## The Factory's Packaging Line #3 is Still Running
The packaging line #3 at that factory is still running. The only changes are a transparent cover added to the roller and the fact that the machine automatically stops when you open that cover. Just three months ago, no one could guarantee whether that line would be running next year.
I am an administrative agent based in Songdo, Yeonsu-gu, Incheon. Let me introduce you to an episode I encountered while working. 🏭
This story begins with a finger fracture. It wasn't a major accident. However, that single case almost caused a small factory with twenty-six employees to lose more than half of its client’s sales. The problem wasn’t the accident itself, but the fact that there was a document missing that needed to be taken care of afterward. And in the process of finding that missing document, the real cause, which no one knew, was revealed.
## Checklist from the Main Client
On Tuesday morning of the first week of September, a long email arrived in our office’s inbox. It was from a woman in her early thirties, the representative of a corrugated cardboard packaging factory in an industrial complex in Incheon. The person who referred us was the president of a neighboring company who we helped with factory registration changes a few years ago.
Attached to the email was a ‘Cooperative Company Safety and Health Level Assessment’ request form from the food company, which accounts for nearly 60% of the factory’s sales, i.e., the main client. The main client reassesses cooperative companies every autumn to reflect the results in the next year’s contract volume, and this year, the assessment items have noticeably increased. The submission deadline was September 26th. There was also a note stating that if the assessment result was ‘unsuitable,’ they would be excluded from the next year’s contract.
There was one item highlighted in red at the bottom of the request form.
"Cooperative companies with industrial accidents in the past year: Submission of a copy of the Industrial Accident Investigation Report and a status report on the implementation of preventive measures is mandatory."
The representative said they honestly wrote about the accident that occurred in August in the self-assessment section of the assessment form. But they said they stopped when they read this line. An Industrial Accident Investigation Report. It was a document they had never heard of before.
The factory had been run by her father for 25 years. The representative took over the factory a year and a half ago when her father retired. Before that, she worked in planning at a distribution company in Seoul. She was confident in sales and numbers, but the safety documents for the factory floor were an area that the previous factory manager had taken care of during her father’s time. That factory manager retired last spring due to health problems.
Her father’s loan guarantee was still attached to the factory building. Half of the twenty-six employees had been working there since her father’s time. If the main client’s volume is lost, the job prospects of those people will be jeopardized next year. The sentence she wrote at the end of the email was, "I want to know what I missed."
## The Date Seen Before the Meeting
The first thing I looked for when I read the email was the date of the accident. Monday, August 11th afternoon. A male worker in his late twenties working on packaging line #3 fractured his finger when it got caught in the roller, and the doctor’s opinion was a 3-week suspension.
Article 57 of the "Industrial Safety and Health Act" stipulates that employers must not conceal the fact of an industrial accident, and Article 73 of the "Industrial Safety and Health Act Enforcement Regulations" stipulates that if a death occurs or an injury requiring more than 3 days of suspension occurs, the employer must submit an Industrial Accident Investigation Report to the competent local employment labor office within one month from the date of the accident. In simpler terms, if an accident requiring more than three days of rest occurs, a report stating "this accident occurred, this is the cause, and we will prevent it like this in the future" must be submitted to the labor office within one month.
If the accident occurred on August 11th, the deadline would be around September 11th. The email arrived on September 2nd, leaving about a week. ⏰
It was within the deadline. Fortunately, but not comfortably. And the red line in the client’s assessment form required not only a copy of the investigation report but also a "status report on the implementation of preventive measures." Creating a plan and showing that the plan is being implemented are two completely different things.
I sent a reply. "I will visit your factory on Thursday morning at 10 am. Please prepare all records written on the day of the accident, and if you have a copy of the documents submitted by the worker to the Korea Workers’ Compensation & Welfare Service, please bring them along as well." This time, it was better for me to go to the factory. There are always things you can’t know just by looking at documents, and those things are always on the scene.
## Industrial Accident Application and Industrial Accident Report are Different Documents
Thursday morning, I arrived at the factory at the agreed-upon time. The representative was waiting in a small conference room on the second floor of the office building, documents spread out before him. They were a one-page accident report written by the work team leader on the day of the accident, a copy of the hospital’s diagnosis, and a copy of the application for rehabilitation benefits submitted to the Korea Workers’ Compensation & Welfare Service (COMWEL).
"The workers' compensation claim has been processed," the representative said, pointing to the application for rehabilitation benefits. "The worker applied to the COMWEL, and the company stamped the employer confirmation section. It was approved by the COMWEL, and I thought the reporting was finished with that."
This is precisely where many people get confused.
The application for rehabilitation benefits submitted to the Korea Workers’ Compensation & Welfare Service (COMWEL) is a 'compensation' procedure for injured workers to receive medical expenses and wage replacement benefits. The industrial accident investigation report submitted to the Labor Standards Supervision Office is a 'prevention' procedure for the employer to report the accident and disclose the cause and prevention plan. The receiving agencies, the people submitting, and the purpose are all different. Just because a rehabilitation application has been submitted to the COMWEL doesn’t mean that a separate report to the Labor Standards Supervision Office is unnecessary. Both must be handled separately.
The representative paused, looking down at the application for rehabilitation benefits, and asked, "So, is it already too late?"
"Not yet. However, to properly write this document, the cause section and the prevention plan section need to be filled in, which isn’t done in the current accident report."
The accident report written by the work team leader had one line written in the cause section: 'Worker negligence.' In the countermeasures section, it read 'Conduct safety education.' It was a document hastily written after visiting the hospital the evening of the accident. That was probably the best they could do at the time. However, if these two lines are directly transferred to the investigation report, there will be nothing to write in the 'Implementation Status of Prevention Measures' section of the prime contractor’s evaluation form. Saying "We conducted education" in one line doesn’t constitute implementation status.
## The Line Already Drawn
Fortunately, the factory had a certified labor consulting firm that had been handling 4 major insurance and payroll matters since the time of his father.
Therefore, the roles were divided as follows: The representative would draft and submit the industrial accident investigation report under his name, and a labor attorney from the labor law firm would be responsible for the final review. I would gather supporting documentation for the factual circumstances of the investigation report, create the framework for the entire prime contractor evaluation form submission materials, and be responsible for applying for safety and health corporation support. That afternoon, the labor attorney and I had a brief phone call to confirm this division of labor. The labor attorney said, "I will review the draft investigation report within two days."
There is an order to work, and that order is defined by deadlines. I spread out the calendar and counted backward. The target submission date for the investigation report was Tuesday, September 9th. There was no reason to drag it out until the last minute. Subtracting two days for the labor attorney’s review, one day for the worker’s representative’s confirmation, and one day for buffer time, the draft should have been out by Friday, September 5th. Today was Thursday, the 4th.
## The Weight of the Term "Serious Accident Punishment Act"
Towards the end of the meeting, the representative cautiously asked, "But, could we be punished under the Serious Accident Punishment Act? I’ve heard that even small factories like ours are covered."
This was the concern that the representative had been holding onto for the longest time after the accident. He said he had been searching the internet every night for articles like "Serious Accident Representative Arrested."
I explained two things.
One. "Serious Industrial Accidents" as defined in Article 2 of the "Act on Punishment, etc. for Serious Industrial Accidents" refers to cases where there is one or more deaths, or two or more injuries requiring more than six months of treatment due to the same accident, or three or more occupational diseases due to the same hazard within one year. This accident involved a fracture requiring three weeks of hospitalization for one worker. It does not fall under the definition of a serious industrial accident as defined by the law.
Two. However, this doesn’t mean that this law is irrelevant to this factory. Since the law began to apply to businesses with 5 or more but less than 50 regular employees, employers are obligated to establish and implement a safety and health management system. This is an obligation that exists before an accident occurs, not an obligation that arises after an accident. The prime contractor increasing the evaluation items this year was part of the same trend.
For now, what the representative needs to do is record, not worry. The representative wrote those words down in a notebook. For the first time that day, he seemed a little more relaxed.
## An Empty Spot
Friday morning, while filling in the basic information for the draft industrial accident investigation report, I discovered an unexpected blank space.
The prime contractor’s evaluation form included an item called “Status of Safety and Health Personnel.” When I asked the representative, he said his father used to handle that role when he ran the factory. What about after the factory manager retired in the spring? The representative didn’t answer.
The Industrial Safety and Health Act, Article 19, stipulates that businesses with 20 to 50 regular employees in certain industries must designate a safety and health manager, and manufacturing falls under this category. The manager must be an employee of the business with a safety manager or health manager qualification, or have completed safety and health training designated by the Ministry of Employment and Labor. This factory had 26 employees, so this position was necessary. However, that position had been vacant for five months.
The problem emerged elsewhere.
Flipping through the file left behind by the factory manager, I found a risk assessment record. However, the date was five years old. A form prepared with the help of an external agency was simply inserted, and no new records had been created since then. New equipment had been installed at the factory in the meantime. The packaging machine on Line 3, where the accident occurred, was installed last autumn. When new equipment is installed, a risk assessment specifically for that equipment should be performed, but that record was missing.
Opening the file to resolve one issue resulted in two more appearing. Administrative work often proceeds this way.
## Ballot Box Made of Tissue Box
The industrial accident investigation report requires confirmation from the worker’s representative. The enforcement regulations stipulate that the report should be confirmed by the worker’s representative, and if the worker’s representative has any objections to the content listed, those objections should be attached. This is intended to have the workers also take a look at the accident, rather than the company handling it alone.
However, this factory did not have a labor union. Nor had they ever elected a worker’s representative. According to the labor lawyer, if there is no labor union, a representative can be elected by a majority of the workers, and it is a good idea to document that process. The representative decided to hold the election immediately during lunch that day.
There was a small commotion. 😄 Since there wasn’t a suitable box to use as a ballot box, we emptied the tissues from an office tissue box and widened the top. Ballot papers were made by cutting A4 paper into eight sections. When the votes were counted, nineteen of the twenty-four votes were cast for one person. He was a man in his late 30s who had been driving a forklift at that factory for 12 years.
The actual candidate wasn’t even present when the votes were counted. He was on the forklift receiving incoming shipments. When his colleague ran to the warehouse to tell him the results, he got off the forklift, laughed for a while, and said, "Am I just supposed to sign it?"
It wasn’t just a matter of signing. And that fact changed the direction of this case.
## Reason for Leaving the Cover Off
When scheduling the explanation of the draft industrial accident investigation report to the worker’s representative for Monday morning, I suggested to the representative that we invite the injured worker and the workers who worked on Line 3 to a meeting to hear their accounts of the accident.
There was a reason for this. The prime contractor’s evaluation form had a separate item called “Implementation and Reflection of Worker Opinion Collection.” Moreover, if the “cause” section of the report simply stated “worker negligence,” the worker’s representative was likely to raise an objection. The report itself isn’t a problem if an objection is attached. However, a report that doesn’t properly identify the cause won’t generate content for the “preventive measures” that the prime contractor requires.
Monday morning break room. A worker who was still wearing a splint on his hand was present. He was about to return to work next week. He was in his third year of employment and was helping to pay his younger brother’s college tuition. Although unemployment benefits were being paid, they weren’t covering his usual overtime pay. What he was most worried about was that he would have to return to that machine.
The initial conversation was cautious. Then, the worker’s representative, the forklift driver, spoke up. “That cover has been off that machine for quite a while.”
A Moment of Silence, Then Stories Began to Emerge
The roller on the 3rd line packaging machine originally had a protective cover. However, when the cover was closed, thick cardboard would get caught on the edge of the cover, causing the line to frequently stop. Each time it stopped, the cover had to be opened and the caught box removed, but the cover was fixed with screws, so it had to be loosened with a screwdriver every time. This happened dozens of times a day. Then, someone removed the cover altogether and placed it on a shelf, and this continued for several months. On the day of the accident, the worker reached in to remove a caught box, and at that moment, the roller started moving again.
"Why didn't you mention this earlier?" the representative asked. The answer was calm. On the day of the accident, the priority was to take the injured person to the hospital, and the work team leader who wrote the accident report was not in charge of that line. The worker himself thought it was his fault for putting his hand in, so he didn't mention the cover. Others considered it insignificant, saying, 'Everyone has done it that way.' No one was trying to hide anything; no one simply asked.
It was only after this conversation that the sentence to be written in the cause section of the accident report form changed.
## Not Documents, But a Record Linked in a Single Line
That night, I returned to the office and reread the prime contractor evaluation form from the beginning. This time, I looked at the space between items, not just each item individually.
When I first read it, I saw this evaluation form as a 'list of documents.' Safety and health policies, hazard assessment records, appointed personnel status, training records, opinion-gathering records, industrial accident investigation report. A list that could be completed with one sheet for each. But rereading it, I realized that there were separate points for certain items. 'Has the hazard assessment result led to improvement measures?', 'Has the employee's opinion been reflected?', 'Has the same type of accident prevention measure been implemented after the accident?'. They weren't asking whether 'documents exist,' but whether 'the documents are linked to each other.'
Reading the regulations is easy. Seeing how one record should be linked to another is difficult.
So, I reorganized the plan. Instead of creating six separate documents, I decided to weave them into a single line of record starting with a single accident.
① In the cause section of the industrial accident investigation report, instead of 'worker carelessness,' it states that the cover was removed and work was performed with it removed due to the cover structure, which frequently got caught, and that there was no device to stop the machine while removing the caught box. This information came from the opinion-gathering session on Monday, so that session's record serves as the basis.
② In the recurrence prevention plan section, instead of just 'safety education,' it states the installation of an interlocking device (interlock) that stops the machine when the cover is opened and the replacement of the cover with a form that is less likely to get caught. Obtain a quote from a facility company and include the date.
③ Conduct a new hazard assessment for the entire factory, including the 3rd line packaging machine. This is not something that can be done with documents; it's something that needs to be done on-site. The business owner and workers must work together to inspect the machines, identify hazards, and determine what to fix and when. I took charge of applying for the Small Business Technical Support service from the Korea Occupational Safety and Health Agency. This was to have the factory people directly conduct the assessment with the guidance of a professional.
④ The vacant safety and health management personnel position is to be filled by someone who knows the factory's circumstances best. The representative recommended the production supervisor, and the supervisor agreed to complete the necessary training. Keep the training schedule and appointment documents together, and record in the prime contractor evaluation form the 'scheduled appointment date and training schedule.'
⑤ We also decided to apply for the Small Business Hazard Machine Improvement Support Project run by the Agency, which helps small businesses with fewer than 50 employees improve hazardous machinery, to cover some of the facility improvement costs. Selection is not guaranteed. However, simply applying creates another record that 'the improvement plan is actually in progress.'
The representative listened to the explanation and remained silent for a moment before saying, "The question I asked initially was 'what did we miss?' I thought we had missed a document, but we missed the connection."
The answer wasn't the number of documents, but whether the documents were linked to each other.
## Submission Two Days Before the Deadline
On Tuesday morning, the draft accident report was passed to the labor lawyer. After reviewing the draft with the changed cause section and recurrence prevention plan section, the labor lawyer asked for one change. It was to write the accident sequence of events more specifically in chronological order. The revised version was returned that afternoon.
Wednesday, the worker representative, a forklift driver, read the investigation form. The person who said on Monday, "Is it just a matter of signing it?" read it line by line this time. And pointing to the cause box, they said, "This is exactly what we talked about." They signed the confirmation box without objection.
The investigation form was submitted to the relevant labor and employment agency with the deadline two days remaining, on Tuesday, September 9. The representative submitted it directly, and we kept a copy with confirmation of receipt. We also secured a copy to submit to the prime contractor.
That Thursday, the application for a Public Corporation (공단) technical support was received, and a field visit date with the responsible person was scheduled for early next week. The equipment company sent a quote stating they could complete the interlock installation within two weeks. The representative said that on the day they stamped the contract, they personally moved the old cover from the shelf to the warehouse.
## The Day the Public Corporation Representative Visited
The following Wednesday, the Public Corporation technical support representative visited the factory. I also stopped by the factory that morning. It wasn't because I knew how to operate the machines. It was because to determine how to translate the information that came out that day into the prime contractor's data and the Public Corporation support project application, it was more accurate to hear it directly on-site.
The representative didn't start by looking at the documents. They took the representative and production manager, the worker representative, and two line 3 operators on a tour of the factory. The cutter, adhesive machine, packaging machine, and forklift aisle. Each time they stood in front of a machine, the representative asked the same question: "When is the most dangerous moment at this machine?"
The answers came from the operators, not the representative. That the order of turning off the power when sharpening the cutter blade varied from person to person, that the floor next to the adhesive machine was slippery due to glue, that during afternoon deliveries, forklifts and people used the same aisle. These were stories that were not in the hazard assessment form from five years ago. That form was filled out by an external company in the office.
The representative, explaining how to write the hazard assessment form, said, "This isn't something we write for you; it's something you people here write. I'll just check to make sure nothing is missing." It was the same story I had first told the representative. Hazard assessments aren't made on paper; they're done on-site.
That afternoon, I took care of two things. One was transferring the hazards identified during the site tour to the 'Hazard Assessment and Improvement Plan' section of the prime contractor's assessment. The prime contractor's format required hazards, risk levels, improvement measures, expected completion dates, and responsible parties to be written in one line, but the order was slightly different from the Public Corporation assessment form. To avoid discrepancies in numbers when writing the same content in both formats, we decided to use the Public Corporation assessment form as the original and transfer the prime contractor's format from there. The other was the equipment improvement support project application. In the 'Necessity for Improvement' section of the application, we wrote down the accident details, opinion-gathering records, and Public Corporation on-site guidance results in order. To have the flow of improvement – an accident occurred, the cause was identified, and expert guidance was received – contained in one application.
On the way back, the representative smiled and said, "I wasn't the one who talked the most today." That was the biggest achievement of the visit.
## What Was Submitted to the Prime Contractor, What Wasn't
When submitting the prime contractor assessment data on September 26, everything wasn't finished yet. The hazard assessment was just completing the first round with Public Corporation guidance, the interlock was being installed, and the safety and health management responsible person had completed about half of their training.
A choice had to be made. Wait until everything was finished and submit a perfect set of data, or differentiate between what was finished and what was in progress and submit it within the deadline?
I recommended the latter. Prime contractor assessments are treated as 'not submitted' if the deadline is missed. On the other hand, items in progress can be evaluated as 'in progress' if an implementation plan with dates and interim documentation is attached. Writing about unfinished work as if it were finished is absolutely not allowed, but writing about unfinished work with documentation of when it will be finished is actually a sign of diligence.
So, I divided the submission documents into three categories: Completed (submission of the industrial accident investigation report, election of a labor representative, consultation with employees, removal of the old cover), In Progress (1st and 2nd results of hazard assessment, interlocking installation contract and progress schedule, expected completion date of employee training), and Planned (annual safety and health education schedule, quarterly consultation schedule). I attached supporting documents for each category. And on the first page, I drew a diagram in a table showing the flow from a single accident to cause verification, consultation with employees, hazard assessment, facility improvement, and education.
## Conditional Approval, and Three Months
Mid-October, the prime contractor’s evaluation results came out. ‘Conditionally Approved.’ The condition was to complete the items in progress by December and undergo a follow-up inspection. The next year’s volume contract was maintained.
During that time, the interlocking mechanism was installed. The new cover was changed to a less obstructive form, and the roller stops when the cover is opened. The returning worker’s first action was to open and close the cover several times. They didn’t take their place until they confirmed that the machine stopped.
The 2nd hazard assessment was completed in November. Factory workers directly identified eleven hazards, and eight of those were fixed before the end of the year. One of those was also re-marking the floor in the area where the forklift traffic and pedestrian walkways overlapped, which was suggested by the labor representative. The production supervisor completed training and was appointed as the safety and health management officer.
In December, the prime contractor’s follow-up inspection resulted in ‘Approved.’ The Industrial Accident Compensation Insurance Corporation’s facility improvement support project was selected in early the following year, allowing us to receive support for a portion of the interlocking installation costs. It wasn’t the full amount, but it was a significant sum for a small factory.
## Returning to the Line
The afternoon the evaluation results came out, I received a short message from the owner. It was a photo of the factory. It was a photo of employees leaving work in front of the factory at sunset. 🌇
The message read: "I told my father the results. He said that cover wasn't even there when he was the factory manager. It’s being installed in my generation.”
Looking back, the crucial documents in this case weren't particularly special. The industrial accident investigation report was submitted within the deadline, the prime contractor’s documents were submitted on time, and the hazard assessment was conducted on-site. However, what connected those documents was a comment made in the Monday morning break room: “That machine has been used without a cover for quite some time.”
Documents after an accident aren't meant to cover up the accident. They're meant to prevent the next accident. If you incorporate that distinction into the documents, the documents become a record protecting the factory, not a burden. When I look at the lights of the industrial complex visible from the window of the office in Yeongu-dong, Incheon, I sometimes think of that Line 3.
## If You’re in This Situation, Check These First ✅
① If an accident requiring more than three days of sick leave has occurred, first check the deadline for submitting the industrial accident investigation report to the Labor Relations Committee (one month from the date of the accident) separately from the Industrial Accident Compensation Insurance Corporation application.
② The investigation report requires confirmation from the labor representative. If there is no labor union, take care of the procedure for electing a labor representative.
③ Before simply writing ‘negligence’ in the cause section, first listen to the stories of the on-site workers. True preventive measures usually come from there.
④ If you are a manufacturing business with 20 to under 50 employees, check if the safety and health management officer position is vacant and if a hazard assessment has been re-conducted after introducing new equipment.
⑤ If the prime contractor’s evaluation or agency submission deadline is approaching but everything isn’t finished, it’s safer to divide it into Completed, In Progress, and Planned categories and submit it with supporting documents by the deadline. Individual verification is required as the requirements vary depending on the case.
#IncheonYeonguAdministrativeAgent #SongdoAdministrativeAgent #SevereDisasterPunishmentAct #BusinessesUnder50Employees #IndustrialAccidentInvestigationReport #WorkplaceAccidentReport #HazardAssessment #SafetyAndHealthManagementOfficer #SafetyAndHealthManagementSystem #CooperationCompanySafetyEvaluation #IncheonYeongu #ManufacturingSafety #BusinessAdministration #VirtualCase
This article is based on actual consultation cases and has been restructured, and the characters, names, and figures appearing therein are unrelated to specific individuals or events.
## Office Information
This administrative agent’s office is located in Songdo, Incheon (Posco Tower Songdo). We handle administrative litigation, licensing/registration agency, foreign entry and residence (visas and residence permits), and regular administrative management. We also help with organizing safety and health documents to be submitted to relevant agencies and clients after an accident, meeting deadlines. Feel free to contact us if you are in a similar situation.
📍 Address: 165, Convensia-daero, Yeonsu-gu, Incheon, POSCO Tower Songdo 2697 📞 Phone: 010-3374-2687 🌐 Website: www.hwangadmin.com