Reporting requirements, system safety

It is almost too obvious to state that companies should be aware of chemical substances that they manufacture or import, but in fact this is often not the case, and is where a compliance problem arises. The regulatory requirements are typically published by chemical name and Chemical Abstracts Service (CAS) Number, whereas in many companies trade names are more commonly used when tracking chemicals. The Material Safety Data Sheet (MSDS) system most often is the easiest place to determine whether a product or an isolated intermediate contains a component that is subject to regulation. With respect to imports, they should be cleared by a regulatory review prior to importation not only for general TSCA compliance, but also to ascertain whether or not there are any TSCA reporting requirements under TSCA... 

The final level. Operations, provides a view of the operational system and acts as the interface between development and operations. It assists in designing and performing system safety activities during system operations. It may contain required or suggested operational audit procedures, user manuals, training materials, maintenance requirements, error reports and change requests, historical usage information, and so on. 

Safety budgeting is allocating financial and other resources necessary to achieve the safety objectives. A budget allocation may be required for the incentive schane. There may be training costs relating to the implementation of a safety systan. Mechanical or structural repairs or modifications may be needed to eliminate hazards reported through the safety system, and these expenses must also be budgeted for. 

At this point the author of the PRA must ensure visibility of these recommendations to all relevant stakeholders. Consideration needs to be given to issuing the first draft of the PRA as early as possible, especially if the output influences the requirements management process (see Fig. 1.3). This may take the form of a stand-alone report or may be contained within any interim updates of the System Safety Assessment (i.e. PSSA is the first issue, SSA is the final issue, with as many ISSAs as required to keep track with the evolving design and maturing System Safety Assessment). 

DOE 1997), This order requires a system for reporting of operations information on unusual occurrences. Section 7, "Occurrence Categorization, Notification, and Reporting Requirements," Part (2) defines a violation of a technical safety requirement as an Unusual Occurrence, which requires DOE notification Mthin two hours of categorization (i.e., identification of the occurrence as an Unusual Occurrence), followed by written notification within 24 hours utilizing a Notification Report. 

The MIL-STD-882D standard practice describes a system safety approach that is useful in the management of Environmental, Health of Safety mishap risks encountered in the life cycle of Department of Defense (DOD) systems, subsystems, equipment, and facilities. To paraphrase the standard, mishap risk must be identified, evaluated, and mitigated to a level acceptable (as defined by the system user or customer) to the appropriate authority, and compliant with federal laws and related rules. Further, residual mishap risk associated with an individual system must be reported to and accepted by the appropriate authority. These basic requirements are fundamental to system safety. 

The MORT tools and techniques can be helpful in preparing a safety analysis report (SAR), the upstream safety product most frequently required for new DOE programs, but the more common system safety products (system safety program plan, preliminary hazard analysis, system/subsystem hazard analysis, operating hazard analysis) are not a dominant part of the MORT program and are seldom even referenced in System Safety Development Center (SSDC) documents. 

An unconfirmed story about one of the military services has it advertising for a series of system safety analyses. The prices bid for the work ranged from around 30,000 to over 800,000 This disparity reflects the differences in interpretation of system safety requirements throughout parts of the system safety community. (The contract was reportedly awarded to the low bidder.)... 

System Safety Data. Specify the types of data that are required to support the effort, including sources of the data and information needed to acquire or access the data. Outline specific data generation and reporting requirements. 

Once all what-if analysis questions have been asked and answered along with all completed HAZOP studies of system components, a final report should be written to document all findings and recommendations. In the chemical industry (in the United States), this report is normally referred to as a process hazard analysis. This report is required under both OSHA and EPA regulations for facilities that handle or contain certain chemical commodities at certain defined quantity thresholds. However, when HAZOP studies and what-if analyses are used in general industry application, documentation of the results can be included in a written report along with any other system safety analyses that may have been performed (as described in previous chapters). If the HAZOP and what-if exercises were conducted as standalone analyses, then a final written report should be... 

To Err Is Human spawned legislation at the state level that requires the development of voluntary and mandatory reporting systems, with legal protections (Prager, 2000). To date, twenty states have legislated the implementation of mandatory reporting systems the National Academy of State Health Policy writes informative reports on patient safety initiatives that are under way at the state level. 

Somehow the Texas City safety pohcy and procedural requirements system drifted into a Check the Box mentality. The CSB reported paperwork had been checked off even when the requirements were not met. 

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