Page 71 - Root Cause Failure Analysis

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REGULATORY COMPLIANCE ISSUES

RCFA is a viable tool that can be used to investigate regulatory compliance problems
that arise in a plant. The logic and decision trees for this type of investigation are similar
to those used for equipment failure and safety investigations but must be modified to
meet both the nature of the incident and the specific requirements of the regulatory body.

Regulatory compliance problems associated with work-related incidents generally fall
into the domain of safety, which is regulated by the Occupational Safety and Health
Agency (OSHA), and environment, which is regulated by the Environmental Protec-
tion Agency (EPA) and state (although a state may defer to the EPA through a formal
agreement) and local governments. This section provides guidelines for investigating
incidents that fall under the jurisdiction of regulations by these groups.

NOTE: The material presented in this section does not constitute legal advice and is
provided for informational purposes only. Please consult the appropriate agencies
directly and seek qualijed legal council for this type of assistance.

SPILL HAZARDS
Be certain that spill hazards are reviewed as part of the plant’s internal audit program.
Audit-team members should be trained to look for deficient containers, fall hazards
that can contribute to a spill, improper container labeling, and other potential hazards.
Major causes of chemical spills are

Mishandling of equipment and supplies in the work area (e.g., use of
improper containers),
Mishandling during transportation (even within a facility),
Leaks from process equipment such as flanges or valves, and
Improperly stored containers (e.g., storage in a damp location leads to rusty,
deteriorating containers).

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