Reviewing documents to support your HAZCHEM incident investigation

Apr 23, 2019 Posted by Walter Ingles

Workplace incidents that involve hazardous chemicals are often an indicator of chemical hazards that have never been fully identified, understood, and controlled. A follow up HAZCHEM incident investigation is an opportunity to understand the different factors which contributed to the incident, then recommend more effective chemical controls.

But an incident investigation is more than interviewing witnesses and examining damaged equipment, reviewing a range of documents is also a critical part of your enquiries. This blog looks at the different types of documents to review during an incident investigation and the ways they can support your efforts.

REMEMBER: Standard operating procedures and site rules are administrative controls that contribute to the overall safety of a job site. The absence of these documents (eg, operations manuals, maintenance schedules, safe work methods) can actually be a hazard in itself.

Why review workplace documents

An effective incident investigation establishes the facts through a number of channels, and workplace documents are an excellent way of checking the consistency of evidence and testimony. More specifically reviewing documents will very often:

  • Support evidence: Eg, a worker claims that a delivery driver was in the warehouse at the time of a chemical spill — the site visitor’s log confirms the driver was onsite at the time of the incident.
  • Raise questions from witness testimony: Eg, a worker explains the exact sequence they followed when decanting cleaning chemicals. But when you check the written operating procedure, it’s different to the way the worker decanted the chemicals.
  • Invalidate individual witness statements: Eg, a supervisor claims to have given clear instructions to three workers at the beginning of shift, but finger scan records indicate one of the workers was late and was not even on the job site at the time.
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Types of documents to review

There is a huge scope of documents that you could review during your HAZCHEM incident investigation, so we suggest the following as a minimum:

  1. Safety Data Sheets (SDSs)

    Safety Data Sheets are one of the first documents to review during a HAZCHEM investigation. The SDS for a chemical will indicate the hazard class and physical properties of substance as well as specific recommendations for appropriate PPE, storage conditions, segregation, and labelling. Your investigation would consider if any of the substances present during the incident were being used or stored against the recommendations of the SDS.

    IMPORTANT: If an SDS is out-of-date or missing from the Register of Hazardous Chemicals this could have also contributed to the HAZCHEM incident.

  2. Company policies and procedures

    Many dangerous incidents occur when workers don’t follow operating procedures, site rules, or safe work methods. Your investigation will need to establish what procedures were actually in place and if they were suited to the task being carried out. A review of the operations manual might indicate work procedures that were developed for a specific type of cleaning chemical and were merely duplicated as new chemicals were introduced to the job site.

  3. Training and HR records

    Operating procedures and site rules are basically useless if workers haven’t received proper training and instructions. You should check the training attendance records for the names of workers involved in the incident. Perhaps some of them were never trained. You might also consider reviewing HR records (eg, job descriptions) for instances of workers acting outside their area of responsibility.

  4. Machinery and equipment manuals

    Checking operations manuals of the machinery and equipment in use at the time of an incident will help you determine if a machine was being operated within the manufacturer’s guidelines. At the same time check maintenance reports to ensure that follow up inspections and repairs were being carried out. For example: if an eyewash unit malfunctioned during a chemical emergency, maintenance records might indicate the unit had been activated and tested only 2 days before the incident. Perhaps there was another problem.

  5. Maintenance and cleaning logs

    Maintenance and cleaning logs can indicate worn or damaged chemical stores flagged for replacement, machines with a history of regular breakdowns, and past instances of chemical spills. Do the logbooks look like they have been completed properly, or does it look like a quick ‘tick and flick’?

  6. Incident reports and safety records

    Reviewing the records kept from previous incidents, or the minutes from safety meetings can indicate common elements. Look for things like:

    • The same staff member — eg, an individual worker who spills acid three times in the past month may not have received enough training.
    • A group of workers — eg, 5 small chemical fires in the lab in the last 2 months could indicate a lack of proper supervision.
    • An item of equipment  — eg, 3 chemical spills from the same drum dolly might indicate a faulty unit or a work procedure that needs reviewing.
  7. Other documents to consider

    • Audit and inspection reports prepared by independent safety consultants and Dangerous Goods specialists. (Had chemical hazards been previously identified and not addressed?)
    • Rosters and timesheets (What was the ratio of supervisors to workers?)
    • Sick/Annual leave records (Had any workers involved in the incidents just returned from an extended absence?)
    • Risk Assessment Reports and Audits (What risk assessments had been carried out on the chemicals involved in the incident?)
    • Australian Safety Standards, WHS Regulations and other legislation (Were there any compliance breaches at the time of the incident?)

REMEMBER: There are literally hundreds of documents you could review, and this could easily bog down your incident investigation for months if you aren’t strategic about the documents you choose.

Walter Ingles

Walter Ingles Compliance Specialist

Walter is STOREMASTA’s Dangerous Goods Adviser. He loves helping businesses reduce the risk that Dangerous Goods pose upon their employees, property and the environment through safe and compliant dangerous goods storage solutions.

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