Managing EHS Incidents Using Integrated Managment Systems. By Matt Noth

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1 Managing EHS Incidents Using Integrated Managment Systems By Matt Noth

2 2 Managing EHS Incidents Using Integrated Managment Systems Introduction Most organizations have been managing safety and environment-related incidents and events in some form for many years. However, there is increasing recognition that recording, investigating and analyzing incidents across a broad range of disciplines using a systematic approach can lead to a more proactive understanding of the business as a whole, which ultimately results in improved efficiency and long term sustainability. Unplanned environmental, health and safety incidents and events are a fact of life for most organizations and the management of these incidents is essential to enable preventative strategies to be implemented. The management of these incidents includes: identification, appropriate tracking, trending and reporting to relevant parts of the organization. Failure to do so can have significant potential impacts including loss of life, organizational reputation, financial penalties and a decrease in stakeholder value. An Incident Management process should be initiated as soon as possible after the incident or event, via either those directly involved or the appropriate EH&S representatives. Where an EH&S application is being used, the appropriate workflow will be defined factoring in a range of categories and classifications, such as incident type and consequences, and this will typically trigger notifications to those that need to be included in the follow up and investigation of the incident. Notifications will likely include various Subject Matter Experts (SME), supervisors and managers, with various roles such as investigators, reviewers and approvers being determined by the organization s business rules. Where an investigation is required (as your business rules may exempt some low severity incidents), SME s will gather the required background information and may document findings and appropriate corrective actions. Further, a comprehensive causal factor analysis may be required resulting in additional findings and corrective actions. About the Author - Matt Noth Matt Noth, Environmental, Health & Safety Specialist with SAI Global, has 15+ years experience in engineering and EHS compliance management enabling him to provide guidance to organizations trying to bridge a gap between federal, state, and local regulatory obligations and their organization s business requirements. Matt holds a B.S. Mechanical Engineering from the University of Texas at Austin and an M.S. Environmental Management from Samford University in Birmingham, AL.

3 Managing EHS Incidents Using Integrated Managment Systems 3 WHAT CAUSES AN EH&S INCIDENT / EVENT? There are many causes of EH&S related incidents or events to occur in organizations, but in most cases, these instances are unplanned or not properly controlled. An incident usually refers to an unexpected event that may have caused injury or damage. Near miss or dangerous occurrence, are also terms for an event that could have caused harm but did not. There are many types of EH&S-related incidents or events, but most commonly these include: Employee / occupational injury or illness Environmental impacts including spills or unplanned / planned releases Operational / process upsets or changes (QA impacts, production / services interruptions) Motor vehicle or other operational equipment accident or damage Explosion / Fire / Flood Property Damage Notice of Violation / Non-Compliance Citation Often these incidents / events are noticed immediately or soon after they happen, necessitating immediate reporting and notification of the relevant information related to and surrounding the event. It s Happened - What s Next? Many organizations have incident / event reporting and investigations built into their EH&S management practices and procedures, either in manual form (i.e. MS-Excel or MS-Word) or using an integrated EH&S application. The fundamentals of incident management include: Initial Response and Notification (including emergency response and required regulatory reporting) Ensure that relevant information is collected for: Each consequence attributed to incident / event by qualified employee (i.e. EH&S professional SME s, supervisors, etc.) External reporting requirement such as OSHA, MSHA, OSHAWA, RIDDOR, etc., documenting the required details for subsequent regulatory reporting Liaise with relevant internal departments such as: Human Resources for workers compensation Finance for insurance related issues

4 4 Managing EHS Incidents Using Integrated Managment Systems Investigation (including root cause analysis and new / revised hazard analyses, as required) Findings and recommendations (including corrective action definition and assignment) Corrective and preventive action implementation and follow-up Reporting and Lessons Learned (across organization as needed) Management Review, Approvals and Closeout (including Management of Change (MoC) and Quality Assurance (QA) management) Proper documentation of all relevant incident / event details and data FIgure 1 - Incident Management Best Practice Flow Chart

5 Managing EHS Incidents Using Integrated Managment Systems 5 Effective Incident Management Figure 1 is provided as an example of best practice effective incident and event reporting management. Attributes of best practice should include: The reporting and investigation procedure should be documented and should include the reporting of incidents to relevant authorities as defined by regulations The reporting and investigation process should define appropriate roles and responsibilities Sites should report and investigate all internal EH&S incidents including near misses and dangerous occurrences as soon as practical after they occur Incident investigation should be relevant to the nature and degree of the incident, identify the root cause(s) and recommend corrective actions Mechanisms should be established for including employees in the incident investigation process Recommended corrective actions associated with incident investigation should be reviewed by site management, and an improvement plan produced and implemented Changes to work practices that occur as a result of implementing recommendations should be communicated to all relevant employees Incident Management Explained in Detail Initial Notification It is recommended that the following be included in the initial notification: Location and site of incident / event Person(s) (employee, visitor, contractor) involved with incident and reporter (as known initially) Description of incident People (employee(s) and other(s)) to be notified Consequences (i.e. causes & impacts) and outcomes of the incident or event Initial severity / risk assessment Immediate Corrective Actions, if any

6 6 Managing EHS Incidents Using Integrated Managment Systems Much of this information is necessary to help define and determine the next steps in the incident / event management workflow. For example, an Initial Severity Assessment may impact your workflow and notifications, which in turn impact what additional details are needed and what type of investigation may need to be performed. Conequences An incident or event may have any number of consequences associated with it. A single incident can track multiple contributing consequences, including multiple Injuries, hazards, spills, etc. Incidents can have any number of contributing consequences, and may include: Environmental - Spill, unplanned release (air, water, waste, etc.), wildlife encroachment, etc. Safety and Occupational Health Security / Loss Prevention (Theft) Inspector / Regulatory Site Visit Process / Manufacturing / Service Outage Hazard Fire / Explosion Equipment / Asset Damage The management of these incidents includes: identification, appropriate tracking, trending and reporting to relevant parts of the organization. 3rd Party impacts such as contractors & visitors Near Misses There can be multiple incidents or events that are related, that would necessitate some connection in the follow-up incident reporting and investigation analysis efforts. When an EH&S incident or event is significant enough to warrant comprehensive investigation and reporting, it is critical that an organization has a cohesive mechanism in place to effectively manage all aspects of the follow-up, from the immediate consequences of the initial incident, through corrective actions back to full productivity. Hazard Investigation Often with health and safety incidents, there are connections to one or more workrelated hazards that are either already known or need to be known for development of a hazard assessment for hazard abatement. In either case, the existing or new hazard that is identified as part of an incident or event report, typically need to be assessed or re-assessed.

7 Managing EHS Incidents Using Integrated Managment Systems 7 Often, these identified hazards are linked to employee job safety analyses (JSAs) or job hazard analyses (JHAs), that would likely need to be re-assessed and amended as a result of the incident or event recorded and investigated. In our previously published whitepaper, Effective Hazard Identification and Management, we discuss the details and methodologies for workplace hazard identification and abatement that would tie into incident and event management as we discuss here. Investigation The accident investigation process typically involves the following steps by an assigned Investigation Team or an Investigator: Identify the causes (see Root Cause Analysis) Report the findings Develop a plan for corrective action Implement the plan Evaluate the effectiveness of the corrective action Make changes for continuous improvement As little time as possible should be lost between the occurrence of an incident (e.g. accident or near miss) and the beginning of the investigation. All information gathered prior to the commencement of an investigation should be collated and provided to investigators (for example; operational logs, witness statements, photographs, etc.). For serious incidents measures are taken to prevent disturbance of evidence so that the scene of the event can be appropriately assessed. Root / Cause Analysis The important point is that even in the most seemingly straightforward incidents, seldom, if ever, is there only a single cause. Therefore, it is necessary to examine some underlying factors in a chain of events that results in an incident. This analysis will focus on factors such as: When an EH&S incident or event is significant enough to warrant comprehensive investigation and reporting, it is critical that an organization has a cohesive mechanism in place to effectively manage all aspects of the follow-up. Unsafe or unstable conditions Environment Equipment Maintenance

8 8 Managing EHS Incidents Using Integrated Managment Systems Human factors Unsafe acts Understanding of task being performed Training The outcome of the causal analysis would be documented findings that lead to the development of corrective or preventive actions. There are many recognized root/cause analysis methodologies that can be can be used to fit organizational requirements. Some organizations have developed their own effective methodologies based upon their specific experience and operational environments. Corrective Actions / Preventative Actions One of the key elements of occupational health and safety, as well as environmental protection regulations, is the ability to perform corrective actions or tasks to correct the problems that caused the incident and possibly preventive actions or measures to help ensure that similar types of incidents or events do not happen again. For further discussion into corrective and preventive actions and tasks, we have previously published a whitepaper on Effective EH&S Action and Task Management Using Data Management Systems. Incident / Event Investigation Follow-Up The management of an organization is responsible for acting on the recommendations contained in an investigation report. Some organizations establish specific groups (e.g. an EH&S committee), to monitor the progress of remediation and corrective actions. Follow-up actions for the incident / event investigation report should include: Respond to the recommendations in the investigation report Develop corrective action plans, including responsibilities and timeframes Actions may include: Lessons Learned Training Disciplinary actions Compliance with regulatory requirements Monitor the execution of the action plans through to completion

9 Managing EHS Incidents Using Integrated Managment Systems 9 Knowledge Sharing and Lessons Learned Knowledge Management, including Lessons Learned, is a systematic approach to facilitating the flow of data, information and knowledge to the right people, throughout an organization, at the right time so that they can act more efficiently and effectively. One of the strengths of an integrated EH&S incident and event management system is that the data collected across its broad range of activities can be summarized and reported on, ensuring that diverse EH&S information can be readily disseminated across the organization for better decision making capability and enhanced institutional EH&S knowledge. The most valuable piece of an incident / event investigation is the resulting Lessons Learned. Clear and timely communication of this information and the subsequent incorporation of these lessons into the organization s operations is what can salvage business advantage from incident investigations. Safety Management Beyond Incidents and Events There are many other aspects to EH&S management beyond incident management that should be included in an organization s overall EH&S management plan. We cover several of these in our previously published whitepaper Health and Safety Beyond Incident Management. Incident / Event Management Software Solutions Incident management software systems are designed for collecting consistent incident report data. These systems, using defined workflows, ensure that the correct information is captured for each incident management process step, including attachments such as photographs and related documentation. Additional benefits include automated notifications, detailed task assignment and escalations when timeframes are not met. These systems provide the ability for administrators to easily configure the incident report forms as needed to meet your specific requirements, create analysis reports and set access controls on the data. Should you require additional information about how SAI Global has helped many leading organizations implement best-practice incident and integrated EH&S systems, please refer to our contact details on the last page.

10 10 Managing EHS Incidents Using Integrated Managment Systems REFERENCES Effective Hazard Identification and Management (SAI Global Whitepaper) Effective EH&S Action and Task Management Using Data Management Systems (SAI Global Whitepaper) Health and Safety Beyond Incident Management (SAI Global Whitepaper) Accident Investigation (Article - CCOHS; 2013) Incident Management (Article - Wikipedia)

11 USA Europe Australia Asia Houston TX T: F: Warwickshire UK T: +44 (0) F: +44 (0) Sydney T: F: Jakarta T: Plainsboro NJ T: +1 (877) 470-SAIG [7244] F: Melbourne T: F: Waltham MA T: F: Perth T: F: Alpharetta GA T: F: About SAI Global The SAI Global Cintellate EH&S Software Suite supports solutions for environmental management, health & safety management, risk management and compliance management. With a global client base, our software is robust, scalable and extremely flexible. Configurable in multiple languages, it interfaces with other business software, facilitating reporting across business silos to give visibility across business operations. Request a demonstration and find out how you can turn information into actionable knowledge. For more information, please call us at the full service location nearest you or visit: SAI Global Ltd. The SAI Global name and logo and Cintellate name are trademarks of SAI Global Ltd. All Rights Reserved. IMMSWP1308a

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