Checklists are a common way to collect information. From inspections and maintenance checks to near-miss and behavior-based safety reporting, most companies regularly use some form of checklist to gather information that should help inform operational decisions. Checklists are important. They establish good employee practices for regularly reviewing operational areas. But the information gathered in checklists only adds value to the organization if the data collected is used.

What happens to your checklists once they are filled out? Are they submitted? Is the data reviewed? And importantly, how are you leveraging the data gathered to better understand and improve your organization

Gathering Data

There are dozens of options available for gathering data through checklists. Paper checklists are largely becoming a thing of the past—and for good reason. Mobile forms and technology (e.g., Microsoft Forms, Google Forms) make completing checklists of almost any type easier and faster in the field. Mobile forms allow employees to quickly and easily complete forms from a mobile device—without logging in—from daily inspections to near-miss information as it is happening. Any daily, weekly, monthly form/checklist can be turned into a mobile form (e.g., Powered Industrial Truck inspection checklists, monthly tank inspection checklists, incident reports, non-conformance reports). Questions can be multiple choice, yes/no, text, numerical, rating scales, and several others.

Storing Data

Not only is completing an electronic form easy for employees, one of the largest benefits of gathering data via a mobile checklist is that the resulting data is already in digital format—and much more usable than a binder filled with paper checklists.

Checklists can be designed to move the data gathered from the form directly into a database, such as Microsoft SharePoint or a SQL database. Digital data from all electronic forms can then be stored in a centralized system; categorized for searchability; and easily accessed for review, comparison, and analysis.

Displaying Data

With all data that is collected being stored in a central database, it then becomes possible to leverage and manipulate that data to graphically display high-level information on a dashboard through the use of technology like Microsoft Power BI. Google dashboards offer another user-friendly alternative for analyzing the resulting data. Dashboards serve as a user interface to display/highlight key information. When companies amass a lot of data in many different areas, the dashboard can provide an integrated view of data pulled from multiple checklists/modules in an easy-to-read display. Dashboards such as this:

• Provide greater visibility and alert to issues that need attention/resolution across the entire organization.

• Allow management to view outstanding issues under their responsibility.

• Display up-to-date graphics of how the organization is performing compared to goals.

• Generate graphs and charts from the data collected based on what information needs to be reported.

• Allow for the use of advanced data analytics to help identify patterns and trends, inform business decisions, and guide resources.

Many companies have a lot of great data at their fingertips but knowing to how access and leverage it can be a challenge. Checklists and forms provide a relatively simple and straightforward method for gathering electronic data and turning it into valuable information that can improve operations and help inform business decision-making.

KTL is pleased to announce that we have renewed our agreement with the Construction Engineering Research Laboratory (CERL) of the U.S. Army Corp of Engineers, which provides access to the following regulatory question modules:

• The Environmental Assessment and Management (TEAM) Guide and the related state supplements address environmental compliance in the areas of air quality, cultural and natural resources, hazardous materials and waste, pesticide management, pollution prevention, energy conservation, petroleum, oils and lubricants, storage tanks, solid waste management, toxic substances, water quality, and more.
• The Occupational Safety and Health (OSH) Guide is used in assessing compliance with the standards of the Occupational Safety and Health Administration (OSHA). It may also be used in combination with an agency-specific safety and occupational health manual. The OSH Guide is based on OSHA regulations from Title 29 of the Code of Federal Regulations.

KTL originally entered into this agreement with CERL in 2015. CERL’s experts are dedicated to conducting ongoing research, updating federal and state environmental and federal safety regulatory requirements, and developing and maintaining standardized audit checklists for those regulations. These checklists are very comprehensive; are used by auditors for DOD, DOE, DOI, and other federal agencies; are updated regularly to reflect any regulatory changes; and cover virtually all of the functions that would be present in a broad mix of industrial companies.

Our agreement allows KTL to make the TEAM Guide and OSH Guide available through an electronic format (i.e. dynaQ™). KTL staff can use these modules to stay current on changing federal regulations. The question modules bring a basis of significant credibility related to the reliability and completeness of audit content via a software tool that manages audit data and makes finding information more efficient. With this agreement, KTL remains one of the only professional service firms in the country to offer access to the following regulatory question modules.

Get to know our KTL team! This month, we are catching up with Senior Consultant and Partner Roberto Bellavia. Roberto has been with KTL for three and a half years and is based in the Chicagoland area.

Tell us a little bit about your background—what are your areas of expertise?

I was born and raised in Rome, Italy. I have a master’s degree in animal production science and started my career in Italy working on the farming side of the food supply chain. I was working with farmers that had small manufacturing operations for cheese, salami, meat, and I was doing food safety (HACCP) plans for them. I also worked in a couple of dairy farms.

I first came to the U.S. in 1999 for a genetic research project at the University of Minnesota on mapping of chromosome 29 in bovine. I moved to the U.S. permanently in 2001, when I got married. I worked at the Italian Chamber of Commerce, made connections, and started working for Turano Pastry Shop as Production Manager. I learned Spanish before I learned English! I wanted to move back into the meat industry, so I began working at Chiappetti Lamb and Veal in the Stockyards District in Chicago, the last federal-inspected plant in the city. When they closed, I moved to U.S. Foods as the Director of Food Safety for the Stockyards brand.

I joined the consulting world at KTL in January 2017. My areas of expertise revolve around food safety, quality, and regulatory compliance. I am well-versed on all the GFSI schemes (i.e., FSSC22000, SQF, BRC, IFS) and the USDA – FSIS and FDA requirements. In this role, I really enjoy working with different people. There is no reporting structure in my team; rather, it is about people working together to achieve the same objectives. I am in the business of food safety. I believe that people always want to do the right thing, but sometimes they need someone to tell them what the right thing is or to show them how to get there.

What types of clients do you work with? What are the biggest issues you see them facing right now?

All my clients are in the food supply chain—from food manufacturing, to food additives and food packaging, to distributors and importers. I also work with a company in the dietary supplement arena, which is an area with growing food safety requirements.

 Data management is one of the biggest challenges facing my clients right now. How do you collect and use data, while also protecting information? Every company needs to fulfill someone else’s requirements (e.g., regulatory, standards, customers, supply chain) by submitting information, auditing, reviewing, and assessing and allocating levels of risk. Our clients look to KTL to help them meet those needs.

Training and culture change are two other large areas where food companies rely on KTL’s expertise. When a company decides to pursue a major change in their food safety program, they also need help in culture change and much of that starts with training.

Lastly, the new rules of the FDA – FSMA have been a challenge, including implementing allergen control, environmental, and food defense/intentional adulteration programs.

What would you say is a highlight of your job?

I get to be 100% involved in what I do. I always seek the highest results and take pride in everything I do. It is important to me to show my clients the value they get from working with KTL, and what we have accomplished once our project is done. We are currently focusing a lot of our expertise on data management and predictive analytics, developing dashboards that allow our clients to see in real time the performance of the food safety programs we are developing. It is very satisfying to see those results.

What do you like to do in your free time?

My free time is about my wife, my three kids, and my dog. When I don’t work, I enjoy spending time home. I like to coach soccer and have been a coach for over eight years. I enjoy a home-cooked meal (because I travel and eat out a lot), spending time at the beach (but that never seems to happen), and playing cornhole (a/k/a bean bags). I also like motorsports, so when I can (and when COVID is not cancelling half of the season), I enjoy watching Formula 1 racing (there is something about technology, courage, and teamwork that is fascinating) and European football (a/k/a soccer).

Finally, I enjoy road tripping with the family—or just driving alone—and discovering and seeing something new. I have been in three different Portlands in the U.S.! I feel that every place I go, no matter how remote or rural it is, has something interesting for me to see.

Read Roberto’s full bio.

The second annual World Food Safety Day (WFSD) returns on June 7, 2020 under the theme “Food safety, everyone’s business.”

WFSD was originally declared by the United Nations on June 7, 2019, to draw global attention and inspire action to help prevent, detect and manage foodborne risks, contributing to food security, human health, economic prosperity, agriculture, market access, tourism and sustainable development. 

This year’s celebration focuses on food safety being a shared responsibility—from farm to table—including governments, to producers, to consumers.

A wider reaching global supply chain exposes our food and those companies within the food supply chain to increased risk. KTL is committed to supporting companies in our increasingly complex world with effectively operating across the food supply chain, while managing food safety and quality risks.  

Both the U.S. Food and Drug Administration (FDA) and World Health Organization (WHO) offer a number of resources for companies and individuals to participate in World Food Safety Day and help reduce food safety risks.

The COVID-19 pandemic has had tremendous impacts on various industries and sectors—most have had to adjust business practices (in small or large ways) to meet new guidelines for safe operations. At times, it may seem impossible to keep up with the latest developments/recommendations and their impacts on day-to-day operations.

A cross-cutting issue for almost every business (and every household) is the safe and proper management of waste. Almost all our activities generate some form of waste. During an infectious disease outbreak such as COVID-19, it becomes increasingly important to ensure the provision of safe water, sanitation, and hygienic conditions to help prevent human-to-human transmission of the virus.

Updated Guidance

State and federal agencies throughout the U.S. and abroad, as well as international organizations, have begun to issue new and/or update existing guidance regarding proper waste management practices as experts learn more about the COVID-19 virus (SARS-CoV-2). The U.S. Occupational Safety and Health Administration (OSHA), for example, recently issued guidance stating that, “Generally, management of waste that is suspected or known to contain or be contaminated with COVID-19 does not require special precautions beyond those already used to protect workers from the hazards they encounter during their routine job tasks in solid waste and wastewater management.” However, state, tribal, and local governments may follow stricter guidance.

Similarly, the World Health Organization (WHO), in its April 2020 revised Interim Guidance, noted that there is “no evidence that direct, unprotected human contact during the handling of healthcare waste has resulted in the transmission of the COVID-19 virus.” The WHO further states that the usual best practices for the safe management of infectious waste should be exercised.

Best Practices to Minimize Risk

The OSHA and WHO guidance highlight an important point—where existing processes and systems can safely be relied upon for the proper management of waste during this pandemic, organizations should avoid making changes. Where the nature of COVID-19 requires adjustments, that is where organizations should focus their efforts.

Outlined below are some general best practices that organizations should consider implementing to minimize risks associated with waste management during COVID-19 and beyond:

• Municipal Waste: Workers and employers should manage municipal (e.g., household, business) solid waste with potential or known COVID-19 contamination like any other non-contaminated municipal waste. Workers should prevent exposure to waste through safe work practices and approved Personal Protective Equipment (PPE), such as puncture-resistant gloves and face and eye protection. To help protect sanitation workers, the Idaho Department of Environmental Quality (DEQ) advises households with waste suspected to be infected with COVID-19 tightly enclose waste in heavy-duty bags, double-bag the waste, and ensure that curbside containers can close completely. As always, anyone handling waste should wash hands thoroughly.
• Healthcare Waste: Healthcare waste with potential or known COVID-19 contamination should be managed like any other regulated medical waste. In the U.S., COVID-19 is not a Category A infectious substance. Again, use typical engineering and administrative controls, safe work practices, and PPE to prevent worker exposure. Although not required, the Healthcare Waste Institute (HWI) recommends COVID-19 waste be identified to protect workers in the event a bag needs to be re-opened. Only grossly contaminated PPE should be placed into sealed bags (red bags in the U.S.). Tissues or similar materials used by patients when coughing or sneezing should be immediately disposed of in a lined waste receptacle, and then correct hand hygiene should be performed. Such waste may be disposed as regular trash (i.e., municipal solid waste), unless otherwise directed by local health departments. Public Health England, for example, advises that such waste be double-bagged, tied securely, stored separately from other waste, and left for 72 hours before sending for disposal as standard municipal solid waste.
• Recycling: As with municipal waste, employers and workers in the recycling industry should continue to use typical engineering and administrative controls, safe work practices, and PPE to prevent exposure to recyclable materials they manage, including any contaminants in the materials. Organizations and households should always refer to their local recycling hauler’s guidelines to determine if and what products can be recycled. The U.S. Environmental Protection Agency (EPA) is advising individuals to treat recyclables as trash if anyone in their home has COVID-19.
• Wastewater: Coronaviruses are susceptible to the same disinfection conditions as other viruses, so current disinfection processes in wastewater treatment facilities are expected to be sufficient, per OSHA and the Centers for Disease Control and Prevention (CDC). This includes practices such as oxidation with hypochlorite (i.e., chlorine bleach) and peracetic acid, as well as inactivation using ultraviolet irradiation. There is no evidence to suggest that additional, COVID-19-specific protections are needed for employees involved in wastewater treatment operations.
• General Hygiene and PPE: As currently recommended by all agencies, improved personal hygiene, particularly adequate handwashing and the use of adequate PPE (e.g., masks, gloves, eye protection), offers the greatest protection against COVID-19, including transmission through waste. Staff handling waste should be properly trained, use approved PPE, and maintain good hygiene.

As with many facets of this pandemic, regulatory requirements and best practices are subject to change as we continue to learn about the virus and its transmission. KTL can help you monitor these developments and understand which requirements and guidance apply to your operations—both in the U.S. and abroad.

Audits provide an essential tool for improving and verifying compliance performance. Audits may be used to capture regulatory compliance status, management system conformance, adequacy of internal controls, potential risks, and best practices.

Most regulations, standards, and guidance require audits to be conducted with some established frequency. For many companies, figuring out how to meet these audit requirements amongst travel restrictions, new company safety protocol, and government quarantines related to COVID-19 presents a significant new challenge.

The Online Alternative

Companies come in a variety of sizes with a range of different needs. Because of this, auditing standards remain fairly flexible by design. Fortunately, this allows for online/remote/virtual audits as a viable alternative to onsite audits—provided the audits:

• Are planned well;
• Appropriately leverage technology; and
• Are executed by a team who understands the facility and the requirements.

The ultimate objective of a virtual audit remains the same as an in-person audit: To obtain credible audit evidence to accurately assess compliance/conformance with identified requirements/specifications. The difference lies in the means in which that evidence is collected (i.e., live stream video, surveillance cameras, group web meetings, electronic document review).

Weighing Risks vs. Rewards

Audits can be conducted onsite, remotely, or a combination of the two. In many cases, companies may already be having portions of the audit (e.g., document review) done remotely. Moving the entire audit to the virtual world allows credible evidence to be obtained in unique ways that can offer significant benefits to a company when onsite audits aren’t possible—and even when they are:

• Reduced cost – Online audits eliminate the expenses associated with travel (i.e., mileage, flights, hotels, meals), which can add up depending on the location and duration of the audit.
• Flexible schedule – Remote audits can be conducted on a more flexible time schedule. Auditors do not have to complete work onsite in a set number of days, as is required when traveling to a facility. The auditor can also review areas in question remotely after the audit is technically over. Note that a more flexible time schedule does not necessarily mean less time involved to conduct the audit.
• Social distancing – As CDC guidelines have recommended, it is currently safest to work remotely, when possible, or to remain six feet of social distance to avoid potential transmission of COVID-19. Through the use of technology, virtual audits provide a social distancing extreme.
• Improved systems – Preparing for a virtual audit provides the “push” some organizations need to improve electronic storage systems. To conduct a virtual audit, documents and records must be retained in an organized manner that facilitates easy/quick access. Being able to access all documents remotely is necessary—paper records or documents stored on individual computers/network drives no longer cut it.

At the same time, there are some potential risks to conducting a completely virtual audit, particularly since this practice is relatively new to many organizations:

• Observation/technology limits – Observation of site conditions is limited by the ability to direct live stream video remotely. Technology can create limitations. If the camera can’t see it, neither can the auditor. Poor video quality can impede visual clarity. You don’t know what you don’t know.
• Communication confusion – It can be difficult to read body language and/or interpret emails and phone conversations to make sure communication is clear. This can require revisiting topics/findings several times to ensure accurate evidence is collected.
• Time barriers – There may be time zone and associated scheduling barriers depending on the location of the auditor and the facility.

Considerations and Best Practices

Regardless of the type of audit a facility conducts (i.e., remote, onsite, combination), standard audit best practices should be followed to ensure that audit results are comprehensive and credible. If the company opts for a virtual audit—for any reason—there are a number of considerations and best practices to ensure that the audit effectively fulfills its objectives and alleviates the risks outlined above to the extent possible:

• Site Familiarity – Virtual audits work best if auditors are familiar with the industry and/or operations. While it is not necessary for the auditor to have visited the site before, that type of familiarity with the facility provides the best-case scenario, especially for compliance audits, as it prepares the auditor to know what to look for (and where) and what questions to ask.
• Careful Planning – Much like onsite audits, virtual audits require careful upfront planning on the part of the auditor and the facility—and perhaps to an elevated degree.
  • The facility needs to collect all documents and records prior to the audit and determine best way to present that information remotely (e.g., email/transfer ahead of time, allow access to company Intranet/shared directory space, share during a web meeting).
  • Interviews are best scheduled in advance to ensure availability; however, they can be conducted on an ad hoc basis as need arises.
  • It is best to plot out route and areas of specific focus for the audit ahead of time using a site map as a guide to ensure that all areas are covered and that the audit can be conducted as efficiently as possible using the allocated facility resources. An audit site guide must be assigned who is familiar with the entire facility.
  • Technology needs and requirements must be evaluated, and logistics and access should be tested prior to the audit. It is vital that all cameras, web meetings, shared document space, WiFi, and other technology is working appropriately prior to the audit or a lot of time can be wasted troubleshooting issues.
• Video – Videos should be live. Site walks should be led by a site guide/employee along the planned route with smart phones, iPads, etc., with live streaming capabilities. It is important to ensure that live streaming works within the facility being audited so auditors have a clear view of site conditions. Auditors can also take advantage of any in-house surveillance cameras (e.g., security or quality systems) to provide additional footage of operations, when necessary. In most cases, surveillance footage cannot replace live video.
• Web Meetings – Opening, closing, and daily briefings can be conducted via web meeting. Remote audits provide the flexibility to conduct the audit in segments, with briefings following each segment. This allows the auditor to review video footage, evaluate records, and generate questions to ensure the information collected is accurate and complete.

Companies all over the world are working through a transition period right now, where they are trying to establish what a new “normal” looks like when it comes to operating practices, employee health and safety, business continuity, and compliance. Audits are one piece of the overall puzzle that can be transitioned somewhat seamlessly with the right planning and technology in place to ensure ongoing compliance.

How many permits does your operating system (e.g., facilities, production, storage, transportation, distribution) have? What kinds of requirements are associated with each of those permits? Who is responsible for making sure requirements are fulfilled? Are there key/critical dates? How many contractors/vendors do you have carrying out activities pertaining to the many diverse permit requirements? How do you manage all that information? And, importantly, how do you verify compliance?

Depending on the breadth and locations of your operations, managing permits and their associated requirements and due dates without a centralized system in place can be an insurmountable challenge. This was certainly true for a large transportation company managing over 3,600 permits for over 1,600 projects across more than 20 states. Finding a better way to track and manage permits wasn’t just a matter of convenience, it was a necessity.

Web-based Tracking System

After a series of washout incidents, the company’s Engineering Department stepped up its efforts to develop a program to ensure engineering and maintenance activities were meeting applicable construction and environmental permit requirements. With so many activities, responsible parties, and deadlines, the Department retained Kestrel Tellevate LLC (KTL) to develop a web-based project tracking system to help:

• Track permit requirements and construction restriction timeframes
• Produce project-specific All Permits Issued (API) documents
• Track post-activity mitigation requirements
• Manage change information
• Report actual-to-budget performance

While the Engineering Department remains responsible for the permitting activities associated with all construction, maintenance, and emergency response activities, KTL’s Permit Tracking System (PTS) offers a cloud-based project management solution to facilitate permit tracking across a variety of data points.

How It Works

The PTS serves as a communication conduit by providing a standardized approach to project/permit activity tracking, while distributing periodic, tailored reports that allow the Engineering Department to manage project activities, as needed. Integrating with internal databases, PTS provides a means to supplement project data with ongoing contractor/consultant input. This enables comprehensive program oversight on the timeliness of the permitting effort and project details, which, in turn, offers preemptive visibility on issues that may affect project construction and permit compliance.

In short, PTS allows the company to:

• Catalog and track permits in one database
• Document and track project conditions, impacts, construction timeframe restrictions, sensitive resources, etc.
• Send and receive notifications of permits about to expire
• Coordinate and communicate with project contractors
• Establish accountability and a standardized approach for reporting and performance measurement
• Effectively manage project process from permitting through handover to construction
• Monitor financial performance

Business Benefits

The Engineering Department has managed nearly 1,600 projects with more than 3,600 associated permits through PTS. Permits in the system include 404 (most common), 401, Floodplain, NESHAPS, FAA, 402, Air, Coast, Air Emissions, 408 Levee, Coast Guard Bridge, Heritage Tree, Tank, Well, Excavated Materials, NPDES, and others.

With this many projects and permits being managed through a consolidated system, PTS is providing many business benefits, including the following:

• Improved program efficiency, consistency, and coherence by fostering a standardized approach to all permitting data management and input by third-party users
• Customized, automated reporting that allows for enhanced progress monitoring, project accountability, and detailed oversight
• Flexible, cloud-based approach to accommodate a variety of program management aspects into a single tool for real-time, comprehensive visibility
• Sole repository for all project management data to help foster communication and coordination both internally and with contractors/consultants
• Improved permit compliance assurance reliability

The following information outlines provisions the GFSI-benchmarked schemes are taking to account for audit disruptions due to COVID-19, as of April 21, 2020.

FSSC 22000

www.fssc22000.com

Re-Certification Audits (V5 upgrade audits)

• A risk assessment will be completed.
• The decision from the risk assessment could lead to extension to the current V4.1 Certificate of up to 6 months.
• The full V5 re-certification audit will need to take place within 6 months.
• The new V5 certificate will have dates aligned with the current certification cycle.

Surveillance Audits (V5 upgrade audits)

• A risk assessment will be completed.
• The decision from the risk assessment could lead to:
  • Maintaining the current V4.1 Certificate
  • Suspending the V4.1 Certificate
  • Postponement of the surveillance/periodical V5 upgrade audit by a maximum of 6 months.

BRC GS

www.brcgs.com

Recertification Audit

Where the site is operational, but a physical audit cannot occur on or before the due date and will result in an existing certificate expiring, a certificate extension of up to 6 months validity may be issued based on:

• The successful completion of a risk assessment by the certification body confirming it is appropriate to continue certification.
• The certification body completing a discussion with the site and review of procedures in place to establish the impact of COVID-19 extraordinary circumstances to the site operations and the effective implementation of an emergency response plan.
  • Certifications can only be extended by the current certification body.
  • Sites with C & D grades may not be extended.
  • For BRCGS Packaging, any extended certificates will be against Version 5.

IFS

www.ifs-certification.com

IFS is subject to the decisions of local authorities and cannot provide a general statement (each situation need to be assessed individually). In the case that an audit cannot be performed on time:

• This will result in the certificate not being renewed.
• An exceptional extension of the existing IFS Certificates is not possible.

Due to precautions taken by local authorities, it may not be possible to carry out audits. In this case, existing IFS certificates remain valid until the end of their term and then lose their regular validity.

IFS appeals to retailers and their suppliers to contact and find bilateral solutions so that supplier contracts can be maintained. The IFS will make it visible in the database if IFS certificates could not be renewed due to COVID-19.

SQF

www.sqfi.com

A certifying body can request to SQF for a site to have a one-time 6-month extension from the certificate expiration date.

• Request may not occur until site is within the audit window of the audit.
• Certifying body will conduct a risk assessment to understand and determine if there is a need to extend the certificate following the IAF Informative Document for Management of Extraordinary Events or Circumstances Affecting ABs, CABs, and Certified Organizations (IAF ID 3:2001).
• Certifying body will submit a change request and Notification Form to SQF for approval.
• Requests will be considered by the SQF Compliance Manager in consultation with the technical team and applicable certifying body and/or legal counsel.
• If the risk assessment identified a low risk of continued certification for a site, SQF will approve and certifying body will extend the expiration date for 6 months from the recertification date.
• Sites that are in the process of switching to a new certifying body, the certifying body that holds the current site’s certificate will be required to conduct the risk assessment to determine the risk level to the existing certificate.
• Unannounced audits can be waived up to 5/31/2020. Any waived must be conducted in 2021.

KTL will continue to track these changes and their impacts on the food industry. We hope KTL can be a trusted resource on many levels now and as we eventually return to “business as usual”.

At the most basic level, a root cause is the fundamental reason—or the highest-level cause—for the occurrence of a problem, incident, or event. The root cause sets in motion the entire cause-and-effect reaction that ultimately leads to the problem. Getting to the root cause of any problem is important not just for resolving the issue at hand, but for identifying underlying issues to ensure that similar problems do not occur in the future. This starts with a process called the root cause analysis (RCA).

What Is the Root Cause Analysis (RCA)?

A root cause can be permanently eliminated through process improvement. RCA is a method of problem-solving used to identify the underlying (i.e., root) cause(s) of a problem/incident. RCA can be used to solve problems and provide preventive actions for:

• Major accidents
• Everyday incidents
• Minor near misses
• Human errors
• Maintenance problems
• Medical mistakes
• Productivity issues
• Manufacturing mistakes
• Environmental releases
• Risk analysis, risk mapping

RCA is a systematic process based on the basic idea that effective management requires more than merely putting out fires. RCA focuses on finding a way to prevent these fires from recurring. Rather than just treating symptoms, RCA seeks to identify and address the true, underlying concerns that contribute to a problem or event.

Why is this important? If you just treat the symptoms of the problem, that alleviates them for the short term, but it does nothing to prevent the problem from coming back again. Lasting solutions address the underlying factors—the root cause(s)— that create the problem in the first place. Targeting corrective measures at the identified root causes, subsequently, is the best way to alleviate risk and ensure that similar problems do not occur in the future.

Best Practice

Both the Occupational Safety and Health Administration (OSHA) and Environmental Protection Agency (EPA) encourage organizations to conduct RCA following an incident or near miss at a facility. In fact, facilities covered by OSHA’s Process Safety Management (PSM) standard are required to investigate incidents that resulted in (or could have reasonably resulted in) a catastrophic release of highly hazardous chemicals. Similarly, EPA’s Risk Management Program (RMP) regulations require regulated facilities to conduct incident investigations. In addition, certain management systems, including ISO and Responsible Distribution (National Association of Chemical Distributors) to name just a few, also require RCA.

Whether an organization is subject to PSM, RMP, or management system standards, identifying the root cause of any incident or problem through RCA is a best practice that can significantly benefit organizations by identifying underlying issues to ensure that similar problems do not occur in the future. So, how do you effectively implement RCA?

Six-Step Process

RCA can be broken down into a simple six-step process, as outlined below.

Step 1: Identify and Clearly Describe the Problem

The first step is to understand and document the problem/issue/incident that actually occurred. This might involve interviewing key staff, reviewing security footage, investigating the site, etc. to get an accurate account of the issue. Certainly safety- or security-related incidents might require an immediate fix or prompt action before the carrying out the complete RCA. This is always the first priority.

Some problems are easier to define than others based on what happened and the extent of the issue. When defining and describing the problem, it is important to be as descriptive as possible, as this will aid in future steps to identify the root cause(s).

For example, the first description below is somewhat vague. The second description provides an additional level of detail that more fully documents the situation:

1. A forklift driver wasn’t wearing his seatbelt. (vague)
2. During a walkthrough of the warehouse on 2/1/20, it was observed that forklift driver John Smith, who is a contract employee, was not wearing his seatbelt while operating the forklift. (clear)

Step 2: Identify Possible Causes…Why?

There are several methods for identifying possible root causes. One of the most common is known as the “5 Why Method”. This approach simply involves asking the question “Why” enough times (i.e., five times) until you get past all the symptoms of a problem and down to the underlying root cause of the issue. The detailed problem description put together during Step 1 serves as the starting point for asking “Why”.

Let’s take our problem description from above a step further to identify the possible causes using the 5 Why Method.

Step 3: Identify Root Cause(s)

At this point, the 5 Why Method is leading you to the core issue that set in motion the entire cause-and-effect reaction and, ultimately, that led to the identified problem(s). It’s now time to determine whether the five whys have dug deep enough. Where does your questioning lead you? Is there one root cause or are there a series of root causes contributing to this incident? Often, there are multiple root causes that may be factors to address when preventing future incidents.

In our forklift operator case, the 5 Why Method points to the lack of a standardized checklist of all items to be trained on—including forklift training—prior to a new contract employee coming onsite.

Step 4: Corrective and/or Preventive Action Taken

Based on the identified root causes, it then becomes possible for the facility to determine what corrective and/or prevention actions (CAPAs) can be taken to fix the problem and, just as important, prevent it from occurring in the future. For our example, there are a number of potential CAPAs:

• Stop the employee from operating the forklift and educate him on seatbelt policy prior to resuming work
• Review contract/temp employee training program
• Retrain shift managers on training expectations
• Obtain training records for contract/temp employees
• Provide refresher/retraining, as necessary
• Add signage to forklifts and warehouse bulletin boards about seatbelt policy

Step 5: Analyze Effectiveness

The effectiveness of whatever action is taken in step 4 needs to be evaluated to determine whether it will resolve the root cause. If not, another CAPA should be explored, implemented, and analyzed to assess its impact on the issue/problem. If it is a root cause, it should help to resolve the issue and you should move on to step 6 below.

Let’s return to our example. You might ask, “Was the retraining effective?” An evaluation shows the following:

• Yes, the employee continues to operate the forklift using seatbelt.
• Yes, subsequent walkthroughs of the warehouse over the next six months have not resulted in any additional seatbelt violations.
• The next contract/temp employee brought on to assist during the busy end-of-year season was required to produce current training.

Step 6: Update Procedures, as necessary

As CAPAs are implemented, once they prove effective, related policies and procedures must be updated to reflect any changes made. This step ensures the outcomes of the RCA will be integrated into operations and used to prevent similar incidents from happening in the future.

In our current example, this might mean that the Contractor Policy is updated to include a new section specific to the hiring of contract/temp employees with the following requirements:

• Obtain valid training certificates for work performed
• Ensure Managers conduct on-the-job training for contract/temp employees specific to work performed

Benefits of RCA

Following these six steps will help to ensure a thorough investigation that identifies the root cause(s) versus just symptoms is conducted. It further ensures that any changes related to the root cause are integrated into the organization to prevent similar events from happening again. In the end, the RCA process can help:

• Reduce the risk of injury and/or death to workers and community members
• Reduce the potential for environmental damage
• Avoid unnecessary costs resulting from business interruption; emergency response and cleanup; increased regulation, audits, and inspections; and OSHA or EPA fines
• Improve public trust by maintaining an incident-free record
• More effectively control hazards, improve process reliability, increase revenues, decrease production costs, lower maintenance costs, and lower insurance premiums

KTL recently announced our partnership with Martin Mantz Compliance Solutions (Martin Mantz), developer of the GEORG Compliance Management System® software. KTL is providing regulatory compliance expertise to the German-based company as it expands its offerings to clients with operations in the United States.

In this recent article, our partners at Martin Mantz discuss how Rudolph Logistics Group, an international logistics service provider from Germany, is using GEORG as a compliance solution to provide employees clear information in accordance with ISO standards on:

• Tasks – what they have to do
• Responsibilities for implementation – who needs to do it
• Date/time of completion – when it needs to be done
• Description of the way the task is to be performed – how the task must be fulfilled

The objective is to simplify requirements to the extent possible so employees can focus on tasks to be completed without needing to interpret complicated and extensive guidelines. Read more…