Incident reporting encouragement

The standard attempts to encourage a security culture and shares many of the expectations of 21 CFR Part 11. For instance, to improve personnel security, ISO 17799 recommends definition of security in job responsibilities, persormel screening, training and awareness, and incident reporting. Access controls recommended by ISO 17799 also match Part 11, e.g., user registration, user-ID and password management, definition of user responsibilities, user authentication, and monitoring system access for unauthorized access attempts. 

Near miss incident reporting is not encouraged by the organization. Language barriers. 

In order to encourage near miss incident reporting, the following paragraph was included in the company s safety newsletter ... 

Feedback derived from incident reports keeps system actors in the loop and encourages agent participation in safety improvement. Operators can see that their concerns are being followed up effectively. 

Make sure your company s short-term objectives (e.g., updating aii P IDs) are consistent with broader PSM goais (e.g., accurate process safety information), sind communicate them in ways that clearly encourage work habits and procedures that support PSM performance. For exampie, your employees need to understand that the company will achieve its goal of reducing reportable incidents by changing its PSM procedures, not its reporting processes. 

Management has the responsibility to create and maintain an atmosphere of trust and respect to encourage openness in reporting near misses and actual loss events. Failure to achieve this positive atmosphere will result in low or no reporting of near misses, which may ultimately lead to a catastrophic incident that could have been otherwise avoided. 

Implementing a recommendation must go beyond an equipment, process or procedural change. What was learned about an incident or near miss and its causes, as well as the changes made to prevent recurrence, needs to be effectively communicated to employees. As a result, they will have a greater understanding to better identify future near misses and the factors that could lead to a chemical reactivity incident at their facility. This will also encourage employees to report other near misses. 

Encouraging employees to report all incidents including near misses... 

In some cases, employees, rather than supervisors, lead investigations for lower level incidents. Companies have found it beneficial for employees to feel ownership of the investigation results. This philosophy helps encourage workers to report more near misses by reducing the fear caused when a supervisor leads the investigation. Most incidents are low complexity. Many of these are near misses and benefit from investigation by persons closest to the process. 

If we search for culprits to blame using the finger-pointing method Ian Nimmo just described, the investigation process is very simple. As Nimmo just indicated, we identify specific individuals (in this case the chemical process operator) as accountable for the incident. It would be easy to say the operator failed to follow established procedures. Disciplinary actions could result to teach people that this is unacceptable behavior. [3] Using just the first layer approach would be a waste of effort. Such injustice could create an atmosphere encouraging sincere individuals to be less likely to report all the facts. It is probable that we would not find out all the underlying contributors and hence be unable to effectively prevent a repeat of an incident with a 5.5 million (1979) price tag. 

The IC must analyze the incident based on the facts and be prepared to change the response tactics and allocated resources as the situation reports mandate. The IC is a decision maker and a delegator. To be effective the IC must assign sector officer responsibilities to qualified staff, encourage ideas and opinions to be voiced through the command structure, insist on key stake-holder participation, seek the input of experts and practitioners alike, continually re-evaluate the tactics and strategy, and develop alternate plans. 

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