Page 79 - Root Cause Failure Analysis

70 Root Cause Failure Analysis
Corrective Actions

Regarding corrective actions, the regulation states:

The employer shall establish a system to promptly address and resolve the inci-
dent-report findings and recommendations. Resolution and corrective actions shall
be documented.

The regulation does not define promptly in definitive terms, but the intent is that all
corrective actions must be implemented immediately.

The major difference between an OSHA-mandated investigation and other RCFA is
that an appropriate corrective action or actions must be implemented as quickly as
possible. In the non-OSHA-mandated RCFA process, a corrective action may or may
not be implemented, depending on the results of the cost-benefit analysis.

The cost of corrective actions is not a consideration in the OSHA regulations, but it
must be considered as part of the analysis. Because of the critical time line that gov-
erns an OSHA-mandated investigation, a full cost-benefit analysis may not be pos-
sible. However, the investigating team should consider the cost-beneft impact of
potential corrective actions. The guidelines provided in the section on “Investigat-
ing a Reported Problem” in Chapter 3 should be followed as much as possible
within the time constraints of the investigation.

OSHA’s Investigation Process
Figure 3-16 illustrates the logic tree to follow for an OSHA-mandated investigation.
While it is similar to other, nonmandated investigations, there are distinct differences.
OSHA’s Hazardous Waste Operations and Emergency Response (HAZWOPER) leg-
islation protects workers who respond to emergencies, such as serious spills, involv-
ing hazardous materials. It also covers those employed in cleanup operations at
uncontrolled hazardous waste sites and at EPA-licensed waste treatment, storage, and
disposal facilities.

Emergency Planning and Community Right-to-Know Act
The Emergency Planning and Community Right-to-Know Act (EPCRA) is adminis-
tered by the EPA and state and local agencies. It affects virtually all facilities that
manufacture, use, or store hazardous chemicals. The following are the reporting
requirements of the act:

An inventory that includes the amount, nature, and location of any hazard-
ous or extremely hazardous chemical present at a facility in an amount
equal to or greater than its assigned “threshold level.”
Reports on releases of a “reportable quantity” of a listed hazardous sub-
stance, including the total annual releases during normal operations.