WorksafeBC Mind Map for Incorrect labelling for IBC Incident 15/02/2019…
WorksafeBC Mind Map for Incorrect labelling for IBC Incident 15/02/2019
Complacency in relation to LTA labelling of IBCs whether for the IBC in question or general management of IBCs.
Competency / Experience) in relation to new personnel on the job (training plan), limited exposure for higher roles around chemical management and the like.
Wrong doing/Work method) in relation to placing a rag in the hole at top of the IBC due to a missing cap, as cap was missing and lack of compliance to waste management process
Systems Organisational Management
Risk and Change Management in relation to LTA SWMS and compliance to the FH Haz Chem and DG Procedure. Workers not knowing the process. The change of the process and knock on effects for storage of IBCs.
In relation to training in the process (no process), systems (procedures not followed) and task (personnel not trained in role) for varying personnel.
Materials Handling) in relation to non-compliance with the FH Haz Chem and DG Procedure and Procedure being unknown.
Procedural Compliance) in relation to not following the FH Haz Chem and DG Procedure for waste disposal and labelling nor the SWMS.
Change Management in relation to changing from storing the IBCs in the open space to the storage shed, which impacted the waste disposal process.
Work Procedure in relation to the FH Haz Chem and DG Procedure not being known
Monitoring, Audit and Review in relation to external/internal audits have not captured/identified prior inconsistent issues
Training in relation to chemical handling and storage and disposal training in company with other induction processes
Communication) in relation to LTA frontloading of on-boarding, inductions, training in systems, processes and tasks in roles
Control Systems in relation to LTA compliance with the FH Haz Chemicals and DG procedure.
Control Systems in relation to nil ‘formalised/documented’ processes for waste disposal (the task is learnt on the job).
Hazard identification (risk assessment) in relation to LTA SWMS to cover all facets of the waste disposal operation
Hazard identification (inspections/comms) in relation to a LTA inspection to identify segregation/contamination etc. and whether the correct personnel are conducting the inspections.
Hazard Identification (Induction) in relation to a LTA induction for the on-boarding to the lab and for the plant.
Hazard identification (training/competency) in relation to personnel having the relevant qualifications to manage the lab and waste disposal process (also haz subs training).
Hazard Recognition) in relation to personnel initially not being aware with the hazards of labelling incorrectly.
Risk Management in relation to a high consequence activity not identifying/managing the process (training, risk management, change management, non-compliance with SWMS/Procedure, inspections and audits not identifying the issue).
Hazard Analysis in relation to LTA SWMS and compliance with the Procedure.
Operations and Maintenance in relation to a LTA inspection regime (that doesn’t capture criteria) or not understood or unknown
In relation to proper ownership of the waste disposal process.
Planning in relation to understanding of the process for management of chemicals and then planning of the work space and dealing with a changing work environment.
Planning in relation to poor planning of the task for chemical handling and storage
Detection systems (signage) in relation to LTA signage for waste disposal on vessels.
Housekeeping in relation to initial poor practices that led to overall findings of non-compliance (segregation etc.).
Guards and Barriers (Guards) in relation to the lid was missing an inner component (2in lid missing) and the hole was bunged with a rag.