Incident Investigation Program
Root cause analysis procedures, witness interviews, corrective actions, and recordkeeping.
What this document is
This document is a written Incident Investigation Program that sets out clear procedures for examining workplace events. It guides employers through root cause analysis, witness interviews, corrective actions, and proper recordkeeping.
The regulation that requires it
29 CFR 1904 and T8 CCR §3203 require employers to investigate and document work-related injuries and illnesses. The federal rule in 29 CFR 1904.39 and the California rule in T8 CCR §3203(a)(4) both mandate procedures to identify and correct hazards. These standards require employers to maintain records that show how incidents are reviewed and how repeat events are prevented. California contractors must follow the stricter Title 8 language in addition to federal requirements.
Who needs it
General contractors, subcontractors, and specialty trades in construction need this program. Any employer with employees in California must comply with T8 CCR §3203. Employers in states that follow federal OSHA rules still need to meet 29 CFR 1904 recordkeeping and investigation duties. Small and mid-size contractors face the same obligations as larger firms when an injury or illness occurs.
What happens without it
OSHA and Cal/OSHA can issue Serious citations with penalties in the current range of several thousand dollars per violation. Willful or repeated violations carry significantly higher fines under the published OSHA penalty schedule. Inspectors routinely check investigation records during site visits, and multi-employer work sites can result in citations to both the controlling contractor and subcontractors. Lack of a written program increases the chance of repeat violations and higher penalty tiers.
What's included in the generated document
- Purpose and scope statement
- Definitions of recordable incidents
- Step-by-step investigation procedure
- Root cause analysis methods
- Corrective action tracking form
How to implement it at your company
- Talk to Guy first. Describe your operation, trade, and location — Guy draws from 300,000+ verified OSHA and state regulatory citations to build a compliance plan specific to your company. Your answers shape every section of the document you receive. Takes about 10 minutes.
- Assign a competent person to lead all incident investigations.
- Train supervisors on the written procedures and interview techniques.
- Use the provided forms to document every recordable event within the required timelines.
- Review completed investigations in monthly safety meetings and track corrective actions to closure.
- Keep all records for the period required by 29 CFR 1904 and T8 CCR §3203.