Corrective actions hazardous conditions

If the RFA or other information has indicated a release of hazardous constituents, then from the owner/operator s perspective, the Corrective Action process truly begins. The first step in the process, the RCRA Facility Investigation (RFI), is directed toward development of the engineering information about the site necessary to permit selection and evaluation of remedial alternatives. The main engineering thrust of the RFI is the characterization of site conditions by defining the nature and extent of the problem. 

It generally is recommended, and often required, that gas dcicciiuii systems be installed in a fail-safe manner. That is, if power is disconnected or otherwise interrupted, alarm and/or process equipment shutdown (or other corrective action) should occur. All specific systems should be carefully reviewed, however, to ensure that non-anticipated equipment shutdowns would not result in a more hazardous condition tlian the lack of shutdown of the equipment. If a more hazardous situation would occur with shutdown, only a warning should be provided. As an example, a more hazardous situation might occur if blowout preventers were automatically actuated during drilling operations upon detection of low levels of gas concentrations than if drilling personnel were only warned. 

Stopping excursions from normal operation conditions before they become hazardous, by correction of process control variables when dangerous situations are detected on-line detection of process deviations associated with trip systems for corrective actions. 

Preliminary Hazard Analysis. The next step in the process is the development of a PHA. This analysis is the core of the FSS program and as such is vital in eliminating or reducing the inherent hazards associated with this laboratory operation. The PHA is used to further analyze the data identified in the PHL. This enhances the hazard control data base and provides specific recommended corrective action for the resolution of hazardous conditions. A combination of the informational sources used in the PHL development and any additional design information should be used in PHA development. 

The OSHA Law, a performance-oriented standard, allows employers to determine testing criteria and to set criteria to judge the acceptance or failure of test results. If a test detects a potentially hazardous condition, prompt corrective action is required. 

Hazard identification and control are important aspects of safety in a laboratory. Most hazards in a laboratory environment involve either unsafe conditions or behavior. Conditions can be controlled through proper analysis and inspection of the work environment, and implementation of controls to reduce or eliminate the exposure to these hazards. A formal job hazard analysis, where individual tasks are observed, broken down into their individual components, and analyzed for existing and potential hazards is necessary for hazard identification and corrective action. This activity must be followed by periodic formal inspections and hazard assessments. 

CRF1910.120(q)(3)(viii) 4.3.9 When activities are judged by the safety officer to be an IDLH (immediate danger in life or health) and/or to involve an imminent danger condition, the safety officer shall have the authority to alter, suspend, or terminate those activities. The safety official shall immediately inform the IC of any actions needed to be taken to correct these hazards at the emergency scene. 

Instrumentation and control systems are required to monitor key parameters (for example, temperature, pressure, agitation, cooling) and take corrective action when a hazardous condition is detected. (See also case histories Al 57-61, pages 184-185.)... 

Information concerning unsafe system operating conditions must be provided to the crew to enable them to take appropriate corrective action. A warning indication must be provided if immediate corrective action is required. Systems and controls, including indications and annunciations must be designed to minimise crew errors, which could create additional hazards . 

Periodic, scheduled facility safety inspections are essential in any operational area, especially where hazardous tasks are performed on a regular basis. Compliance with safety inspection requirements should not be difficult to accomplish since similar requirements should already exist in an established occupational safety program. The facility inspection encompasses all facets of daily operation and considers the human-machine interface a primary candidate area for potential mishaps. Frequent facility inspections are an excellent method of maintaining current awareness of facility conditions and how those conditions affect, or might affect, the safe operation of that facility. A system should be in place to ensure implementation of corrective actions and to track repetitive items. Results of inspections should be properly documented and accountability for discrepant items appropriately determined and assigned in order for the inspection process to be effective. If properly performed, the facility safety inspection is an excellent tool in the overall success of the system safety function. 

The main contractor is responsible for cooniinating the construction project activities so that separate but simultaneous tasks do not create hazardous conditions for anyone on the same constraction site. The main contractor must also appoint a safely coordinator to overlook and verify the correct safely actions, as well as the ones that the sub-contractors are responsible for. 

All employees should be able to report hazards without reprisal. When a good safety culture is in place, managers are properly trained and accept their responsibility for safety. Informal oral reporting of hazardous conditions should occur naturally. When an employee s concerns appear valid, management must have the responsibility to correct the hazard, request corrective action by maintenance or other resources, or ask for assistance from a safety professional. Most workplaces encourage this type of reporting. Used alone, it does not provide for hazard correction tracking. Nor does it enable you to look for trends and patterns. 

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