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SAUE: When to investigate and notify the enforcement authority
We updated our guidance on significant accidental or unintended exposures (SAUE) on 24 August 2020.
The employer’s responsibilities are set out in Regulation 8(4).
As the employer, if you suspect, or are informed, that a SAUE has, or may have occurred, you must first carry out a preliminary investigation as soon as possible.
If the preliminary investigation shows beyond reasonable doubt that the incident meets the specified criteria for a SAUE, you must notify the appropriate enforcing authority as soon as possible.
This means that, depending on the circumstances, employers need to make the notification no later than 2 weeks after discovering the incident. You must then carry out a detailed investigation of the circumstances of the exposure or arrange for this to happen.
Keeping records of investigations
There must be a record of the investigations and what they found. You need to keep these records in accordance with your local procedures and with Regulation 8(3). You must do this regardless of whether an incident needs to be notified to the appropriate enforcing authority or not.
For SAUE incidents, you must send a report on the outcome of the investigation to the appropriate enforcing authority. The report should include:
- what happened
- an estimate of the dose(s) received by the exposed individual(s)
- a detailed account of the root causes and contributory factors
- whether any similar previous incidents have occurred where individuals might have been over or under exposed, or if there are any trends that show a possible systematic failure
- whether local duty of candour requirements have been met
- whether local procedure, required under Regulation 8(1), schedule 2(l), has been applied
- any learning from the investigation and how this has been shared
- the corrective measures adopted and/or remedial actions implemented to reduce the likelihood or prevent this type of incident from happening again.
The appropriate enforcing authority needs to receive the investigation report as soon as possible, regardless of the severity of the incident or any complications. Employers need to submit the report no later than 12 weeks after the incident was discovered. This is irrespective of any timeframes of a health board or an employer’s own timeframes for reporting serious incidents.
You must redact names of individuals in the report to comply with GDPR requirements.
If you cannot submit the report within the expected timeframe, you need to discuss with an inspector from the appropriate enforcing authority as early as possible.
- Last updated:
- 21 August 2020