What is an Incident Report?

Beyond Administrative Requirements

Far from being a mere compliance checkbox, the incident report is the fundamental unit of organisational safety intelligence. Under the Model Work Health and Safety Act and international standards such as ISO 45001, these reports provide the "who, what, where, and when" that allows investigators to determine the "why" behind safety failures through systematic incident investigation.

The scope of what constitutes an incident has expanded significantly over the past decade. Modern safety management now encompasses not only evident physical trauma but also latent system failures and psychological risks. This broader view recognises that every incident, regardless of outcome, represents a valuable opportunity for learning and improvement.

What Must Be Reported

Contemporary incident reporting captures the entire spectrum of unintended outcomes. Organisations should document every event that provides safety intelligence, from catastrophic failures to simple hazard observations.

From Lagging to Leading Indicators

Historically, incident reporting was treated exclusively as a lagging indicator—a metric of failure. Organisations measured safety performance by counting Lost Time Injuries and striving for zero. This approach was fundamentally flawed.

Modern safety philosophy, often termed "Safety II," reframes the incident report as a tool for understanding operational reality. A high volume of incident reports—particularly for near misses and minor hazards—is now viewed as a leading indicator of a robust safety culture. It suggests an environment where workers feel psychological safety, allowing them to report issues without fear of retribution.

Conversely, a workplace with zero incident reports is statistically improbable and often indicates a "culture of silence" where errors are hidden rather than managed. This insight is supported by Heinrich's Safety Triangle, which demonstrates that for every major fatality, there are dozens of minor injuries and hundreds of near misses. By rigorously reporting and analysing the base of the triangle, organisations can identify systemic risks and implement corrective actions before incidents escalate.

Australian Legal Requirements

Under the Model Work Health and Safety Act (implemented in most Australian jurisdictions), the Person Conducting a Business or Undertaking (PCBU) has a non-delegable duty to maintain incident records and notify regulators of specific serious events. This creates a critical distinction that many organisations misunderstand.

Every incident should be recorded internally for due diligence and continuous improvement. However, only a subset of serious incidents must be reported to state regulators such as SafeWork NSW or WorkSafe Victoria immediately. This bifurcation means understanding notification thresholds is essential for compliance.

Notifiable Incidents Under the WHS Act

Section 35 of the WHS Act defines notifiable incidents as the death of a person, a serious injury or illness, or a dangerous incident. The thresholds are objective and based on the treatment required or the nature of the event, rather than the outcome alone.

For notifiable incidents, the PCBU must notify the regulator immediately by the fastest possible means (typically telephone), and the incident site must not be disturbed until an inspector attends or grants permission. The only exceptions are to assist an injured person, remove a deceased person, or make the site safe to prevent further incidents.

Failure to notify is a criminal offence. Maximum penalties for corporations can reach $80,000, with individual officers facing fines up to $16,000. These penalties reflect the importance the legislature places on transparency and regulatory oversight.

The 2025 Psychosocial Safety Reforms

In December 2025, Safe Work Australia published transformative amendments to the Model WHS Act that fundamentally expand the scope of incident reporting. These reforms introduce "Violent Incidents" as a distinct notifiable category, recognising that psychological harm can be as debilitating as physical trauma.

The new violent incident category includes sexual assault, physical assault (including with bodily fluids), deprivation of liberty, and credible threats where the person has the intent and means to carry them out. Critically, it also covers work-related suicide and extended absences of 15 or more consecutive calendar days due to work-related psychological injury.

The amendments include specific privacy protections. While the PCBU must notify the regulator of the occurrence of a violent incident, they are explicitly not required to provide sensitive identifiers such as the names of alleged victims or perpetrators of sexual assault in the initial notification. This balances regulatory visibility over psychosocial risks with the protection of those involved.

The Anatomy of an Effective Report

To satisfy both legal notification requirements and internal investigation needs, an incident report must be comprehensive yet concise. The legal weight of a report relies on objectivity—subjective language, assumptions, and emotional descriptors can compromise utility and create liability during litigation.

Reports should focus exclusively on observable facts. Instead of writing "the worker was careless," document "the worker was not wearing the required safety glasses." Rather than "the floor was slippery," record "there was a 20cm pool of hydraulic fluid on the floor." Specificity aids investigation and avoids the pitfalls of subjective interpretation.

A well-structured report captures administrative metadata (unique reference ID, date and time of incident, date reported), the "five Ws and H" (who, what, where, when, why, how), categorisation and consequence details (incident type, severity rating, injury specifics), and immediate actions taken to preserve the scene and make it safe.

The Economic Case for Reporting

Incident reporting is often mischaracterised as an administrative burden, yet economic data suggests it is a critical value protection mechanism. Safe Work Australia, in partnership with Deloitte Access Economics, estimated the total cost of work-related injury and illness to the Australian economy at $28.6 billion annually.

The "iceberg theory" of cost suggests that for every dollar of direct insured costs, an organisation incurs between $3 and $10 of indirect uninsured costs. These hidden expenses include lost productivity, retraining, investigation time, and damage to plant and equipment. Effective reporting of minor incidents allows organisations to intervene before a major, costly event occurs.

The Deloitte analysis indicates that eliminating work-related injury would add 185,500 full-time equivalent jobs to the Australian economy and increase wages by 1.3%. For individual organisations, robust incident reporting is not a cost centre—it is a strategic investment in operational continuity and workforce protection.

Overcoming Barriers to Reporting

The primary obstacle to effective incident reporting is fear—fear of blame, fear of discipline, or fear of peer ridicule. If a worker believes that reporting a near miss will lead to a drug test or a formal warning, they will simply hide the event. This creates a dangerous culture of silence.

To combat this, organisations must adopt a "Just Culture" that distinguishes between human error (honest mistakes requiring training and system design improvements), at-risk behaviour (shortcuts requiring coaching), and reckless conduct (deliberate rule violations that may require discipline). A Just Culture ensures that workers are not punished for honest reporting.

This approach is supported by the WHS Act itself, which makes it an offence to engage in discriminatory conduct against a worker for raising a safety issue or performing a safety role. Discriminatory conduct includes dismissal, demotion, or detrimental alteration of duties. The legal framework and modern safety science are aligned: organisations must protect and encourage reporting.

Digital Systems and Modern Workflow

While the WHS Act does not mandate a specific format, the industry has shifted decisively toward digital reporting systems. Mobile applications allow workers to report from the field, attaching photos and GPS data instantly. This reduces the friction of reporting and significantly improves data quality.

Digital platforms enable workflow automation, automatically routing serious incidents to legal and executive teams while sending minor hazards to maintenance. This ensures critical risks are not buried in paperwork. Perhaps most importantly, digital systems enable data analytics, allowing organisations to aggregate information and identify trends such as injury hotspots or time-of-day patterns that would be invisible in paper-based systems.

The WHS Act imposes strict record-keeping duties regardless of format. Incident notifications must be kept for at least five years from the date of notification, and records must be readily accessible to WHS inspectors upon request. Records relating to hazardous exposure may need to be kept for 30 to 75 years depending on the jurisdiction and substance.