Site Document Review

OSHA will examine records for the past three years to verify implementation of the safety and health program. The site should have all of these documents available for the team. Reports on safety meetings, training, inspections, etc., should be placed in chronological order so that the forms are easier to review. 

T)rpically, these are the documents that are requested during a review  

Any additional information that shows the quality and depth of the safety and health program of the facility will also be requested. Various levels of management may be questioned regarding documents and written programs. OSHA will also calculate the incident rates and lost workday case rates for the facility. 

Managing safety can be a difficult task, but the efforts are beneficial to the employees and to the organization s bottom line. The economic benefits of fewer injuries begin with a reduction in workers compensation insurance losses and continue with lower indirect costs associated with those losses. Safer warehouses tend to be well run and more productive. Often a facility will experience an improvement in both safety and business at the same time. 

Safety programs require commitment, planning, cooperation, and resources. Management must commit to improving safety performance. The time to improve and move forward is not after a serious injury or a high OSHA penalty, but before any catastrophic or serious incident occurs. 

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The Manual contains 59 pages of checklist questions to solicit a yes or no response from site documentation reviewed, activities observed, and/or personnel interviewed. According to the Manual, Any no response shall normally result in a citation for violation of that provision (US. Department of Labor 1994). 

The results of the audits indicate that the delineation of zones is easy to put into a plan hut difficult to keep current. The nature of remedial work demands fiexihility. As sites become remediated, the exclusion zone boundaries change. This is not a situation that is easily handled in a plan, but should be reviewed as other site documents on a predetermined regular basis. 

The first phase of process safety incident investigation involves gathering all the pertinent facts from the collected evidence, whether derived from interviews, site and equipment inspections, or document reviews. At this... 

Computer systems that are identified as requiring validation must be included in the site validation master plan. A validation master plan is typically used as a high-level plan for the site or processes and systems that make up the facility GMP operations. The plan should outline the scope of the validation program, controls to be adopted, and how activities are to be conducted, documented, reviewed, approved, and reported. Target completion dates should be included for validation work in each area. 

QA auditors should help investigate suspected fraud or misconduct by means of data and document review and audits at the concerned sites. Their independent and objective perspective of the situation will be important to provide an unbiased view and a valid assessment. Investigations of fraud should always be conducted by two auditors. 

The PLL program is a comprehensive, multicomponent activity that is distributed across all PMCD demilitarization sites and includes workshops, assessments, technical bulletins, directed actions and updates, programmatic planning documents, site document comparisons, critical document reviews, and a quick react feature (Box 4-1). 

Directed actions and updates transfer information or request that it be sent from or to the chemical demilitarization sites. Originating primarily in the workshops and/or quick reacts, directed actions and updates can also come from the PLL oversight board, critical document reviews, and other similar activities. The directed actions are assigned by PMCD managers and tracked by the PLL team until theyare acted on. The responses are reviewed by the PLL team and incorporated into the PLL database. 

Site documents comparison involves PLL team review of new documents prepared at a site and comparison to previously approved documents from an earlier site and to programmatic guidance. The PLL team provides comments and recommendations, but implementing them is not mandatory at the site level. 

The EFCOG/DOE CSTC CUSHR Team conducted a limited review of how DOE sites address compressed gases. Results showed that at these sites, only 50-70% of requirements were addressed in site documentation of chemical-related safety and health requirements. These results confirmed the view that while all DOE contractors who engage in the same work activities must follow the same requirements, many either do not know which requirements apply to their work or are confused by them. The Team concluded that this was likely due to the fact that multiple requirements from many varied sources frequently overlap, covering the same points in slightly different and sometimes conflicting ways. 

The OIVV team prepares phase reports and submits to regulatory authority for reference after accomplishing each phase. The report covers document review reports, site visit reports, thread audit reports, and anomaly reports completed by OIVV team during each phase. Also, all anomaly items are... 

The audit should be based on document review, selected interviews, and observations on operations during site visits. 

In recent years, the reactors at the Savannah River Site (SRS) have undergone careful scrutiny in the area of reactor safety. Three major appraisals, which focused primarily on Three Mile Island (TMI) related issues were the Crawford Reports, the DuPont Post-TMI Assessment, and the Committee on Nuclear Safety Report. In addition, documented reviews by the Advisory Committee on Nuclear Facility Safety (ACNFS), the National Academy of Science (NAS), the Government Accounting Office (GAO), and DOE addressed issues related to the SRS reactors that have arisen in light of Chernobyl. In all, over 75 documents contain the results of assessments addressing issues that could affect the operation and safety of the SRS reactors. 

It may be appropriate, based upon the hazards of the materials processed, for the client company to make a final site visit during the toll shutdown activities to review the toller s methods and completeness of process termination. This review could include termination status such as removal of all hazardous wastes and verification of associated documentation, and the adequate cleanup of equipment and the process area. 

Does the facility evaluate (for example, audit) the off-site waste management facilities used to manage hazardous wastes If yes, do the evaluations ensure that wastes will be handled safely, without causing harm to waste handlers, the public, or the environment Flave the reviews been documented ... 

Contract documents should be reviewed. The HASP should reflect and possibly reference contractual agreements. Contract documents can contain much information pertinent to site safety. For example, many contracts contain monetary incentives for completion of site work accident free. If management wishes to share some of this monetary incentive with site workers, the HASP is an excellent vehicle for communicating safety incentive programs. 

Audits by definition are conducted on-site. An audit may be conducted using a variety of approaches and guides, but in general involves a team that gathers data through interviews, observation, and review of documentation. The team usually includes at least two people depending on the complexity of the facility or processes under review, tWs may expand to as many as five or more. 

In the area of documentation systems, there were several managers who had volunteered their site to be the pilot location. A relatively small location (Poole Harbor) was selected because while it had numerous documentation systems, it was also determined that the overall implementation time would be fairly short. This provided feedback in an expeditious fashion. The remaining managers who had volunteered their sites were used as part of a pilot review team to keep their interest and support active. They actually started to implement the protocols for a few of the documentation systems on their own, in advance of the roll out at their sites. They also became key proponents of the corporate-wide roll out of the overall integration effort, based on their involvement in just this one area. 

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