How to do an environmental hazard analysis

As environmental professionals, there is much we can learn from our colleagues on the health and safety side.

An essential part of an effective health and safety program is job hazard analysis. The purpose here is to identify safety issues that may be present during the performance of a specific task. The hazardous analysis takes the form of a series of five questions:

  • What can go wrong?
  • What are the consequences?
  • How could it happen?
  • What are other contributing factors?
  • How likely is it to happen?

For example, if you were to perform a job hazard analysis at a job where an operator is working with a stationary rotating blade, you would ask the question “What can go wrong?”. The operator’s sleeve could get caught by the rotating blade. What are the consequences? His arm or wrist could be amputated. How could it happen? There are no machine guard to prevent such accident. What are other contributing factors? The operator may be fatigued due to long working hours. He may be careless and not paying attention to the blade. Or he may be distracted by talking to his fellow employees while working. How likely is it to happen? Without machine guards or other forms of engineering control, such accident is likely to happen sooner rather than later.

You can apply the same job hazard analysis approach to your environmental program. Let’s call it environmental hazard analysis. Here are a couple of examples:

Example 1: You walk through the plant and you notice some severe signs of corrosion at the base of one of your aboveground storage tanks where you store some pretty hazardous chemicals.  You ask the five questions:

What can go wrong? The structural integrity of the tank can fail.
What are the consequences? The tank could rupture and cause a massive spill of hazardous chemicals.
How could it happen? The tank could fail if no action is taken to address the corrosion of the tank.
What are other contributing factors? Strong wind, minor earthquake or any external forces on the tank could contribute to its structural failure.
How likely is it to happen? It is likely to happen if nothing is done.

Example 2: You are reviewing your plant’s Spill Prevention Control and Countermeasures (SPCC) plan and notice that there is no record of any inspection being carried out even though the plan calls for weekly inspections. You ask the five questions:

What can go wrong? The SPCC plan is not being implemented as planned.
What are the consequences? Spills could have occurred without anyone noticing it. An EPA inspector may issue a citation against your plant for failure to implement it.
How could it happen? The inspection team was not made aware of the weekly inspection requirement.
What are other contributing factors? The people responsible for implementing the plan were not involved in its development. There is a lack of ownership. There is a failure of communication.
How likely is it to happen? The failure to implement the plan is likely to happen if employees are not properly trained and involved in the plan.

Example 3: You notice that there are drums of hazardous waste in your central storage area that do not have the proper labels on them. The ones with labels do not have accumulation start dates. You ask the five questions.

What can go wrong? You can exceed your maximum storage time limit without knowing about it.
What are the consequences? You could be fined for operating a hazardous waste facility without a permit if an inspector finds out.
How could it happen? The operator had not been told about the labeling requirements.
What are other contributing factors? There is no one individual responsible for making sure the label is on the container and it is properly filled out. The weekly inspection has not been carried out or it has not been done properly.
How likely is it to happen? It is very likely to happen.

This simple environmental hazard analysis can help you identify small problem before it festers into a much larger and more costly one. Once you have determined that the problem is likely to happen, you need to take immediate steps to stop it. It is like doing an internal audit. There is no point in doing an audit unless you have the commitment and resources to fix the problems you uncover.

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