SUB/Specific/TBT-SUB-007

Subcontractor Incident Reporting

Subcontractor & Supply Chain SafetySpecificSubcontractor Incident Reporting

Subcontractor Incident Reporting

Toolbox Talk Record

Ref: TBT-SUB-007  |  Issue: 1  |  Date: March 2026
PresenterProject
LocationDate

What?

  • Subcontractors must report all incidents, near misses, and dangerous occurrences to the principal contractor.
  • Under-reporting by subcontractors hides the true safety picture and prevents organisational learning.
  • RIDDOR 2013 requires notification to the HSE for specified injuries, diseases, and dangerous occurrences.
  • The principal contractor is usually the responsible person for RIDDOR reporting on construction sites.
  • Subcontractors must report incidents within the agreed timescales — typically within 1 hour of the event.
  • Near miss reporting is equally important — near misses reveal the same root causes as actual injuries.
  • Subcontractors must preserve the scene and cooperate fully with the principal contractor's investigation.
  • Failure to report incidents is a serious breach of contract and may result in removal from site.
  • CDM 2015 requires cooperation between all duty holders including subcontractors on incident management.
  • Incident data from subcontractors feeds into the project safety performance metrics and trend analysis.

Why?

Legal requirementRIDDOR requires notification of serious injuries and dangerous occurrences to the HSE.
Learning opportunityUnreported incidents and near misses prevent learning that could save lives elsewhere.
True safety pictureUnder-reporting masks real risks and prevents the principal contractor from managing them.
Contractual dutySubcontract agreements require prompt reporting — failure can result in removal from site.
Do Don't
  • Report all incidents, near misses, and dangerous occurrences to the site manager promptly.
  • Follow the principal contractor's incident reporting procedure and timescales.
  • Preserve the scene after an incident until told otherwise by the investigating team.
  • Provide accurate witness statements and cooperate fully with the investigation.
  • Report near misses with the same urgency as actual injuries — they have equal value.
  • Ensure your own workforce knows how and when to report incidents on this site.
  • Record the details of every incident including time, location, and persons involved.
  • Support the principal contractor in identifying root causes and corrective actions.
  • Share lessons learned from incidents with your own workforce and other sites.
  • Attend incident review meetings when invited by the principal contractor.
  • DON'T hide, minimise, or delay reporting any incident or near miss.
  • DON'T clean up or disturb the scene before the investigation team arrives.
  • DON'T instruct your workers to avoid reporting injuries to the principal contractor.
  • DON'T submit inaccurate or incomplete incident reports to avoid scrutiny.
  • DON'T treat near misses as unimportant — they are warnings of future injuries.
  • DON'T assume the principal contractor will discover the incident without your report.
  • DON'T refuse to cooperate with the investigation or provide witness access.
  • DON'T blame individuals without examining the systems and conditions involved.
  • DON'T wait until the end of the shift to report a serious incident.
  • DON'T fail to cascade lessons learned from incidents to your own workforce.

See also: Subcontractor Safety Management | Accident and Incident Reporting (RIDDOR)

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