Apogee EHS Group

Being able to determine the root cause of incidents is a critical component of an effective Safety Management System (SMS).  Operating under the presumption that there should not be any incidents (zero) if the SMS is functioning properly, each incident indicates failures or faults must be present in the current SMS.  Hence the need for effective incident investigation, to determine the failures and faults in the current system so they can be corrected and prevent future incidents.  However, the term root cause is often “mis-used” following an incident.

When attempting to determine why an undesirable event occurred, injury, equipment failure, quality defect etc., root cause must be established to prevent future occurrences.  Unfortunately, many investigations only establish root cause leaving secondary causes and contributing factors unaddressed.  Failure to identify the secondary causes and contributing factors along with root cause will often retain the same risk of future failures as correction of root cause eliminates.

System failures are seldom based on a single cause-event, but rather a series or chain of events that lead to failure.  In this writer’s experience conducting hundreds of incident investigations, there are always at least two secondary cause or contributing factors (usually 3-4), which left unaddressed, will contribute to future incidents.   Incident investigations need identify as many causes and contributing factors as possible to allow for system corrections, and true future incident elimination.

There are several incident investigation tools available.  Many utilize lists or check-boxes of common causes and contributing factors as an aid.  Regardless of the tools used, successful incident investigation includes analysis of the work environment (including equipment), work processes (how tasks are completed) and personal or people related factors (such as knowledge and decisions made).  Investigating to root cause only leaves the door open to secondary causes or contributing factors to re-surface and put you at-risk of incident.

Material Safety Data Sheets (MSDS) are required documents under OSHA Hazard Communication standards (29CFR1910.1200).  Manufacturers are required to produce MSDS for any chemicals having components with physical or health hazards.  While there are requirements for must be contained on MSDS, much of the information is boiler plate/legal disclaimer except for the physical data.  The MSDS requirement as prescribed in HazCom can require significant effort for limited value.

OSHA requires MSDS be available, without barriers, for all employees on every work shift.  The theory is MSDS will contain specific material data that employees can reference and have full knowledge of material hazards, treatment for exposures, protective measures etc.  The reality is MSDS are really only used to retrieve technical information.  Specific information regarding hazards, treatment etc. are often obtained from other sources based on the components listed on the MSDS.  Ironically the technical data most often used, hazardous components, are reported as a range of weight percent rather than a specific value.  To obtain specific content component weight percent, a Certified Product Data Sheet (CPDS) is needed.  Given the limited intrinsic value of MSDS,  what can be done to maximize the value of maintaining MSDS as required?

When evaluating how to maintain MSDS information and maximize value, ensuring compliance is where to start.  Let’s face it, we maintain MSDS because it is required so we must meet those requirements first.  To maximize the value delivered by meeting the MSDS management requirements, review your environmental regulatory requirements and index your MSDS by specific hazards and components.  Too often the safety and environmental management systems are independent of each other and you end up a separate data file of chemical information for environmental reporting.  Using one system for both sets of requirements can increase value by reducing effort required for data management.   Having your MSDS indexed by hazard and component can be very helpful when new regulations are proposed or specific safety concerns arise.

Archiving obsolete data and limiting MSDS in the active system to only what is currently used can also significantly increase value.  Without an archive process, the number of documents to search can become quite large quickly and employees can have difficulty determining the correct MSDS for a product.  MSDS are considered medical records and must be maintained for 30 years past employment, so an archive process is required, but often the process used is time intensive and neglected because of conflicting priorities or time constraints of the person maintaining the system.  The most effective archive processes are usually tied directly to material procurement so changes are initiated at the source.

MSDS requirements and practical application can create challenges for safety managers.  Focusing on how and what material information is actually used can create synergies and maximize the value your chemical management system provides.

Hazardous chemicals are required to be labeled with “appropriate hazard warnings” under Hazard Communication standard (29CFR1910.1200).  Hazard warning is defined as “any words, pictures, symbols, or combination thereof appearing on a label or other appropriate form of warning which convey the specific physical and health hazard(s), including target organ effects, of the chemical(s) in the container(s).”  This definition has caused many to question if the two most popular methods of secondary container labeling, the HMIS and NFPA labeling systems, meet the requirements.

The HMIS and NFPA systems were designed to provide quick, visual general hazard information.  The definition of hazard warning requires specific information, including target organ effects.  To provide appropriate hazard warning, some additional information should be on containers than just the standard HMIS or NFPA markings, but often times it is as simple as adding target organ information.  If employees understand the color and number scheme of NFPA or HMIS, adding verbiage about target organ effects will meet regulatory requirements (before GHS enactment).

Target organ verbiage can be obtained from MSDS or manufacturer container labels.  That verbiage can usually be easily added to an open area on the bottom portion of HMIS or NFPA pre-printed labels.  Target organ effects need to be included in employee training to fully close the loop and ensure hazard “communication” is effective.