Treadstone Associates
Guide

An incident response runbook for a site

The first hour after an incident isn't the time to be looking up which form applies. This is the sequence to have memorized before it happens, with the regulatory clocks that start the moment it does.

Treadstone Associates · Updated 2026

Key takeaways

  • • Stopping the hazard and getting people safe comes before anything else in this runbook — including before any call to a regulator.
  • • Ontario's OHSA s.51(2) allows the scene to be disturbed only for a limited set of purposes — rescue, preventing further injury, maintaining public safety. Tidying up beyond that is a separate problem you're creating.
  • • Whether an injury meets Ontario's verbatim 'critical injury' definition determines which regulatory clock applies — and BC runs an entirely separate 48-hour preliminary / 30-day full reporting structure under its own Workers Compensation Act.
  • • A work refusal under OHSA s.43 is a parallel, separate process with its own rules — not a step inside this runbook.

STEP 01 OF 10

Stop the hazard and get people safe, before anything else

Nothing in this runbook happens before this step. If the hazard is still active — equipment still running, a structural failure still in progress — controlling it and getting people clear takes priority over every notification, documentation and reporting obligation that follows.

This step has no clock attached to it, unlike almost everything else in this guide. It's not sequenced after anything; it's the precondition for every step that comes next.

STEP 02 OF 10

Provide first aid and call emergency services if needed

This also has no clock — it happens the moment it's needed, in parallel with hazard control, not after it. A site with a trained first-aider and a clear internal alert method moves through this step faster than one improvising in the moment.

STEP 03 OF 10

Preserve the scene within the limits the law actually allows

Ontario's OHSA s.51(2) permits disturbing the scene of a fatality or critical injury only for limited purposes: rescue, preventing further injury or damage, or maintaining public safety. Tidying beyond that — moving equipment to "make it safer-looking," clearing debris before it's documented — creates a separate problem layered on top of the incident itself.

If something genuinely must move for one of the permitted reasons, photograph its position first, and note who moved it, when, and why. That record protects the integrity of the investigation that follows.

Restrict site access to essential personnel only until the scene has been documented. A curious crowd of coworkers, however well-intentioned, is itself a risk to the scene's integrity and to their own safety around an unresolved hazard.

STEP 04 OF 10

Determine whether the injury meets Ontario's critical-injury definition

O.Reg 420/21's verbatim definition covers an injury that "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; involves the amputation of a leg, arm, hand or foot but not a finger or toe; consists of burns to a major portion of the body; causes the loss of sight in an eye" (ontario.ca). Ministry interpretation extends "leg" to include the ankle or foot, "arm" to include the wrist or hand, and treats a fracture or amputation of more than one finger or toe as critical.

This determination decides which clock applies for the rest of this runbook. Make it deliberately, against the actual definition, rather than by instinct — a borderline injury misclassified in the first few minutes can put the wrong reporting timeline in motion.

STEP 05 OF 10

Make the immediate notification call

A fatality or critical injury in Ontario requires immediate notice to the Health and Safety Contact Centre (1-877-202-0008, available 24/7), the JHSC or health and safety representative, and the union. In BC, WorkSafeBC requires immediate notification when a worker is seriously injured or killed, there's a major structural failure or collapse, a major hazardous-substance release, a fire or explosion with injury potential, or a blasting incident resulting in injury — contacted through the Prevention Information Line (worksafebc.com).

Know both lists before an incident happens, not during one. The categories differ enough between the two provinces that a site operating in both needs both lists posted, not one generic "call the regulator" instruction.

STEP 06 OF 10

Notify internally in parallel with the external call

The JHSC (or health and safety representative) and the union both need notice under OHSA s.51/52, at the same time as the external regulatory call, not sequenced after it. One notification doesn't substitute for the other — both are required, independently.

STEP 07 OF 10

Start the written-report clock in your own tracker

Ontario requires a written report within 48 hours for a critical injury, and separately requires an employer's WSIB report within three business days of the reporting obligation beginning (wsib.ca: "we must receive your completed accident report within three business days after your reporting obligation begins"). WSIB's page states that late or non-reporting is against the law and can carry "a financial penalty as well as prosecution," without naming a specific dollar figure on that page.

BC runs a different structure entirely: a preliminary investigation report is due within 48 hours, and a full investigation report within 30 days, under Workers Compensation Act s.69 and WorkSafeBC Prevention Policy items P2-71-1 and P2-72-1 (worksafebc.com). The OHS Regulation's own s.3.4 on investigation reports was repealed effective 1 February 2016 (B.C. Reg. 195/2015) — the current requirement lives in policy, not the Regulation itself.

Three separate clocks can be running at once — Ontario's OHSA 48-hour report, WSIB's 3-business-day accident report, and (if the site is in BC) WorkSafeBC's 48-hour preliminary report. Track each one individually; meeting one doesn't satisfy another.

STEP 08 OF 10

Know the boundary with a work refusal

OHSA s.43 gives a worker the right to refuse unsafe work on specific grounds, and if a worker invokes it over the same underlying hazard, that becomes a parallel, separate process — with its own rule that the refusing worker "must remain in a safe place that is as near as reasonably possible to his or her workstation" until an investigation, conducted "immediately, in the presence of the worker," is complete. This is not a step inside the incident-response runbook itself; it runs alongside it, with its own procedure.

Know the distinction before it matters. Treating a work refusal as just another item on this runbook's checklist, rather than its own parallel process, is how the refusal process gets handled incorrectly under the pressure of an active incident.

STEP 09 OF 10

Assign one person to own external communication

Insurer contact, the WSIB claim, media inquiries if any arise — name one accountable person for all of it, so the site crew isn't simultaneously managing the immediate aftermath and fielding calls that pull attention away from it.

This person doesn't need to be the same one who made the immediate regulatory notification in step five — the notification is time-critical and needs to happen fast; the ongoing external-communication role is a different, more sustained responsibility.

Name this role in the runbook itself, before an incident happens, the same way the health and safety management system names an accountable owner for its own review cycle. A role assigned in the moment tends to default to whoever happens to be available, not who's actually best positioned for it.

STEP 10 OF 10

Debrief and file within 48-72 hours, before memory fades

Even though the full written report isn't due for days (or, in BC's case, up to 30 for the full investigation), start writing down what happened while the details are still fresh. A debrief captured 48-72 hours out is measurably more accurate than one reconstructed from memory once the formal report deadline finally arrives.

This early file becomes the working draft for whichever formal report is due — not a separate document that gets discarded once the official one is filed.

Common mistakes

Disturbing the scene beyond what s.51(2) actually permits. Rescue, preventing further injury, and maintaining public safety are the named exceptions. Cleaning up to make the site 'look better' before the investigation is a separate compliance problem layered onto the original incident.

Treating the internal JHSC notification as interchangeable with the external regulatory call. Both are independently required under OHSA. Making one call and assuming it covers both obligations leaves one of them unmet.

Waiting for the full report deadline to expire before writing anything down. Memory degrades fast. Start the debrief within 48-72 hours regardless of when the formal report is actually due, so the eventual report is built from a contemporaneous account, not a reconstruction.

Assuming meeting one reporting clock satisfies all of them. Ontario's OHSA report, WSIB's accident report, and BC's WorkSafeBC reports are separate obligations to separate bodies. Filing one does not stop another clock from continuing to run.

The reporting clocks, worked

Scenario. An incident occurs at 10:00am on Tuesday, 18 August 2026, at a BC site. The preliminary investigation report, due within 48 hours, is due by 10:00am Thursday, 20 August 2026. The full investigation report, due within 30 days, is due by 17 September 2026. If the same site were in Ontario and the injury met the critical-injury definition, the written report to the Ministry would be due within 48 hours — the same 20 August deadline as BC's preliminary report — but Ontario has no 30-day full-report equivalent; instead, WSIB's separate 3-business-day accident-report clock would also be running from whenever the reporting obligation began. Three different clocks, three different documents, none of them satisfied by completing another.

Where the reporting structure genuinely differs by province

  • Ontario: immediate notice for a fatality or critical injury, a 48-hour written report for critical injuries (4 days for non-critical), plus a separate WSIB accident report due within 3 business days.
  • British Columbia: immediate notice for five named serious-incident categories, a 48-hour preliminary investigation report, and a 30-day full investigation report — governed by Prevention Policy, since OHSR s.3.4 was repealed in 2016.
  • • Neither province's clock structure transfers to the other. A site running crews in both needs both runbooks posted, not one generalized version.

Frequently asked

Does a work refusal count as an incident requiring this runbook?

Not on its own — a work refusal under s.43 is a separate, parallel process with its own investigation and 'remain in a safe place nearby' rule. If the refusal follows an actual incident, both processes run side by side, but the refusal itself doesn't trigger this runbook.

What if the injury doesn't meet Ontario's 'critical' definition — is there still a clock?

Yes. A non-critical injury still requires written notice to the JHSC or representative and the union within four days, distinct from the 48-hour critical-injury report and separate again from WSIB's own 3-business-day accident report.

Who decides whether police need to be called?

That's a scene-specific judgment call for whoever is managing the immediate response, generally guided by whether the incident involves a fatality, a criminal element, or a public-safety risk. It sits alongside, not instead of, the regulatory notifications in this runbook.

Does WSIB's 3-business-day clock run separately from OHSA's 48-hour clock?

Yes — they're two distinct obligations to two different processes, and satisfying one does not satisfy the other. Track both independently from the moment the incident occurs.

Is the emergency-services call ever delayed by the regulatory notification steps?

No, and it should never be. First aid and emergency services come before any regulatory call in this runbook's order — the sequence exists precisely so the two are never confused under pressure.

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