Contractor incident evidence handover between New Zealand PCBUs

An incident on a shared site may involve a subcontractor's worker, equipment controlled by another business and an area managed by the principal contractor. In the first hours, people need care and the scene may need preserving. Then the PCBUs must exchange accurate information so notification, investigation, corrective action and communication do not fall between organisations. A handover is a controlled transfer of facts and ownership, not an attempt to decide liability in a spreadsheet.

WorkSafe New Zealand's guidance on PCBUs working together explains overlapping duties in contracting chains. Its notifiable-events guidance says only one notification is required per event, but all relevant PCBUs are responsible for ensuring it is made. This page concerns evidence and decision transfer between businesses, separate from a generic incident-report form or an account of HSWA duties.

Protect people and control the scene first

Arrange emergency assistance, first aid and immediate protection under the site's emergency plan. Stop affected work and prevent others entering a danger area. If the event may be notifiable, check WorkSafe's current requirements for preserving the site; do not move equipment or alter the scene except where legally permitted for care or safety. Record who took each immediate action and when. A digital report should never delay urgent help.

Avoid guessing at the event category. The nominated competent person should assess the facts against WorkSafe's current notifiable-death, injury/illness and incident definitions. If uncertain, seek advice promptly. Preserve the observations needed to make that decision and record the reasoning, including any information still missing.

Establish one shared incident identity

Agree a case reference, site, exact location, date, time and businesses involved. Identify the affected person and equipment through controlled records, with privacy safeguards. Link each PCBU's internal report to the shared reference rather than merging sensitive personnel files into one unrestricted folder. The first report can be incomplete; label later facts as updates instead of silently rewriting the original account.

Capture direct observations, photographs or measurements with source and time. Separate a witness statement from a manager's inference. Record which party has custody of physical evidence and how it will be preserved. If WorkSafe or police directs the investigation, follow that direction before taking site actions that could alter evidence.

Decide who notifies and confirm completion

Where the event is notifiable, the PCBUs should coordinate a nominated notifier and share the details needed for an accurate notification. WorkSafe's notifiable-events page says the regulator must be notified as soon as possible and that a single notice is required, while all PCBUs need to ensure it happens. Record who notified, when, by what route and the acknowledgement or reference. Other parties should not assume a contractor did it merely because the contract said they would.

If it is not notifiable on the facts known, record the assessment and who will revisit it if new information arrives. A later diagnosis or new account can change the picture. No software status should be presented as a binding legal determination.

Hand over the open actions

List immediate restrictions, medical follow-up, worker or family contact, evidence preservation, regulator response, internal review and corrective controls. For each action, name the PCBU and person able to perform it, a due point and the confirmation needed. A line saying “principal contractor to follow up” is too vague if the underlying equipment belongs to a subcontractor.

The parties should agree access to information relevant to their duties without sharing more personal data than necessary. A contractor may need to know that an area remains closed, but not every detail of an injured worker's health record. The WorkSafe overlapping-duties position expects consultation, cooperation and coordination according to influence and control.

Example: shared traffic route incident

A subcontractor driver strikes a barrier in a site delivery route used by several trades. The principal contractor stops movement through the area and checks for injury; the subcontractor secures the vehicle and supplies driver and vehicle facts. Both parties preserve relevant photographs and records. They assess whether WorkSafe notification is required and agree who will make it, recording the outcome and reference. The principal contractor owns the site-route control review, while the subcontractor owns the vehicle inspection. Neither closes the event until the other confirms its action and the affected crews are briefed.

The handover shows what each PCBU controlled, what was shared and what remains open. It does not declare fault.

If one party leaves the site before the assessment is complete, identify a reachable contact and a deadline for supplying records. The remaining PCBU should record which evidence is still held by the departing contractor, whether access to the scene is restricted and who will communicate any new notifiability information. The receiving person must acknowledge the open items. A handover sent by email without confirmation can leave both businesses believing the other is acting.

Review investigation and lessons together

If an investigation proceeds, maintain an evidence log with version and access controls. Share findings needed to correct shared risks. A revised traffic plan may be ineffective unless the contractor changes its delivery booking process too. Record verification in the field rather than closing every action after a meeting. Keep the original event timeline, notification decision, protective steps, investigation findings and corrective evidence traceable.

For a current-product discussion, see Complys New Zealand contractor management software and verify how present records and named owners can support inter-business follow-up. This guide does not claim Complys decides notifiability, notifies WorkSafe, preserves a physical scene, investigates automatically or transfers PCBU duties.