KTL will be exhibiting at the American Correctional Association’s 155th Congress of Correction in Denver, CO, August 21-26, 2025. The Congress features a wide array of workshops and sessions focused on cutting-edge topics for correctional facilities. The educational workshops feature the best in the business, passing on critical knowledge and engaging in important discussions, while the expansive exhibit allows attendees to interact with hundreds of companies serving the correctional industry.

Be sure to stop by and visit KTL at Booth #871. We look forward to seeing you at the Congress of Correction!

Safe + Sound Week

Electrical safety issues have been among the top findings in the Occupational Safety and Health Administration (OSHA) compliance audits KTL has conducted over the past year. Many workers are unaware of the potential electrical hazards present in their work environment when completing tasks that involve electricity. As such, they end up working in either unsafe conditions (e.g., poorly maintained/deteriorating equipment) or unsafe work practices (e.g., using conductive tools, not de-energizing prior to work)—or both. The result can be an OSHA finding or worse, including electrocution, electric shocks and burns, injury from exposure to arcing, and fire from faulty electrical equipment or installations.

Electrical Safety Standards

OSHA and National Fire Protection Association (NFPA) electrical safety regulations are complex. OSHA actually has several standards that address electrical safety. The most notable for general industry is 29 CFR 1910 Subpart S, which is broken into sections on design safety standards, safety-related work practices, safety-related maintenance requirements, and safety requirements for special equipment. If you have electrical equipment, at least some of OSHA’s electrical requirements will apply.

NFPA 70E supports the OSHA standard and fills in gaps, particularly related to qualified workers and hazard assessments. NFPA states that an Electrical Safety Program should develop a risk assessment procedure that outlines processes to identify hazards, assess risks, and implement controls before work begins. NFPA 70E is revised every three years.

Common Electrical Hazards

Electrical energy remains one of the most serious health hazards in the workplace, which is why all workers need to understand the dangers of electricity and how to take proper precautions. The following are the most common electrical safety gaps identified in KTL’s safety audits over the past year:

• Misused equipment. If electrical equipment is not used as designed or according to manufacturers’ instructions, safety features are not reliable.
• Damaged or defective electrical equipment is damaged or defective. When electrical panels, power disconnects, or any other electrical equipment in use at the site is not properly maintained, it can fall into disrepair. If electrical equipment is damaged, defective, or missing components, this may cause unintended contact with electrical components and lead to injury.
• Improperly used extension and flexible cords. Cords are subject to damage. Normal wear-and-tear can loosen or expose wires. In addition, employees do not always use the right type of cord for the intended usage and tend to repair and reuse cords that should be retired.
• Lack of ground-fault protection. Daily use of electrical equipment may lead to wear-and-tear (e.g., insulation breaks, short circuits, and exposed wires). Without proper safeguards, deteriorating equipment can create a ground fault that may send electrical current through a worker’s body.
• Missing path to ground. If the power supply to the electrical equipment is not grounded or the path is broken, fault current may travel through a worker’s body.

Creating Your Program

To eliminate these electrical hazards and their associated risks, it is important for any organization with electrical equipment to develop a written Electrical Safety Program, train employees, implement and enforce safe work practices, and regularly verify the Electrical Safety Program’s effectiveness.

Written Electrical Safety Program

A written Electrical Safety Program identifies the possible electrical hazards and outlines the procedures and controls required to effectively eliminate or engineer them out. Development of the Electrical Safety Program should be preceded by an electrical safety hazard assessment that systematically identifies electrical hazards that may cause harm, evaluates how likely and severe the potential harm is, and determines methods to effectively eliminate or control the harm from happening (i.e., hazard controls).

The Electrical Safety Program should consider safety through design, electrical risk management programs, job observations, refresher training, personal protective equipment (PPE) and tools, auditing, and electrical incident investigations.

Employee Training

It is important to understand that electrical training is not a one size fits all. As a part of an effective Electrical Safety Program, organizations should identify the scope of the electrical work—and who is qualified to do it—and then ensure those workers who have not been trained do not do electrical work. OSHA puts workers into two categories: unqualified workers and Qualified Electrical Workers (QEWs).  

• Unqualified workers are those employees who are not trained or permitted to work with live electrical components but may face risk of electric shock (above 50 volts). Unqualified workers must receive training on safety-related work practices that pertain to their job tasks and the inherent hazards of electricity (high voltage, arc flash, lack of guarding, etc.).
• According to OSHA, a QEW is one who has received training in and has demonstrated skills and knowledge in the construction and operation of electric equipment and installations and the hazards involved. Only QEWs are permitted to work on or near energized parts.They must have the skills and techniques to distinguish exposed energized parts from other parts of electric equipment and appropriate training on all electrical safety procedures.

Safe Practices and Conditions

Even with the best Electrical Safety Program possible, if an organization continues to implement unsafe conditions or unsafe work practices, electrical safety accidents will continue. The following list provides best practices for working safely with electrical equipment:

General Electrical Safety Principles

• Always assume that overhead lines and all wires are energized, even if they appear to be insulated.
• Never operate electrical equipment while standing in water.
• Do not use electrical equipment that shocks, smokes, smells, is damaged, or has burn marks.
• Train all workers appropriately.

Power Line Safety

• Contact utilities to identify buried power lines, look for power line indicators, and post warning signs.
• Stay at least 10 feet away from overhead power lines (unqualified workers).
• De-energize and ground lines when working near them.
• Use non-conductive wood or fiberglass ladders when working near power lines.

Tools and Equipment Condition

• Use only equipment that is approved to meet OSHA standards, including double-insulated tools and equipment.
• Visually inspect all electrical equipment prior to use and remove any equipment with frayed cords, cracked casings, missing ground prongs, etc. from service.
• Make sure any altered equipment is compliant.
• Continually audit tools and equipment available for use onsite.

Grounding and Bonding

• Ground all power supply systems, electrical circuits, electrical equipment, and exposed metal parts of equipment.
• In wet/damp locations, ensure electrical circuits or receptacles are equipped with a Ground-Fault Circuit Interrupter (GFCI).
• Use GFCIs on all 120-volt, single-phase, 15- and 20-ampere receptacles.
• Follow manufacturers’ recommended testing procedures for GFCI.
• Frequently inspect electrical systems to ensure the path to ground is continuous.

Cord and Plug Safety

• Use factory-assembled cord sets and 3-wire type extension cords marked with designation codes for hard or extra hard usage.
• Use only cords, connection devices, and fittings that are equipped with strain relief.
• Do not modify cords, repair cords with electrical tape, or use them incorrectly.
• Remove cords from receptacles by pulling on the plugs, not the cords.
• Continually inspect cords used onsite.

Lockout/Tagout (LOTO) and De-energization

• When possible, de-energize electrical circuits before doing any type of work according to proper LOTO procedures.
• Use lockout devices to prevent a circuit from becoming energized.
• Use an AC voltage tester to verify that the electrical power is off.

Verify Effectiveness

It is important to analyze the effectiveness of all electrical safety efforts, including electrical safety hazard assessments, the written Electrical Safety Program, and associated work procedures and equipment. Regular audits and inspections can help ensure work conditions and work practices protect employees and create a culture that understands and promotes the importance of electrical safety.

Building Safe Systems

Electrical safety encompasses many different elements and requires specialized qualifications and expertise to safely manage. As such, bringing in a second set of eyes to review and/or help build the right size Electrical Safety Plan for your facility can be helpful (or even necessary depending on in-house electrical capabilities). Relying on experts with not only electrical capabilities but also overall occupational safety understanding can help ensure you implement practical solutions—from compliance audits to customized electrical safety strategies—that integrate with your corporate Safety Program and operations and make your electrical systems as safe as they are efficient.

Safe + Sound Week

According to the Occupational Safety and Health Administration (OSHA), a hazard is any source of potential damage, harm, or adverse health effects on something or someone. It is a condition, activity, or substance that could lead to injury, illness, or even death if not controlled. For any workplace—regardless of size, industry, location, etc.—it is important to understand and control workplace hazards. This is done by conducting a hazard assessment.

Importance of Hazard Assessments

One of the primary root causes of workplace injuries, illnesses, and incidents is the failure to identify and control potential hazards. A hazard assessment (also known as a risk assessment) is important because it takes a thorough look at the workplace to:

1. Systematically identify those things that may cause harm (i.e., hazards), particularly to people.
2. Determine how likely and severe the potential harm is (i.e., the associated risk).
3. Decide what measures should be in place to effectively eliminate or control the harm from happening (i.e., hazard controls).
4. Create a plan to prioritize hazards associated with a specific activity/task/job and implement identified controls.

Steps to Take

Hazard identification and assessment should include the following steps:

• Collect existing information about workplace hazards. Determine the types of hazards that may be present and who might be exposed. This information can come from sources already available in the workplace (e.g., safety data sheets (SDS), operating manuals, OSHA 300/301 logs, job hazard/safety analyses, safety programs, worker input, etc.) or external sources (e.g., trade associations, labor unions, safety consultants, OSHA, NIOSH, CDC, etc.).
• Inspect the workplace to identify safety and health hazards. The objective is to identify potential hazards and address them before incidents occur. Think about how people work and what practices they follow, how equipment is used, what chemicals are onsite, and what the general condition of the facility is. Generally speaking, workers have the best understanding of the work being done, so they should be engaged in inspections.
  • Workplace incidents and near misses provide a clear indication of where hazards may exist. Look at past incident records to help identify less obvious hazards.
  • Consider employees, contractors, visitors, and members of the public.
  • Workstations, processes, operations, equipment, tools—and their related hazards—can all change, so regular inspections should be conducted.
  • Consider physical safety hazards, but also identify workers’ exposure to health hazards, including chemical, physical, biological, and ergonomic hazards.
  • Emergencies and non-routine situations present different hazards to manage. Identify foreseeable emergency situations and non-routine tasks and then develop procedures for responding appropriately and safely to potential hazards.
  • Use checklists to help ensure the major categories of hazards are addressed (e.g., general housekeeping; slips, trips, and falls; electrical; equipment operation and maintenance; fire protection; work organization and process flow; work practices; ergonomics; emergency procedures).
• Assess the associated risk of identified hazards. Think about the types of incidents that could result from exposure to those hazards. Consider the severity of potential outcomes, likelihood that the event will occur, and the number of workers who might be exposed (i.e., the overall risk). How likely it is that someone could be harmed and how serious it could be? Who might be harmed and how?
• Rank your risks. Assigning priority to hazards based on their risk creates a ranking that identifies which hazards are the most serious and should be addressed first. Ranking risks should consider the probability of exposure and the potential severity of an incident. It requires knowledge of workplace activities, urgency of situations, and objective judgement.
• Identify control options. Risk can be reduced/eliminated by controlling or eliminating the hazard or reducing employees’ exposure to the hazard.  
  • Review external sources and investigate control measures used at other workplaces to identify options.
  • Get input from workers who may be able to suggest/evaluate solutions based on their knowledge of the facility, equipment, and work processes.
  • Select controls that are the most feasible, effective, and permanent using the Hierarchy of Controls, which emphasizes engineering solutions first, followed by safe work practices, administrative controls, and then personal protective equipment (PPE).
  • Avoid selecting controls that may introduce a new hazard; discuss options with workers to ensure their feasibility.
• Develop a Hazard Control Plan. The Plan should describe how the controls will be implemented. What are you already doing to control the risks? What further action is required? Who is responsible for implementing the control? What is the timeline?
  • Address the serious hazards first. While interim controls may be necessary, the ultimate goal is to ensure effective long-term control of hazards.
  • Determine whether you can get rid of the hazard altogether. If not, identify what can be done to control the risk so harm is unlikely. This might include redesigning the job; replacing materials, machinery, or processes; reorganizing work; implementing new practices to work safely; or providing PPE.
  • Select additional controls to protect workers during non-routine operations and emergencies.
  • Assign responsibility and deadlines, conduct drills, track progress, and verify the effectiveness of controls once they are installed.
• Implement selected controls in the workplace. Implement measures according to the risk ranking priorities established in the Hazard Control Plan on a “worst-first” basis. Eliminate or control serious hazards as quickly as possible using interim controls, as necessary, while developing longer term solutions. In addition, promptly implement any easy and inexpensive solutions regardless of risk level.
• Follow-up to confirm that controls are effective. Monitor and track progress in implementing controls.
  • Conduct regular inspections and preventive maintenance to confirm controls are operating as intended and still effective, particularly when there are changes to the workplace that could introduce new risks (e.g., staff, processes, substances, equipment).
  • Record your findings so you can track and verify results.
  • Communicate the results. Workers must be aware of every hazard associated with their job and the controls in place to protect them.

Part of the Plan

Hazard assessments are an integral part of a Health and Safety Management Plan. They help organizations to evaluate hazards and then minimize the level of their risk by implementing control measures to prevent injuries and illnesses, meet legal requirements, and create an overall safer and healthier workplace. Employees should be engaged in the process, as they are generally the most familiar with workplace practices. An external party can offer additional perspective, experience, and fresh eyes in answering the following questions:

• What are the potential hazards?
  • What can happen and under what circumstances?
  • What are the possible consequences and risks of those hazards?
• How risky are the possible hazards and associated consequences?
  • How likely are they to occur?
  • How severe?
  • Who will they impact?
• How can we control or eliminate our hazards to reduce risks?
• Are our efforts successful?
  • Have we achieved an adequate level of risk reduction?
  • Is further action required?

According to the Occupational Safety and Health Administration (OSHA), safe workplaces are sound businesses. Every workplace should have a safety and health program that includes management leadership, worker participation, and a systematic approach to finding and fixing hazards. This is what it means to be Safe + Sound.

Safe + Sound Week

OSHA’s Safe + Sound program is a year-round campaign to encourage every workplace to develop and implement a safety and health program. During one week every August (August 11-17, 2025), OSHA promotes Safe + Sound Week as a nationwide event to recognize the successes of workplace health and safety programs and offer information and ideas on how to keep America’s workers safe. This year’s Safe + Sound Week focuses on emergency preparedness and response.

Participating in Safe + Sound Week can help companies get their safety and health program started, energize an existing program, or recognize company and individual employee safety and health accomplishments. It is an ideal time to reflect on and recognize the efforts you have made to improve workplace safety and health throughout the year and to focus in on areas of improvement going forward.

KTL’s Series on Investing in Safety

Throughout OSHA’s Safe + Sound Week this August, KTL will be featuring a series of safety-related articles and posts on our blog and social media (i.e., Facebook, LinkedIn, X), including:

• Hazard assessments
• Electrical safety 
• Emergency response
• Machine guarding
• Strategies for maintaining health and safety compliance.

Watch for these articles! For more information on what your organization can do to participate and promote a strong safety culture, visit the OSHA Safe + Sound Week website.

All types of organizations and operational processes demand a variety of audits and assessments to evaluate compliance with requirements—ranging from government regulations, to industry codes, to management system standards (e.g., ISO, GFSI), to internal obligations. Audits and assessments capture regulatory compliance status, management system conformance, supplier compliance, adequacy of internal controls, potential risks, and best practices.

Internal audits help identify problems so corrective/preventive actions can be put into place and then sustained and improved prior to third-party certification/compliance audits. Internal audits and assessments also help companies with continuous improvement initiatives.

Understanding the Internal Audit Process

Many organizations conduct internal audits with their own staff to assess conformance and identify opportunities for improvement. For companies large enough to have a dedicated internal audit team (with have no ties to the processes they audit), this may make perfect sense. However, it can take significant resources—time, personnel, money—to conduct all internal audits with internal resources.

It is easy to underestimate what goes into a successful audit and assume that it is more efficient and cost-effective to use internal resources. But that often isn’t the case. Let’s consider what an internal audit entails.

Pre-Audit Preparation

• Research: Auditors must understand the standard they are assessing against (i.e., regulatory, management systems, internal, industry). Effective auditors will also understand industry best practices; related local, state, and/or country-based requirements; processing norms for new product areas; etc. that can impact operational compliance and risks.
• Logistics: Logistics includes coordinating with the facility(ies) to schedule the audit and time with applicable personnel for interviews and, if travel is required, researching/booking flights, booking hotels, arranging for car transportation, etc.
• Document Review: Prior to the onsite audit, auditors should review available documentation (e.g., procedures, policies, programs). This will better inform and guide them on where they should dig more deeply during the audit, as well as help them create effective audit protocol (see below). Pre-audit document review also allows the onsite portion of the audit to remain focused on observing operations, interviewing workers, and verifying physical requirements are being met.
• Audit Protocol/Template: Auditors need to take the time to develop protocol/questions for conducting the audit, as well as standardized reporting templates, before the site visit. A standard protocol will make conducting multiple audits more efficient. Consistent protocols and templates also add value by allowing for direct year-over-year and site-to-site comparisons.

Onsite Audit

• Technical Knowledge: To efficiently conduct an audit, auditors must have a thorough understanding of the standard they are assessing against. In many cases, auditors are asked to juggle multiple areas of focus at once. For example, in a foods facility, the auditor may simultaneously evaluate Food and Drug Administration (FDA), U.S. Department of Agriculture (USDA), Global Food Safety Initiative (GFSI), and facility-specific procedure requirements. For an environmental, health, and safety (EHS) audit, the auditor may simultaneously assess Environmental Protection Agency (EPA), Occupational Safety and Health Administration (OSHA), state agency, and facility-specific requirements. Deep technical knowledge of all the related standards and codes helps to ensure a thorough audit.
• Audit Tools: Having the right tool for the job can make audits significantly more efficient. This includes the audit protocol and templates developed as part of pre-audit preparation, as well as audit tools that may be used to conduct and manage audits more efficiently and effectively.
• Audit Management: Auditors are responsible for building a relationship of trust and openness with the facility quickly, while still maintaining control of the audit. This can be a challenge for internal auditors when interviewing colleagues and assessing internal systems.

Post-Audit Follow-up

• Report: Auditors need to synthesize observations from the audit to create a report that concisely conveys all pertinent information, including nonconformances with the defined standard(s). Auditors provide additional value when they can leverage their industry experience to prioritize findings and identify opportunities for improvement and best practices. Reports are most valuable when finalized within a few weeks of the site visit when information is fresh to facility staff.
• Corrective Actions: After an internal audit, facility staff will inevitably have questions regarding findings and what to do next. Auditors can provide valuable support by offering recommendations, building corrective action plans, and supplying technical guidance.

Many organizations do not have dedicated internal auditors—rather, internal auditing is an “add-on” responsibility—so time spent completing these internal audit activities takes time away from other business responsibilities. This often results in a post-audit period where the internal auditor has significant catchup to complete other work that has been put on the backburner while conducting the internal audit.

Value of a Second-Party Auditor

A second-party auditor can provide an objective assessment of overall compliance status and, in many cases, do it more efficiently than organizations are able to do with their own resources. A second-party auditor has the time required to conduct the audit, travel, review documents, and create a report. Beyond that, a second-party auditor also has audit tools and templates to create efficiencies when conducting the audit and reporting, can consolidate audit trips, and can spend dedicated time completing all audit activities as efficiently as possible without needing to factor in other business responsibilities.

Beyond saving significant resources, using a second party to conduct audits provides significant business value and additional return on investment:

• Objectivity: Enlisting a qualified outside firm to conduct an audit provides a fresh set of unbiased eyes to assess aspects of your program internal staff may not consider or see. Second-party auditors offer broad perspective and knowledge of best management practices from conducting audits across industries and standards. They maintain ongoing, up-to-date awareness of current and pending regulatory requirements that the organization should consider.
• Customizable: The audits themselves can be customized to fit the needs and goals of the organization. A second-party auditor can provide more direct coverage to evaluate specific program effectiveness and allow for a more focused understanding of existing strengths and improvement areas. Whether there is a desire to prepare for unannounced regulatory agency visits, review plans and programs, assess supplier compliance, or even verify applicability, second-party audits can be built to address the organization’s identified concerns and help manage risks.
• Effective Tools: Second-party auditors often bring effective audit tools to help conduct and manage audits. These tools capture regulatory compliance status and certification system conformance more efficiently, track audit progress/completion status by subject, and generate reports that can be used by management to inform decision making. 
• Efficiency: Audits performed internally can take resources away from normal business operations not only when conducting the audit, but also when catching up on daily responsibilities and work that is set aside during the audit. Second-party auditors work with the resources allocated to them to conduct an audit in a timely manner that does not negatively impact business functions. These audits minimize the overall disruption in business compared to internal audits.
• Validation: Second-party auditors validate existing programs and identify areas where best practices can be implemented to further protect the company. They assist in identifying and prioritizing issues before they become violations—focusing on implementing and closing corrective actions. They also provide data and reports that can be shared internally with employees to improve performance or externally with communities or customers to bolster the company’s image.  
• Consistency: Using the same second-party auditor to conduct your audits creates consistency across locations and over time. This allows the organization to establish a benchmark for performance that can be used to help ensure continuous improvement throughout the organization and its supply chain.

Second-party audits are not just about checking boxes—they are about building stronger partnerships, spotting issues early, and keeping your business running smoothly. Don’t wait for nonconformances to catch you off guard. Implementing second-party audits isn’t just a compliance tool, it is a strategic advantage.

The Food Safety Modernization Act’s (FSMA) Preventive Controls for Human Food (PCHF) Rule (21 CFR 117) requires subject food facilities to develop and implement a robust Food Safety Plan that includes an analysis of hazards and risk-based preventive controls (PCs) to minimize or prevent those identified hazards.

One of the key requirements of the PCHF Rule is that certain activities be performed by a Preventive Controls Qualified Individual (PCQI) who is knowledgeable in the development and application of risk-based PCs. At least one PCQI is required at each subject facility, who is responsible for overseeing or performing the following:

• Preparation of the Food Safety Plan.
• Validation and verification of PCs and monitoring activities.
• Records review.
• Annual reanalysis of the Food Safety Plan.

PCQI Training Requirements

Becoming a PCQI requires knowledge in the development and application of risk-based PCs gained either through job experience or through training under a standard Food and Drug Administration (FDA)-recognized curriculum.

The Food Safety Preventive Controls Alliance (FSPCA) PCHF (PCQI) training curriculum, which includes minimum of 22 contact hours, is widely recognized by FDA and industry as the “gold standard” for food safety professionals to obtain the knowledge required to create a Food Safety Plan under the PCHF Rule.

A New Version

On June 30, 2025, FSPCA retired its previous (Version 1.2 (V1.2)) PCHF/PCQI training curriculum; as of July 1, 2025, FSPCA will only conduct and/or approve administration of its new Version 2.0 (V2.0) curriculum. V2.0 is designed to better equip participants with the most current tools and reference materials, new and updated guidance documents, and the latest strategies for managing Food Safety Plans and FDA compliance.

One of the most significant changes to the curriculum includes integrating the FDA’s new Hazard Analysis and Risk-Based Preventive Controls for Human Food draft guidance, which was released in January 2024. The curriculum expands the hazard analysis chapter to show participants how to use the guidance when performing a hazard analysis, takes a deeper dive into specific pathogens of concern for food, and offers more specific examples of chemical and physical hazards.

Other changes include the following:

• More modern format to improve clarity, including using QR codes to provide quick access to supporting documents and resources.
• Knowledge checks at the end of each chapter to help gauge participant understanding throughout training.
• Restructured to follow Hazard Analysis and Critical Control Points (HACCP) principles built on critical control points (CCPs) and expanded using PCs.
• Examples incorporating recent current events (e.g., recalls, economically motivated events).
• Updated model planning examples to support learning objectives.
• Clearer examples of how to document PCs.

Training Renewal

Individuals who received FPSCA training under PCHF/PCQI V1.2 do not need to re-complete the training course again to remain a PCQI. There is no FDA regulatory requirement to renew training to comply with the PCHF Rule. However, some customer and third-party requirements may require renewal.

Beyond requirements, taking the V2.0 course incorporates new FDA guidance information tools and may be valuable for any current PCQI to get new insights into the PCHF Rule and updated resources to help with compliance. All food safety professionals taking the FSPCA PCHF/PCQI course will be trained under the new V2.0 curriculum going forward.

Functionality: What does it do?

Every organization is at risk of incidents, those unplanned events that have the potential to disrupt service and cause significant operational impacts—safety, environmental, food safety, quality, reputational, etc. KTL’s Incident Management Tool provides organizations with an effective system to help manage workplace incidents, track patterns, identify trends, and correct unsafe practices to maintain compliance and prevent future issues.

Benefits: Why do you need it?

Built on Microsoft’s Power Platform, KTL’s Incident Management Tool:

• Allows for easy and secure data entry from any device, anytime, anywhere with mobile access.
• Tracks all types of incidents in one system, providing centralized incident data management, trending, and analysis.
• Connects to KTL’s Root Cause Analysis Tool and Corrective and Preventive Action (CAPA) Tracking Log to enhance incident investigations, identify root causes, and track and manage CAPAs to closure.
• Implements workflows to manage incidents, including sending email notifications, routing documents, processing forms, etc.
• Generates customized dashboards that provide visual displays of incident data to help identify opportunities to prevent future incidents.
• Improves compliance by organizing data for reporting to OSHA, EPA, or other regulatory agencies.
• Allows response teams to document and share information as events unfold—from initial emergency response protocols through crisis management steps—so proper decisions can be made and documented for business continuity.

Technology Used

• Power Apps
• Microsoft Dataverse
• Power Automate
• Power BI

Functionality: What does it do?

Root cause analysis (RCA) is a systematic method of problem-solving used to identify the underlying (i.e., root) cause(s) of a problem or incident, alleviate risk, and help ensure that similar problems do not occur in the future. KTL’s RCA Tool walks users through the 5-Why Process, a simple method for conducting an RCA that involves asking the question “Why” enough times (i.e., five times) to get past the symptoms of a problem and down to the underlying root cause of the issue.

Benefits: Why do you need it?

KTL’s RCA Tool ties directly to corrective and preventive actions (CAPAs) to help ensure an RCA is conducted, as needed, for each CAPA. The tool sends a notification to supervisor/management when a CAPA is submitted with a direct link to the CAPA so management can complete the RCA, assigns follow-up actions and sends notifications to the responsible person(s), and keeps records in a central location for audits, regulatory visits, or future data analysis.

Using the RCA Tool offers a simple way to conduct an effective RCA that can help organizations to:

• Reduce the risk of injury and/or death to workers and community members.
• Avoid unnecessary costs resulting from business interruption; emergency response and cleanup; increased regulation, audits, and inspections; and OSHA fines.
• More effectively control hazards, improve process reliability, increase revenues, decrease production costs, lower maintenance costs, and lower insurance premiums.

Technology Used

• SharePoint for data storage
• Power Apps for the user interface
• Power Automate to send notifications

The Safe Quality Food (SQF) Program is a rigorous food safety and quality program. Recognized by the Global Food Safety Initiative (GFSI), the SQF codes are designed to meet industry, customer, and regulatory requirements for all sectors of the food supply chain. SQF certification showcases certified sites’ commitment to a culture of food safety and operational excellence in food safety management.

In mid to late August 2025, SQF will be releasing Edition 10 to align the code with the latest GFSI benchmarking criteria, updated regulatory requirements, and scientific changes. According to the SQF Institute (SQFi), SQF Edition 10 is designed to reshape how food manufacturers approach safety, culture, change management, and continuous improvement. Edition 10 is scheduled for implementation with audits beginning April 2026.

Key Updates

According to SQFi, Edition 10 represents a strategic evolution in food safety management, focusing on three critical areas:

1. Food Safety Culture. Edition 9 elevated food safety culture by requiring senior leadership to lead and support a food safety culture within the site. Edition 10 aims to transform food safety from a procedural requirement to an organizational mindset by mandating robust Food Safety Culture Plans that demonstrate comprehensive strategies for the following:
   • Effective communication.
   • Comprehensive employee training.
   • Systematic feedback.
   • Continuous improvement.
2. Change Management. Edition 10 implements a mandatory change management clause that requires organizations to develop documented procedures for handling all types of changes (i.e., equipment, processes, personnel). The intent is to help organizations better identify and manage risks and prevent potential incidents.
3. Environmental Monitoring. Edition 10 requires a risk-based assessment to determine environmental monitoring needs. This will allow sites to develop monitoring strategies and programs based on their specific operational risks and environments.

In addition, Edition 10 includes the following updates:

• Documentation: Requirements for documentation are now contained in a single structured section to simplify compliance and improve auditor efficiency.
• Training: Edition 10 includes enhanced training and competency assessments so personnel at all levels understand and are prepared to maintain food safety standards.
• SQF pre-audit: The concept of pre-audits (i.e., internal audits) is reintroduced to help sites better prepare for certification.

Planning for Change

For companies that are SQF-certified, now is the ideal time to assess current SQF program elements, identify improvements that are internally desirable and required by the new standard, and implement those updates that will make the SQF program more useful to the business. This can be done through a series of phases to ensure adoption throughout the organization.

Phase 1: SQF Assessment

An assessment should begin by reviewing the following:

• Existing SQF programs, processes, and procedures.
• Existing document management systems.
• Employee training tools and programs.

This documentation review and program assessment will help to identify elements of the existing SQF program that are acceptable, those that show opportunities for improvement, and those that may be missing, including those needed for development and implementation to meet the requirements of SQF Edition 10.

Phase 2: SQF Program Updates

The assessment will inform a plan for updating the SQF certification program, including major activities, key milestones, and expected outcomes. Development/update activities included on the plan may include the following:

• Developing new or updating current SQF programs, processes, and procedures with missing Edition 10 requirements, including new procedures for change management and environmental monitoring.
• Updating training programs with any new and additional requirements, focusing on enhanced competency assessments.
• Revising document register to align with SQF Edition 10 changes.
• Updating records and forms with any new/additional requirements.
• Updating Food Safety Policy to include new food safety culture requirements.

When implementing program updates, leveraging existing management system and certification program elements and utilizing proven approaches can greatly streamline the process.

Phase 3: Training

To ensure staff are prepared to implement and sustain the updated SQF Edition 10 program, training is important. This includes training for affected staff on applicable requirements; specific plans, procedures, and Good Manufacturing Practices (GMPs) developed to achieve compliance; and the certification roadmap to prepare for future audits.

Following this plan now will help companies ensure they maintain their SQF certification when audits begin under SQF Edition 10 in April 2026 and demonstrate their ongoing commitment to meeting customer and regulatory requirements, protecting the company brand, and keeping consumers safe.

The Occupational Safety and Health Administration (OSHA) uses inspections to help ensure employers provide safe and healthy workplaces. In April 1999, OSHA implemented its first nationwide Site-Specific Targeting (SST) plan to conduct comprehensive programmed inspections in non-construction worksites with 20 or more employees. The SST inspection program has been renewed and updated since that time, and on May 20, 2025, OSHA issued the most recent directive for its SST inspection program. This new version is more narrowly focused, prioritizing programmed inspections at establishments with high or upward-trending injury and illness rates, as well as those that failed to submit required information.

Key Changes

The SST program uses injury and illness data that employers submit under 29 CFR 1904.41 through OSHA Form 300A. The new SST directive was updated to rely on data from calendar year (CY) 2023 versus CY 2021, reflecting OSHA’s continued efforts to allocate enforcement resources based on the most recent injury and illness data. OSHA then uses this data to target and identify facilities for a potential SST inspection, as follows:

• High-rate establishments: Facilities with elevated Days Away, Restricted, or Transferred (DART) rates for CY 2023. Importantly, OSHA will set one DART rate of manufacturing and a different DART rate for non-manufacturing to provide for equal targeting from both groups.
• Upward-trending establishments: Facilities with rates at or above twice the private sector national average in CY 2022 that have continued to trend upward annually from CY 2021-2023.
• Low-rate establishments: Those with low DART rates. Low-rate facilities will be randomly selected for inspection to verify the reliability of Form 300A data.
• Non-responders: Facilities that failed to submit CY 2023 Form 300A data, as required. A random sample of non-responders will be inspected to discourage employers from not reporting.

What’s Involved

Based on data collected and the above criteria, OSHA Area Offices (AOs) select facilities to target for planned SST inspections. The SST inspections are comprehensive in scope and may be expanded with justification (e.g., including health hazards based on prior inspection history in industry classification).

During the SST inspection, the Certified Safety and Health Official (CSHO) will do the following:

• Review data. The CSHO will review available OSHA 300 Logs, Form 300A summaries, and 301 Incident Reports for CY 2021, 2022, and 2023.
• Conduct a facility walkthrough. During the walkthrough, the CSHO will evaluate potential hazards in all areas of the workplace; however, the focus will largely be on those areas where the facility has had documented injuries and illnesses.
• Evaluate employee exposures. The CSHO will pay particular attention to hazards observed during the walkthrough, discussed in employee interviews, and/or identified on OSHA 300 Logs and 301 Incident Reports.
• Assess the safety and health management system. The SST inspection will focus on whether the management system is adequate to identify and address the elevated injury and illness rates.
• Conduct a closing conference. The CSHO will discuss with the employer identified hazards, gaps in reporting practices, and deficiencies in the safety and health management system during the closing conference.

What You Can Do

The updated SST inspection program update reflects OSHA’s ongoing commitment to data-driven enforcement and targeted inspections in general industry. Correspondingly, accurate data is critical. Facilities must have their OSHA recordkeeping and reporting practices in check. Not only should records be verified as accurate and complete, but each accident should have a documented corrective action. This information should be checked, and any additional actions should be made to fully comply with Occupational Safety and Health (OSH) Act requirements.

But beyond recordkeeping and reporting, facilities can take steps to avoid an SST inspection altogether by making sure they have the processes, programs, and systems in place—and documented—to protect employees’ safety and health:

• Develop comprehensive safety programs and a robust safety management system. A compliance management information system can provide a centralized location to track and manage all safety-related information (e.g., policies, procedures, and practices) to not only help ensure going compliance but to also provide the documentation required should an inspection occur.  
• Regularly assess the level of existing OSHA programs against compliance issues and potential accidents. Identify what may need to change in the facility’s OSHA compliance programs and practices to ensure their effectiveness and then implement and document appropriate corrective actions.
• Maintain robust occupational health and safety and incident. Information technology (IT) tools, such as KTL’s OSHA 300 Power App, with its comprehensive intake form tailored to OSHA 300 and OSHA 300A requirements, make it easier to collect, search, and analyze data—and maintain OSHA compliance. Using a digital forms further helps ensure no crucial data points are missed and makes it easy to filter, search, and analyze records and data to offer deeper insights into safety performance.
• Understand what to expect from an OSHA inspection. Educate staff on the process a CSHO will follow and make sure team members understand their roles in the inspection. Prepare staff to respond appropriately to the CSHO’s questions and, importantly, make sure they know how to locate requested documentation.
• Train employees. All employees should receive ongoing training to fully understand and follow safety processes and procedures. Training should focus on worker knowledge and understanding their responsibilities to comply with identified requirements.