkers in immediate area must be interviewed concerning their knowledge of the accident. Attach summaries of interview and/or statements from witnesses. Section 10 Worker s Comments The worker can describe what happened in detail, including the sequence of events which preceded the incident. Signatures and Dates Health and Safety Rep or JHSC Member; Investigated by Manager/Supervisor; and Reviewed by District Manager/Regional Office (Retail) or DC Manager/Corporate Officer (Logistics) Director (if applicable).

Record of Changes Version # Date Section/ Paragraph Changes Made / Reason for Change Changed By 1.0 2009 Creation Creation Jeff Wilcox 2.0 2014 All Changes to the format and content Jeff Wilcox 3.0 2015 All Changes to the format and content Jeff Wilcox 4.0 2016 All Changes to the format and content Jeff Wilcox 5.0 2017 Title & Footer Moved the logo, changed the date. Sam Owen