I-A-01.00 SOSO Page 17 of 17
Rev # 28
SAFETY / SOSO / Current Issue: 02/25/14Revision: 28
By: P. Daigle
Verified by:___
Date:______ / REPORTING AND INVESTIGATING ACCIDENTS/INCIDENTS AND IMPROVEMENT IDEAS
Date Reviewed:
02/25/14 / I-A-01.00 Page 1 of 17 / Original Issue: 05/28/81Originator: P. R. Daigle
SCOPE:
This procedure applies to all persons working at/on the Green Lake Facility site, pipeline, and Port facility as well as off-site job related incidents. This includes all contract as well as Green Lake Facility employees. This procedure encompasses Safety, Health and Environmental (SHE) and Quality accidents or incidents occurring in the plant. Quality issues include exceptions to specified control limits, non-conforming products and raw materials and the waiver process.
It is the policy of the Green Lake Facility that every accident resulting in personal injury, no matter how slight, be promptly reported to the employee's supervisor. The employee’s supervisor is responsible for reporting to the Green Lake facility’s SHE Department and the on duty Shift Manager. The same is true for environmental or quality issues which occur.
It is also the policy of the Green Lake Facility that every accident resulting in equipment damage or material loss be promptly reported to the employee's supervisor and the Green Lake’s SHE department
In addition, near miss incidents, which do not result in an injury or property damage must also be reported to your supervisor and the Green Lake SHE Department. It is also the responsibility of all facility and contract employees to share ideas for improvement (i.e. SHE opportunities).
Action items: Items identified as needing correction will be assigned to a responsible party for completion. A target completion date will be assigned. The target completion is not to extend beyond 12 months from the date it was entered in the Traction database. Items that must be extended beyond 1 year require Leadership Team approval. The Leadership Team will set the new completion target. There must be sufficient documentation in the completion area of the action item to detail how the item was completed.
PURPOSE:
Immediate reporting is essential for the following reasons:
a. Insures prompt and proper treatment
b. Results in an investigation -- when necessary -- that will prevent a similar, possibly more serious accident/incident.
c. Generates records that can be analyzed to determine where additional safety, environmental or quality efforts should be directed.
d. The EPA, OSHA and ISO policies require immediate reporting and complete documentation of such events.
Some incidents could result in very serious accidents with a few seconds change in time, or a few inches change in where it occurred, or a minor change in other conditions such as wind direction, or absence of protective equipment. Some of the serious no loss, no injury accidents yield valuable data when fully investigated. This may prevent similar incidents, possibly more severe in nature, from occurring. All records will be coordinated through the Safety Department.
I-A-01.00 SOSO Page 17 of 17
Rev # 28
Later sections of this procedure describe the process for properly completing and routing of the various incident report forms and reports.
For the purpose of this procedure, the term accident will refer to “an event which results in unintended harm or damage”. The definition of incident is “an event which could or does result in unintended harm or damage”.
PROCEDURE:
A. Minor Injuries (First Aid)
1. An employee receiving an injury requiring first aid or who is ill shall immediately notify their supervisor of the nature of the injury/illness and how it was sustained. The injured/ill employee will proceed to the closest point of care which could be the Production Control Room or the dispensary. The employee’s supervisor will ensure someone will be at the dispensary to provide medical treatment (nurse, EMT).
2. The employee’s supervisor is responsible for making required notifications to the On Shift Production Shift Manager. Notification to the On Shift Production Shift Manager will be made as soon after the incident occurs as possible without interfering with the care of the injured/ill employee.
3. The only exception to the above is in the event of a chemical exposure. The Production Control Room will be the first to be notified. The Production Control Room will be responsible for properly deconning the employee and providing first aid. Only after proper deconning will the employee be brought to the dispensary for further medical evaluation.
4. The On Shift Production Shift Manager is responsible for writing the incident report on any injury occurring in a Production controlled area of the plant. The resident contractor supervisor or Green Lake representative of the contractor is responsible for writing the incident report for injuries occurring in non-production controlled areas of the plant (ie, maintenance shop, B&R area, etc). All incident reports need to be completed and approved before the end of the shift in which the injury occurred.
B. Serious Injury or Illness requiring emergency response:
1. An employee receiving a serious injury or illness that requires emergency response will contact the Production Control Room immediately via radio, page talk or fellow worker to the control room. The plant ERT will be activated by Production. The employee’s supervisor will be notified as soon as practical.
C. Reporting Unable to Work
1. If an employee’s occupational injury/illness prevents him from returning to work, their supervisor or the on shift Production Shift Manager must be notified immediately. The supervisor or shift manager must notify the Green Lake SHE department immediately. Arrangements can then be made for the injured employee to be examined by the company physician.
D. Property Damage or Loss Accidents/Incidents
1. An employee involved in an accident/incident resulting in damage to equipment or release of materials must report the details to his supervisor immediately.
2 The supervisor is responsible for completing a Traction report.
E. No Loss/No Injury Incidents
1. The near-miss type incident may eventually result in an injury, equipment damage, or material loss unless the incident is reported, investigated, and action taken to correct the cause of the incident.
2. An employee involved in a No-Loss, No-Injury Incident will promptly report the incident to the supervisor involved. For contractors the supervisor will then report the incident to his/her Green Lake Facility contact person.
3. The supervisor or company contact person is responsible for completing a Traction report.
F. Quality-related incidents:
1. An employee must immediately report to his/her supervisor any incidents encompassed by the quality system. This includes any non-conformance for equipment, raw materials, products or which result in process operating conditions outside established final specification limits on any of the quality parameters in the quality procedures. Note: for In Process values exceeding Internal established spec limits for process parameters, will be informed on the production shift notes.
2. Continue using this format for the waiver process of receiving non-conforming raw materials or releasing non-conforming products.
3. The supervisor or his/her designee is responsible for completing a Traction report.
4. Quality – Related incidents, non-conformities and customer complaints are addressed by Quality procedure QPGL-1300, “Corrective and Preventive Action System.
G. Environmental Incidents
1. Spills, releases and other excursions from permit and regulatory requirements must be reported to the SHE Department soon after the incident is discovered.
2. An Incident/Investigation Report must be completed for each spill, release or other excursion regardless whether the incident is reported to the State or Federal Environmental Agency. This includes any environmental target exceedances. This to ensure that corrective/preventive action is taken.
3. There are two types of environmental incident reports:
a. Material Release – an incident where products or materials are released from their primary containment in an uncontrolled or unplanned fashion. This includes the following release types:
i. Atmospheric – Loss of primary containment with release directly to air, requires immediate action to repair, release of a material as a gas (rather than vaporized from a liquid).
ii. Spill – Loss of primary containment, has or may have an impact on soil, requires immediate action to repair, released as a liquid or solid.
iii. Leak - Loss of primary containment, no impact on soil, requires immediate action to repair, released as a liquid or solid.
b. Compliance/Conformance: Environmental Event – any environmental incident that is not a “material release” as described above. All environmental events should be entered as non-conformance. The SHE Department will adjust this classification as needed.
H. SHE Improvement Ideas or Opportunities
1. It is important for all Green Lake Facility and contract employees to share ideas for improving health, safety, environmental and quality performance. Employee input and involvement is needed to continually improve our performance. Employee suggestions will be evaluated by the SHE Department when setting improvement goals (i.e. objectives, targets and the means to achieve them).
2. Improvement ideas must be reported using the Incident Reporting system (Incident category: “Near Miss/SHE Opportunity”).
I. Inquires from External Interested Parties
1. An incident report must be completed for all inquiries from external interested parties as described in SOSO I-A-01.02. Inquiries must be reported using the incident report category: “Complaint: Public/Third Party.”
J. High Potential Incidents
1. A high potential incident is outlined in Key SHE Process 5 as an incident or near miss, including a security incident where the most probable outcome is a major incident.
In addition to the internal reporting requirements, a high potential notification will be sent as per Key SHE Process 5.
K. Security Incidents
1. Employees should report all security incidents to their supervisor immediately. Security incidents could include robbery, theft, burglary, and criminal property damage. All reports of assault or threats, fraud or unethical conduct, drug or alcohol abuse should be reported immediately to the supervisor, who will then report directly to the Security Manager.
L. Process Safety Incidents
1. A process safety incident is one in which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemical in the work place.
2. Periodically during the SHE Department Staff meeting, all incidents/accidents are going to be evaluated to determine which meet the process safety incident definition to classify them on Traction.
M. OSHA requires that they be notified within eight (8) hours following the death of any employee or the in-patient hospitalization of three or more employees from a work-related incident. This requirement applies to each fatality or multiple hospitalizations that occurs within 30 days of an incident. If we do not learn of a reportable incident at the time it occurs, we are to make notification within eight (8) hours of the time we know about it. The SHE Department is responsible for making this notification.
1. In the event of a work related fatality or in-patient hospitalization of three or more individuals occurring at the Green Lake plant, the SHE Department will be notified according to the Emergency Notification Priority List procedure E-A-01.00.
2. After this initial notification, the SHE person notified will complete the attached form and call the information in to OSHA at 1-800-321-6741 or the local office located in Corpus Christi (361) 888-3420.
3. The information required for the form is: establishment name, location of the incident, time of the incident, number of fatalities or hospitalized employees, contact person, phone number (of contact person) and a brief description of the incident.
Incident / When / To whom / How / Investigated by Whom / ReportFirst Aid
/ 24hrs / Line Manager, SHE / Tr@ction and/or local reporting system. / Local RCA/CLC Specialist and Local Team / Tr@ction report and/or local reporting systemRCA Report.
Recordable / 24hrs / Line Manager, SHE / Tr@ction
Full Committee Investigation / Local RCA/CLC Specialist and Local Team / Tr@ction report RCA Report.
DAFWC* / ASAP 24hrs / Line Manager, SHE / Verbally
Tr@ction
Full Committee Investigation / Local RCA/CLC Specialist and Local Team / Tr@ction report
RCA Report,
Initial RCA Report (10 days MAX)
30/60 Day close out report.
HiPo* / ASAP 24hrs / Line Manager, SHE / Verbally
Tr@ction
Ad hoc format by E mail or Fax. Full Committee Investigation
/ Local RCA/CLC Specialist and Local Team / Tr@ction report
RCA Report,
Initial RCA Report (10 days MAX)
30/60 Day close out report.
IA**
(Fatality) / Immed.
24hrs
Max / Line Manager, SHE / Verbally
Tr@ction
Ad hoc format by E mail.
SHE Alert.doc / Independent Senior Manager
RCA Specialist
External / Local Support / Tr@ction report
RCA Report,
Initial RCA Report (10 days MAX)
30/60 Day close out report.
SHE
Alert / Upon Completion of Investigation / SHE / SHE Alert.doc / Compiled using Full Committee findings. / Send to Site Director for Distribution.
PROCESS FOR DECIDING TO CONDUCT A FULL COMMITTEE INVESTIGATION:
A. Immediately following an injury, accident, or No Loss/No Injury Incident, the involved employee must first report the event to his or her supervisor. The involved employee will assist the supervisor in obtaining all of the information pertaining to the acts and/or conditions responsible for the accident. This will not apply, of course, in the case of serious injuries where the employee is not available.
B. At the earliest possible opportunity during the same shift on which the injury, accident, incident or near miss occurred, the immediate supervisor or company contact person shall investigate the event and prepare a written report. A full committee investigation will be conducted for:
1. Major injury/illness - any injury or illness serious enough to result in a lost workday (time off or restricted work) or OSHA Recordable. Situations which should always be considered major:
a. An injury that results in death
b. Any OSHA recordable injury or illness