Being implementing EMS for the organization, could anyone help raise example of Preventive Action for EMS system?

We developed and implemented a soap and water cleaning system to replace our solvent method. I guess it could be continuous improvement but we really didn't need to improve the old system. We did it to prevent issues down the road. Ergonomics is a good place for prevention too. When reviewing systems internally, changes made to prevent injuries or environmental accidents are often generated. Development of an informational newsletter shared with employees and the community could be prevention too. Problem with prevention is you can never illustrate success because to be a prevention it can't have ever been a problem (if it was, it would be a corrective action - not a prevention). How then do you know if the prevention worked or if it was never going to happen anyway? Best thing to do is look at all your continuous improvement projects and allocate some of them to prevention. Also if you use information from a corrective action and apply it to a situation which had no problem before, that could be a prevention.

Preventive action can and is any number of things...

Have a good equipment inspection and maintenance program.

Have a good awareness and response program for potential chemical spills or releases (here in the states we call it HAZWOPER (Hazardous Waste Operations & Emergency Response), and you can find it at www.osha.gov. (http://www.osha.gov.)

Initiate a recycling program, an energy control program, a hazardous materials management program, the list can go on from here.

The main thing to do is educate the workforce and MANAGEMENT of whatever programs you put into place.

Aside from the above you can get into engineering issues like the control of storm water runoff, your drain/sewage system, managing stack emissions, scrap management/minimization, electrical power distribution, waste water management, and other things along these lines.

What you can do is boundless. be sure to document and show improvment.

If anything else comes to mind I'll let you know.

QSMSO,

I believe my mind wasn't engaged when I gave the answer above to your question.

Looking back I think you might be refering to clause 4.5.2.

The 1st thing you need to do for Preventive Action of non-conformancies is inform every employee of their responsibilities to identify and perform corrective actions. This includes the reporting of suspected non-conformancies of operations and precedures.

Next you need to perform analysis of whatever environmental indicators you have in place to determine the possibility of a non-conformance to whatever you have specified. Remember "Preventive Action" is based upon the analysis of data.

Make sure your documentation reflects changes in procedures that are Preventive in nature and that employees have been made aware of procedural changes.

I hope I am slightly more on track here.

Dear all,

Thank you very much for your ideas. Now, we are implementing the activity called “Corrective Action Impact”

The concept is to issue information about NC of some area from both internal audit result and external information (other branches oversea). At first we issued Preventive Action Request to each area that may have potential of those problem, but very difficult for them to think about how to prevent things that actually not happen. So, we change just to keep informing them about NC in other area, which we hope that they might consider and try to implement some prevention activity.

Anyway, all of your comment, we will take to discuss within the team.

Best regards,

QSMSO

I believe 4.5.2 deals solely with system nonconformances. For instance if you didn't do EMS audits as precribed in the standard, how do you prevent that from happening again?

To extend preventive action to operations activities may be a good thing to do, but I would suggest separating system nonconformances from operating problems (note different wording). I'm not suggesting that operating problems shouldn't be prevented, but trying to do that without considering the system root is confusing and ultimately futile.

Internal auditing, hazard spotting and risk analysis are the best ways of generating preventive actions. Score the issues with a risk analysis/FMEA approach, pareto them, improve them, then do it again. Have a documented plan to go through this exercise every 4-6 months and show that the improvements have reduce the risk scores.

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Alan Greatbatch

HAZWOPER

This is beginning to sound like a sci-fi movie...

Marc,

HAZWOPER - Hazardous Waste Operations & Emergency Response .. 29CFR 1910.120.

A highly mis-understood and mis-interpreted document

Yup - I'm reading through a mound of stuff I have printed out and am getting the feel for it. I saw that WOPER on the end and just started laughing out loud...

What do you feel is 'misunderstood' with respect to it?

Originally posted by Marc
Yup - I'm reading through a mound of stuff I have printed out and am getting the feel for it. I saw that WOPER on the end and just started laughing out loud...

What do you feel is 'misunderstood' with respect to it?

If you are laughing just reading it, imagine what it is like to be the lone female HAZWOPER in a group of 36 big burley production and maintenance guys:eek: Our last refresher included SCBA and full hazard suit Olympics, we divided into teams of 4, each team had to run a relay with 3 members getting suited up, including the oxygen tank, then go from one end of the building to the other, switch suit and tank etc.

I was the "incident commander" for our team, so I did not have to suit up, but I am still taking flak from the guys for holding the record for "undressing the most guys in the shortest time".

Sometimes, you just can't win.:bigwave:

The amount of training required.

Most situations where there there is a spill or somthing like that are covered by general OSHA type training.The only extended training (24 & 40 hour) is for specific situations. Most folks go into a serious overkill mode on non-essential training courses and waste resources that could be utilized elsewhere.

Trust me, I've been there and done that.

It's the same for maintaining MSDS's that are required under the Hazard Communication Standard 29CFR 1910.1200. A whole lot of overkill by a whole bunch of folks.

It takes careful reading of the regulations and bouncing them off of the interpretation documents to get a good handle on what is truly required.

Originally posted by SteelMaiden

If you are laughing just reading it, imagine what it is like to be the lone female HAZWOPER in a group of 36 big burley production and maintenance guys...Don't start me or I'll jump in line with the 'guys'... :thedeal: