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…

Effective information management is critical to complying with complex EHS regulations. Join KTL and Southeast Missouri State University (SEMO) for this APPA webinar to get helpful tips for the successful management of EHS information, data, documents, and records.

Improving EHS Management with Information Technology: A University Demonstration
April 16, 2020 | Noon – 1:00 p.m. CT
REGISTER NOW!

This webinar will use a formal EHS management system model (plan-do-check-act) to highlight the importance of:

• Identifying, understanding, and documenting applicable EHS requirements
• Providing easy-to-use EHS information management tools
• Capturing institutional knowledge of experienced staff for operational sustainability

Learning Objectives

Facility managers, plant operators, EHS staff, and supervisors working in higher education will better understand:

• Key components of an effective EHS management system based on ISO 14001/45001
• Best practices for applying information technology to assist with EHS compliance
• Strategies for improving adoption of new technology tools throughout campus
• How to use an affordable, available technology platform (Microsoft SharePoint®) to enhance EHS compliance and communication practices

Presenters

SEMO’s Autumn Gentry will join KTL Principal Joseph Tell to provide a demonstration of SEMO’s recent efforts to manage and communicate EHS information using Microsoft SharePoint® tools to simplify EHS compliance.

REGISTER NOW!

About APPA, Leadership in Educational Facilities
Formerly known as the Association of Physical Plant Administrators, APPA is recognized globally as a leader in professional development programs, credentialing, research, publications, networking, and information services for the educational facilities profession. APPA’s mission is to “support educational excellence with quality leadership and professional management through education, research and recognition.” 

KTL is pleased to announce 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.

“Martin Mantz has created something unique with the GEORG software in that it simplifies and provides an interpretation of legal and technical requirements in a customer-specific database,” KTL Principal Lisa Langdon states. “KTL’s understanding of industrial operations, as well as U.S. legal and technical requirements (e.g., EPA, OSHA, FDA, ISO), allows us to translate these requirements into simple tasks in the GEORG system that employees can follow to help fulfill regulatory requirements.”

How GEORG Works

GEORG is used to make the requirements of standards and regulations comprehensible and transparent. KTL specializes in the practical mapping of legal requirements and audits. These audits allow KTL to create technical content for the GEORG system based on facility-specific applicability. We then work directly with the company to delegate the identified tasks. If there are revisions in the standards/regulations, KTL works in the system to ensure tasks are updated to meet regulatory requirements.

The benefits of this approach include:

• Effectiveness – All tasks are assigned, easily formulated, and regularly updated.
• Efficiency – The effort and expertise required to understand complicated regulations is reduced.
• Transparency – Responsibilities are clear and easily visible to all employees.
• Conformity – Compliance status within the system reflects the degree of fulfilment of the related requirements.

Faber-Castell Expands GEORG Implementation to U.S. Subsidiary

Faber-Castell Cosmetics, an internationally renowned Martin Mantz customer with worldwide operations, is already benefitting from the Martin Mantz-KTL partnership. After successful implementation of the GEORG software in their German facilities, Martin Mantz has worked with KTL to expand usage to Faber-Castell’s subsidiary in the U.S.

About Martin Mantz Compliance Solutions
Martin Mantz Compliance Solutions, based in Grosswallstadt and Leipzig, Germany, offers its contractual partners services in the area of ​​legal organization (GEORG) of companies to avoid organizational negligence and compliance violations. This includes consulting and provision of the compliance software GEORG Compliance Management System®, implementation of the technical and legal modules, as well as construction and maintenance of the customer-specific database. https://www.martin-mantz.de/

About Kestrel Tellevate LLC
KTL is a multidisciplinary consulting firm that specializes in providing environmental, health, and safety (EHS) and food safety management and compliance consulting services to private and government clients. Our primary focus is to build strong, long-term client partnerships and provide tailored solutions to address regulatory requirements. KTL’s services include management system development and implementation, auditing and assessments, regulatory compliance assistance, information management solutions, and training. KTL is a Small Business Administration-registered company with headquarters in Madison, WI and Atlanta, GA and offices across the Midwest and Washington, D.C. www.kestreltellevate.com

Aerosol cans have long provided regulatory challenges under the U.S. Environmental Protection Agency (EPA)​. Some states have defined aerosol cans as universal waste; some states define it as reactive (D003) waste​. On December 9, 2019, the EPA published a new rule (effective February 7, 2020) adding hazardous waste aerosol cans to the Universal Waste Program under the federal Resource Conservation and Recovery Act (RCRA) regulations.

This change provides a clear, protective system for managing discarded aerosol cans. The streamlined universal waste regulations are expected to ease regulatory burdens on retail stores and others that discard hazardous waste aerosol cans; promote the collection and recycling of these cans; and encourage the development of municipal and commercial programs to reduce the quantity of these wastes going to municipal solid waste landfills or combustors.

Current Review of Universal Waste

The designation of universal waste holds several advantages for generators. Universal waste doesn’t “count” against generator status. It does not have to be manifested and generally requires specific labeling language.

Under EPA’s definition, the following are the current universal waste streams:

• Batteries (Li, Ni-Cd, Ag, Hg)
• Mercury-containing equipment (MCE)
• Electric lamps
• Cathode ray tubes (in electronics)
• Pesticides (recalled or farmer-generated)

Adding Aerosol Cans

Adding aerosol cans to the EPA’s Universal Waste Program now provides the option for generators to manage the waste as hazardous or universal. The program addresses emissions with more stringent language​ and allows generators to set up separate management​.

More specifically, the following outlines some basic details of the program for effectively managing aerosol cans as universal waste:

• If the aerosol can is empty (i.e., at ambient pressure, there is no more liquid inside), it is considered an empty container. It can be recycled as metal or thrown away as solid waste (except for Nebraska, where it is D003).
• Full and partial aerosols can be recycled.
• Depending on the vendor, segregation may not be required.
• If the aerosol can is punctured, contents must be captured, and a hazardous waste determination must be performed.
• If the waste from the aerosol can is hazardous, the contents count toward generator accumulation.
• The only benefit to generators occurs if they ship unpunctured cans for recycling.
• If a household hazardous waste (HHW) facility accepts business aerosols and punctures them, the HHW facility becomes a generator.
• All emissions must be captured and managed properly; filters may be hazardous.

Regulatory Review

The new program for managing aerosol cans requires a safety program, education, and written documentation. KTL has the experience and expertise to help you evaluate your waste and to properly manage universal waste. Although not as complex as the requirements for proper hazardous waste management, universal waste has nuances that a generator must be aware of to properly meet the regulatory requirements. KTL can help determine how this new regulation applies and if it can help you minimize your regulatory burden, save some money, and manage your waste more efficiently.

To ensure companies uphold standards (internal or external) and continuously improve performance, audits are critical. In short, there are three primary purposes of auditing:

1. Verify conformance with the standard/requirement – Are we doing what the standard/requirement says we must do?
2. Verify implementation of stated procedures – Are we following the steps in our documented procedures?
3. Evaluate effectiveness – Are we accomplishing our goals and objectives?

For an audit to be effective, appropriate mechanics must be in place when it comes to planning, execution, and reporting.

PLANNING

As with most things, your execution will only be as good as your plan. All good audits must begin with planning. This involves everything from planning for your team, to planning out the scope of the audit, to planning all the associated logistics.

Auditors: Who Is on the Team?

Depending on the size and complexity of the audits, audit teams need to be selected. These individuals must be independent of the area being audited and trained in the basic elements of the facility’s management system and/or programs. Team members will be led by a trained auditor. The auditor’s responsibilities include the following:

• Comply with and communicate audit requirements
• Prepare working documents under the direction of the Lead Auditor
• Plan and carry out the assigned responsibilities within the scope of the audit
• Collect and analyze evidence to draw conclusions
• Document audit observations and findings
• Report audit results to Lead Auditor
• Retain and safeguard audit documents
• Cooperate with and support the Lead Auditor
• Assist in writing the report

As indicated above, one person on the team is typically designated the Lead Auditor. This individual will coordinate audit assignments and address any questions/concerns that may arise. Specifically, the Lead Auditor has the following responsibilities:

• Assigns team members specific management system/program elements, functions, or activities to audit
• Provides instructions on the audit procedure to follow
• Makes changes to work assignments, as necessary, to ensure the achievement of audit objectives

Audit Objectives, Scope, and Plans: What Are We Auditing?

The audit is all about:

1. Conformance – auditing sections of the standard/requirements to determine if the system conforms
2. Implementation – auditing work instructions to see if they are being followed

In determining the audit scope, it is importation to define what is to be audited (e.g., policy, planning, implementation, checking/corrective action, management review). If the organization has more than one physical location, the scope may outline what physical locations and/or organizational activities are to be audited (e.g., production lines or departments). These factors will ultimately also help determine the length of the audit.

Logistics: How Are We Going to Do This?

There are many things to factor into the audit from a logistical standpoint for it to go smoothly. Safety should always be of utmost concern. What precautions do auditors need to take? Is there any PPE that might be necessary? Do auditors need any special safety training introduction or training before conducting the audit? Consider the facility. Auditors need to understand the operation/activity being audited. In line with this, the auditor must also have an understanding of whether there is any equipment or special resources needed, ranging from technical support (e.g., tablets, smartphones) to lunch. Finally, it is important to make sure there are no conflicts of interest when it comes to the auditor and the facility that is being audited.

EXECUTION

Once planned appropriately, audits should be conducted according to the program elements. Interviews and objectives evidence will both provide the support needed to conduct a valid audit.

Program Elements

The auditor must know in advance which elements are being covered in an audit so he/she can:

1. Control the pace of the audit.
2. Guide the course of the audit.

That being said, additional audit activities should not be restricted if other issues arise.

Auditing should only be done against current controlled work instructions or procedures related to the program elements. Procedures that are being used in the field must be verified. Historical and/or uncontrolled procedures should not be used.

Auditors must remember that they are creating a record. Notes should include statements, document numbers, identifiers (e.g., department, area), positions. Common pitfalls to be avoided in taking notes include abbreviations, no location identifier for observations, no document references, illegible, pejorative, cryptic. These things all impact the credibility of the audit.

Interviews

The goal of an interview in the audit is to obtain valid information. However, how questions are asked will impact the answer. Auditors must prepare and know what questions need to be asked and how to ask them in advance of the audit. Creating an atmosphere of trust and open communication is key to getting open and honest responses. Remember, the goal is to audit the system, not the interviewee.

The following are good rules of thumb for conducting effective audit interviews:

• Direct questions to the person who does the job, not to the supervisor.
• Never talk down to anyone.
• Speak the person’s language.
• Speak clearly and carefully.
• LISTEN!
• Use who, what, where, when and why in your questioning vs. can or does.

Objective Evidence

Objective evidence provides verifiable information, records, or statements of fact. This is vital in any audit report. Objective evidence can be based on any of the following:

• Interviews
• Examination of documents
• Observation of activities and conditions
• Results of measurements
• Tests
• Other means within the scope of the audit

Evidence should be firsthand evidence based on witnessed fact, not supposition, presumption, hearsay, rumor, or conjecture. It can be qualitative or quantitative, but it should be repeatable.

REPORTING

Findings form the basis of the report. Findings can be classified in one of two ways:

• Nonconformance is the observed absence of or lapse in a required procedure or the total breakdown of a procedure that can cause a negative impact on the organization’s environmental performance. These can fall into a few categories:
  • Does not meet the requirements of the standard. This may include issues identified with records, procedures, work instructions, and use of controlled documents.
  • Is not fully implemented. Most commonly, these implementation nonconformances may relate to training, communication, and documentation.
  • Is improperly implemented. This is often demonstrated by worker lack of understanding, improper implementation of written work instruction, or missing stated required deadlines.
• Opportunity for improvement is just that—an opportunity to improve management to either reduce impacts, minimize legal requirements, prevent future nonconformances, or improve business performance.

The following examples and tips can serve as guidelines for writing useful and more concrete findings that will the company to identify opportunities for improvement:

• Do not overstate conclusions.
  • Poor: The procedure for handling spent light bulbs is being ignored.
  • Better: Three spent fluorescent bulbs were found in the general trash.
• State the problem clearly and exactly.
  • Poor: Instruments are not being calibrated.
  • Better: The sampling and analytical instruments in the wastewater treatment plant are not calibrated.
• Avoid generalities.
  • Poor: The area’s empty drum management process is inadequate.
  • Better: The hi-lo driver in the area handling empty drums was not trained on hazardous material handling.
• Communicate the extent of the problem fully.
  • Poor: All cardboard in the catalytic converter area is being sent to the compactor.
  • Better: None of the cardboard in the catalytic converter area was being stored and/or evaluated for reuse as dunnage.
• Do not focus on criticisms of individuals.
  • Poor: Jim Jones had no understanding of the safety policy.
  • Better: Discussions with several employees indicated that the safety policy was not fully understood.
• Give specific references.
  • Poor: Hazardous waste area inspections have not been conducted.
  • Better: Weekly hazardous waste storage area inspections (VMEWP-008) have not been conducted since June 2002.
• Avoid indirect expressions.
  • Poor: There were occasions when the reports were not filed on time. It appears the air monitoring equipment is not calibrated.
  • Better: Reports were filed late on ten occasions in 2002. There were no records of air monitoring equipment calibrations for 2001 or 2002.

Audits are a skilled activity. They provide the basis for assessment of conformance and, correspondingly, company actions to improve performance. For audits to be valuable, however, the audit process must be consistent and controlled. Clearly and correctly documented nonconformances lead to appropriate corrective actions—the mechanism for translating audits into improvements.

Southern Region Meeting: February 24-26, 2020

KTL is looking forward to seeing many NACD member companies at the NACD Southern Region Meeting in Savannah, GA February 24-26. It’s always such a great time to gain great insights from the NACD speakers, touch base with you on the latest happenings in your organization, and continue our conversations about your business and compliance needs.

Jake Taylor, KTL’s Responsible Distribution Adviser, will be available throughout the meeting to talk more about how KTL can help chemical distributors more effectively manage management system requirements (e.g., Responsible Distribution, ISO 9001) and ongoing EHS&S and food safety compliance obligations.

MEETING DETAILS

Spring Regulatory & Responsible Distribution Workshop: March 10-12, 2020

Plus, save the date for the NACD Spring Regulatory & Responsible Distribution Workshop this March in Long Beach, CA. The 2020 Regulatory Workshop focuses on International Trade for Chemical Distributors on March 10.

Attention turns to Responsible Distribution March 11-12. There are many great sessions planned for new and experienced NACD members, including KTL’s interactive session on Thursday, March 12 from 9:15-10:15: Digging Up the Roots! Root Cause Analysis Review and Exercise. Jake Taylor will be guiding participants through properly identifying root causes using real-world examples from 6th cycle non-conformance findings.

WORKSHOP DETAILS

Kestrel Tellevate is expanding our international resources with the addition of Consultant Emily Watt. Emily has in-depth knowledge of and experience as a Project Manager, working with federal contracting regulations and requirements. As a Consultant with international experience across multiple sectors, Emily will be working with KTL’s multinational clients and government agencies to provide EHS compliance and sustainability support.

Emily has worked on implementing projects for the U.S. Forest Service (USFS), U.S. Agency for International Development (USAID), U.S. Department of Agriculture (USDA) Agricultural Research Service (ARS), Office of Cooperative Threat Reduction (CTR) Chemical Security Program, and U.S. Department of State International Visitor Leadership Program (IVLP). Her primary countries of experience include Nigeria, Zimbabwe, Vietnam, Iraq, Turkey, Brazil, Malawi, South Korea, and India.

Read Emily’s complete bio for more information.

For the ninth consecutive year, Fall Protection – General Requirements (1926.501) has topped OSHA’s Top 10 Most Cited Violations list. The complete list for fiscal year 2019 includes:

1. Fall Protection – 1926.501
2. Hazard Communication – 1910.1200
3. Scaffolding – 1926.451
4. Lockout/Tagout – 1910.147
5. Respiratory Protection – 1910.134
6. Ladders – 1926.1053
7. Powered Industrial Trucks – 1910.178
8. Fall Protection – Training Requirements – 1926.503
9. Machine Guarding – 1910.212
10. Personal Protective and Life-Saving Equipment – Eye & Face Protection – 1926.102

In this article with Safety+Health, Deputy Director of OSHA’s Directorate of Enforcement Programs Patrick Kapust said, “These are common violations that we’re finding – they’ve been in place for a lot of years. The answers are out there, and employers shouldn’t feel like these are very complex issues.”

He further explains in the interview that the top 10 violations remain largely the same (with some variation in order) because employers don’t aggressively target these hazards in the workplace, despite OSHA’s resources. Falls remain the top cited hazard because they result in significant injuries and deaths.

That being said, falls, as well as the other top safety areas on the list, are easily preventable with the right training and commitment. Kapust suggests that the top 10 cited hazards are a good place to start when evaluating your workplace hazards. From OSHA’s perspective, targeted enforcement and outreach are two critical tools in getting employers to identify and correct hazards in the workplace. H&S professionals are encouraged to continue developing and promoting strong safety and health programs, as well as educating and training workers in safety awareness.

Read the entire Safety+Health article and interview with Kapust.