Management systems corrective action tracking

On the negative side, verbal reporting does not provide for corrective action tracking, nor does it provide a database for possible trends and patterns of issues that are reported. Verbal reporting does not provide an employee protection from a member of the leadership team who may not understand the issue and does not take the need for response seriously (Overview of System Components, Safety Health Management Systems eTool, n.d.). One method is to have alternative means for reporting concerns that allow employees to autonomously bypass any commimication obstacles. Several of these are discussed below. 

Some measures of PSM and ESH performance are easy to identify, establish and track. These include accident rates, effluent tonnages and composition and number of days lost to illness. Almost all of these traditional performance measures are end-of-pipe that is, they measure the output of the management system and allow corrective action only after a failure has occurred. The ideal measurement system identifies potential problems ahead of actual failure allowing corrective action to be taken. This requires using techniques such as audits and hazard assessments. 

Activities documenting and tracking implementation of corrective actions or safety improvements are not part of a PrHA report. However, the PSM Rule requires a documented, integrated system for managing and monitoring action items. This system must assure that action items and recommendations are addressed and documented in a timely manner. Implementation schedules for corrective actions or safety improvements must be tracked. Finally, the system must assure that all affected operating and maintenance personnel and other affected employees are notified of planned actions. 

Management can use a variety of criteria to select and prioritize corrective actions and safety improvements. They include costs, other competing priorities, implementation schedules, the effectiveness of risk reduction, and technical feasibility. These criteria, as well as management decisions about corrective actions, must be documented. If after evaluating an action item, management chooses to take no further action, that decision must also be documented. In addition to requiring documentation of management decisions, the PSM Rule requires a system to track implementation of corrective actions to be made. 

Problem Reporting and Corrective Action. A familiar problem with management systems is that although problems and issues might be effectively and accurately identified and recorded, their resolution can sometimes escape proper control. Procedures need to be in place to ensure that the quality loop is complete so that defect reports are properly tracked to their final resolution. 

On completion of the PrHA, appropriate findings and recommendations for corrective action are usually presented. These recommendations must be reviewed and acted upon by plant management. It is recommended that, if there are many recommendations, they be entered and tracked with a database tracking system. Management may only reject some of the findings on the basis of factual errors, not necessary for the protection of health and safety, an alternative measure providing a sufficient level of protection, and the recommendation being infeasible. 

Department managers and the Safety Office (as defined by the safety management system) should maintain the documentation of the investigation findings, conclusions, and recommendations and track the status of corrective actions. 

Corrective and preventive action. As part of its safety management system, each utility should establish and implement procedures for identifying and investigating non-compliance issues, developing effective corrective and preventive actions, and tracking actions to closure. An effective procedure of this nature should include, at a minimum, the following elements ... 

AIMS will programmatically identify all actions required of RRD, including reportability, evaluation, tracking, trending, disposition, and closure of the items when appropriate corrective action has been completed. The intent of this proposed program is to continue the management and control of issues as the restart issue management systems reaches completion. Both an Operational... 

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