Business Management, Environmental, In The News

ITC Facing Criminal Charges for Chemical Plant Fire

In March, we aired an episode with our first guest, Mo Aziz, discussing the ITC “Intercontinental Terminals Company” Chemical Plant fire. The fire burned for days and reignited after it was extinguished. Most of Houston wondered what, if anything, would be the penalty for ITC. Based on history, these plants aren’t often penalized effectively enough to encourage them to up their game when it comes to safety and prevention. When a problem repeats itself, it’s time to start looking at better processes.

ITC has numerous encounters with Texas Commission on Environmental Quality (TCEQ). This particular plant fire was really unable to sneak on by Houston as you could see the plume for miles and miles outside of and around Houston. Allergy and asthma flare ups were experienced by many. There were shelters in place for Deer Park, rendering many unable to go to work. Then, there was a breach of a containment wall. Large amounts of toxic chemicals discharged into Tucker Bayou. Air and water quality were a major concern.

It has now been announced that ITC will be charged by Harris County’s District Attorney’s office with 5 misdemeanor counts of water pollution. When I first read this, I was shocked. I thought to myself, “Misdemeanor only?” As I continued to read, I realized what a big deal this was. Previously and often, plants are charged civilly only or incur minor fines from TCEQ. In this case, the DA is charging ITC with criminal charges. Wow!

A spokesperson from the DA’s office has also stated that “This the beginning of our review, not the end,” indicating there are likely more Criminal Charges coming. The current charges are for the 5 days the law was violated and carry a fine up to $100,000 per day.

I looked into whether or not TCEQ has fined ITC and what those fines were if it had. From what I’ve read, TCEQ can attempt to enforce action against a company, but it seemingly goes ignored. When the companies refuse to pay, TCEQ turns it over to the state attorney general’s office. In this most recent case with ITC, the Texas Attorney General filed suit against ITC before the fire was even put out stating that ITC “…has a history of environmental violations.”

I will say there are many arguments by different groups and parties as to why the AG filed (not good reasons according to them) and favor the DA’s Criminal Charges. Many are wondering if the AG will supersede the DA. I’m not going to delve into all of that. I’ve attached links to the articles for you to read if you are so inclined.

For our purpose, quality matters. ITC didn’t have proper processes in place, neither to prevent nor quickly remedy the situation. Whether the AG, DA, or TCEQ wins, I just hope that it’s enough for the chemical plants to take notice and enforce a better quality program to protect its civilian neighbors.

Harris County DA hits ITC with five environmental charges

So many forms and process… what to do?

NCR, RNC, CAR, CAPA, MOC, CI, ECN, Risk….

It gets confusing…

They all have a place and purpose and, sometimes they overlap. How frustrating is that??? Is it a Corrective Action Report, a Management of Change, or an Engineering Change…. maybe I need to complete a Document Change Request…? Do you really need to issue an NCR for each CAR? How bout an ECN for a MOC?

The key, folks is to identify a SCOPE for each tool(NCR, CAR, DCR, MOC, etc…). Once you have a scope, identify methods for accounting for root cause*. If you can handle both of these, you’re well on your way to a compliant system, regardless the standard. Knowing who requires a root cause is crucial. ISO 9001 8.7 Control of Nonconformities, controls just that “nonconformity(s)”. A nonconformity does not necessarily require addressing the root cause. If we jump ahead in the standard to clause 10.2 Nonconformity and corrective action, sort of a continuation on 8.7. 10.2.1, we see that it states:

10.2.1 When a nonconformity occurs, including any arising from complaints, the organization shall:
a) react to the nonconformity and, as applicable:
1) take action to control and correct it;
2) deal with the consequences;

However letter b) gives us more definition of EXACTLY what makes this a Corrective Action (RCA required).

b) evaluate the need for action to eliminate the cause(s) of the nonconformity, in order that it does not
recur or occur elsewhere, by:
1) reviewing and analysing the nonconformity;
2) determining the causes of the nonconformity;
3) determining if similar nonconformities exist, or could potentially occur;

and then letters c) – f) detail more documentation requirements for a Corrective Action…. such as the ensuring the fix was effective and making required changes to the QMS.

Root Cause Analysis anyone???? This is more important than you might think!

Essentially we wind up diving into the world of Quality Forms and those that require Root Cause Analysis vs. those that don’t. Clause 10.2 of course has requirements for “Documented Information” in 10.2.2. We need to determine what requires Root Cause Analysis. That’s the million dollar question. The standard gives us some good clues and advice here. Soooo…. if Root Cause Analysis is required and clause 10.2 is invoked for lack of a better word, we MUST:

Document the nature of the nonconformity(s) and any actions taken… Nonconformity(s)is plural. So, Trend Analysis is immediately a key for conducting Root Cause Analysis.
Make changes to the quality management system… this makes total sense, no one should change procedures or specifications for fun, we do it because a problem (actual or potential) was identified, and to mitigate that RISK (oh yea, CAR’s are your best friend for Risk Based Thinking folks) we make a change to some part of the Quality Management System. So, issue a Corrective Action Report and account for the nonconformity, the risk, and the root cause.
Implement any action needed… Standard production line defects “nonconformity(s)” don’t require any implementation. Implementation is required for a complex solution. Now if we have a complex solution, we must also have a nonconformity that poses a RISK to the QMS or business in some way. We don’t implement anything complex without knowing the ROOT CAUSE, otherwise it’s almost blindly throwing at the dart board.

Let’s break it all down in more detail here.

Most companies have multiple processes to address various issues including Nonconformity, Corrective Action (internal and external), Management of Change, and even OHS/EHS Corrective Actions. These may have multiple inputs from customer complaints, production identified nonconformity(s), QC Labs and QC checks, shipping, continual improvement initiatives, Internal Audit, Management Review, etc… ITS A BIG LIST. Keeping these straight can be tough.

As a general rule, the purpose and scope of these processes must be defined in such as way it is clearly understood if and when a person might be required to file Multiple Actions/Forms. In addition, where capable, the process should not overlap. Such an example is a Corrective Action. By definition, the Corrective Action fully encapsulates the requirements of tracking nonconformity(s) and therefore it is unnecessary to create both a nonconformity report and a corrective action report. Of course, if your procedure calls for it, don’t break procedure on my account. I would suggest a Corrective Action Report to change the procedure.

Change Management

When a change management process is introduced, it’s important to identify the purpose and scope. For example, is this internal Continual Improvement (preventative action) based on the assessment of risk? Or is this change management in regard to a product design during or even after the completion of a design and development process? The difficulty comes when there is a nonconformity and NOT a risk that the change management action is issued. A change management action always results in a change to the QMS, such as a revision to a work instruction, or change in suppliers for a product, etc… when a management of change action is issued in response to a nonconformity the action meets the requirements for corrective actions. The key difference between Management of Change and Corrective Action is that a CAR has a requirement to identify a root cause and mitigate that cause and further evaluate the effectiveness of the preventative measure.

Risks and Opportunities

Risks and Opportunities is another fun area to address.

First, we need to set the record straight. Risk and Opportunities are like heads and tails of a coin. Any, ANY opportunity worth pursuing has a risk of failure or trouble in some way. Let’s look at a common example. If my wife and I get a babysitter for the night. AWESOME opportunity? YES! However, driving on the road presents a risk, a 16 year old watching our three kids, there is a risk. You get the idea.

I conduct 2^ndand 3^rd party audits as a part of my function with Texas Quality Assurance and as a contractor for 3^rd Party Registrars of course. I’m the youngest auditor I’ve met, and all the more senior folks like the “Risk Register”. Some folks can make a good use (beyond compliance requirements) of such a register. Personally, I’m not a fan (since risk and opportunity are of course heads and tails of the same coin). I like the idea of a couple tools or so. For one, each time you implement a new process or an annual review, create or update a FMEA. Make sure you’ve got good controls for those top level issues, and check to make sure the ones from last year worked. Second thing, INSIDE you CAR or CAPA or MOC (with Root Cause accounted for) include the (S)Severity, (O)Occurrence, and (D)Detection for each CAR BEFORE and AFTER corrective action. If needed to review on a large, how easy would it be to create a FMEA for each class of grouping of CAR. Last thing, and this topic deserves its own blog post. Risks and Opportunities are darned near the same thing, let’s just say it, they are the same thing. You can track opportunities separately. But wasn’t EVERY single CAR a preventive Opportunity if you’d caught it ahead of time? What about that new client you’re going after, building up infrastructure for? Great opportunity, until they don’t provide the PO’s. Then, you took a huge risk.

If thought out and measured against existing people, process, and business requirements, simple additions or changes to either the corrective action or management of change process can resolve these potential conflicts and mitigate the risk of not identifying and treating the root cause of nonconformity(s).

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Certification, Environmental, Health & Safety, ISO Audit, Leadership, Quality Management, Training

[…] doesn’t kill people | Culture Kills People

It doesn’t matter what you fill in as the blank in that statement, culture kills people. I’ve known this for years, having spent nearly a decade in Health & Safety, but got to see it first hand in a recent audit. That does NOT for one second discount people’s individual choices and decisions. Still, a good culture around safety, quality, security, etc.. they all impact the performance for the best and worst performers in your organization.

You’ll find at the bottom of this post, some of the requirements from the standard for reference, in case you need to make some findings of your own.

First thing, lets recognize people do “dumb stuff”, its hard to avoid. Lets consider it a RISK to be mitigated. I myself stood on a chair last week to change the light in my office. We MUST recognize that culture is vital to the success of any Quality or Health and Safety Management System. The number of rules enforced *and followed, does not directly correspond to the safety of the folks working there. Culture is key.

Let’s take a couple of common findings in any safety audit, or any quality audit where safety problems are clearly visible. No I’m not talking about Forklift Inspection Checklists. Yes, auditors go straight for them cause they are clearly required and it’s clear if they are missing. The majority of deaths from forklifts are not caused by a missed oil change, and leaky hydraulic fluid is generally found apart from the daily inspection. We all know by common sense that the number one way folks are killed or injured by a forklift is by getting crushed by a falling load. Check it out here . Most folks that are killed or injured by a forklift, I’m sure, knew the rules. The people, and the management, turned a blind eye to small infractions, at best. At worst, management encouraged the behavior “to save time”. That sends a massively clear message that convenience, and arbitrary time savings is more important than your safety. It’s not the message you want to send. I’ll bet everyone knows the punishment for showing up late, but how many know the punishment for riding on a forklift?

Crane Accidents Causes

Another common source of OSHA violations and injuries in most industrial locations is cranes. An industry crane can be a dangerous piece of equipment. Each and every year there are injuries and deaths due to crane accidents. According to the U.S Bureau of Labor Statistics, from 1992 to 2006, there were 632 death caused by crane accident in the construction area alone.

Causes of Crane-Related Deaths in Construction, 1992- 2006

In a recent audit, I observed two workers working underneath an elevated load weighing approximately 3500 lbs. The workers were cleaning and taking dimensions. When questioned, it was determined that this is standard practice. When speaking with management I found out that in the past the company had used some rather large jack stands (these could come with their own hazards but would be infinitely better than relying on rigging alone to keep yourself safe). One employee quickly spoke of this being why he has life insurance. I get the jest, but when speaking with the shop foreman the topic was avoided, and again seemed to be a daily practice. I would expect top leadership to jump in and take action, but no immediate action was taken. Again, a clear message was sent to the employees that convenience and arbitrary deadlines are more important than being 10 minutes late.

Now I’m going to be a realist, I know there is close to a one in a million chance something bad will happen here, but the 632 deaths between 1992 and 2006 where workers died from being struck by a crane load felt the same way. Let’s not forget, most businesses in America are small businesses, and a small business, unlike large O&G corporations, cannot absorb the loss and continue business. I know that sounds crude, but if you have enough people working for you there are “statistically acceptable” numbers for these sorts of things.

I’ve personally conducted over 60 accident investigations in my career. At the time of investigation, I’m always presented with some form of the idea that it was the employee’s fault. He should have just checked the rigging, he shouldn’t have used that grinder, he always, he should have… These are all true. But, each of these 60 cases had 1 or more witnesses. No one stepped in to stop the guy once on any of the investigations I’ve conducted. Yes, the worker did something unsafe for bad cause, but he worked in a culture that allowed unsafe acts and, at times, promoted it. He worked in a culture where the deadline was more important than slowing down to do the right thing, even if it meant taking a fine from a customer. A $100,000 fine for being a day late on the project is nothing compared to the loss of a life, and the subsequent loss of the 100+ jobs of the men and women working there.

Look, “unsafe acts”, “dumb stuff”, “wasn’t thinking”, “going too fast”-these are not the reasons for most injuries and in industrial facilities. Culture, a culture where men are more afraid of being 10 minutes late to a 4 AM shift than they are standing under a 3500 lbs load, and justify it by saying they have life insurance.

If and when you run across these situations in your career, here are some easily cit-able references from the standards.

ISO 9001:2015

5.1 Leadership and commitment
5.1.1 General

d) promoting the use of the process approach and risk-based thinking;
e) ensuring that the resources needed for the quality management system are available;
i) promoting improvement;

ISO 45001

5 Leadership and worker participation
5.1 Leadership and commitment

a) taking overall responsibility and accountability for the protection of workers’ work-related health and safety;
c) ensuring the integration of the OH&S management system processes and requirements into the organization’s business processes;
d) ensuring that the resources needed for to establish, implement, maintain and improve the OH&S management system are available;
f) communicating the importance of effective OH&S management and of conforming 576 to the OH&S management system requirements;

5.4 Participation and consultation

d) give additional emphasis to the participation of non-managerial workers in the following:
1) determining the mechanisms for their participation and consultation;
2) hazard identification and assessment of risk (see 6.1, 6.1.1, and 6.1.2);
3) actions to control hazards and risks (see 6.1.4);
4) identification of needs of competence, training and evaluation of training (see 7.2);
5) determining the information that needs to be communicated and how this should be done (see

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Certification, Environmental, Health & Safety, ISO Audit, Leadership, QMS Software, Quality Management, Training

What is Quality Management? | How do I “get” ISO 9001?

I’m Kyle Chambers. I’m the founder and owner operator of Texas Quality Assurance. I get asked by friends and family frequently about what I do.. I tell them Quality Management (Auditing, Consulting and Software Development) most commonly dealing with ISO 9001 ( I end it there, 18001, 14001, API, that will just muddy the conversational waters far too much ). When I answer, it’s deer in the headlights a lot of the time. I also run into a similar situation with prospective clients and top management of companies I work with from time to time. Folks just don’t have a firm grasp on the what the process of getting and using ISO 9001 or any management system is.

Lets stat by answering some basic questions.

What is Quality Management?
How do I “get” ISO 9001?

What is Quality?

In this Quality Manager’s experience, here we go. First, we need to define what “Quality” is. There are many definitions, Dr. Google defines Quality as “the standard of something as measured against other things of a similar kind; the degree of excellence of something.” Maybe that’s correct, but it’s hard to understand. And if it’s quality, it should be easy to understand and clear to see. Texas Quality Assurance defines Quality as “saying what you’re going to do, doing it, and doing it repeatedly”. Of course, lots of pieces of the puzzle make this definition of Quality a reality. There are four principles that build up “Quality”. Quality is all about integrity and hard work, after all isn’t integrity doing what is right when no one is looking? Isn’t hard work sticking to the task even when it’s not easy? And don’t you need to be proactive to maintain quality? You need to anticipate problems and devise solutions. Then, if you’re really a Quality company, you’re going to deliver better than your customer expected, that is “High Quality”-when a spirit of generosity is applied to your work.

So let’s summarize, Quality is the essence of doing what you said you’d do, over and over again. This, for us, is based on four principles.

Integrity – Proverbs 28:6
Pro-activity – I Peter 1:13
Generosity – Proverbs 13:4
Hard Work– Proverbs 11:24-25

What is Quality Management?

Now let’s talk about Quality Management. It’s the act of applying our simplistic definition of quality and living the principles and infusing them in our organization. We need a structure, we need a framework to work within. It’s true, we could, on our own, from our intelligence, work history, and experience develop a framework to maintain our Quality Management System. It is also true that this hard work has been done by others in a form that is Internationally Accepted. We find this in the form of standards such as ISO 9001 (most common Quality Management Standard World Wide) or ISO 14001 (Environmental Management) or a variety of API Standards (American Petroleum Institute), etc… For now, we will discuss ISO 9001.

First, let’s recognize ISO 9001 comes with its own set of Quality Management Principles. You can read more about that here, Seven Quality Management Principles (ISO 9001:2015) . They are:

Custom Focus
Leadership
Engagement of People
Process Approach
Improvement
Evidence Based Decision Making
Relationship Management

And these are the guiding lights of the standard. The principles translate well to MOST ANY Quality Standard as they vary from industry to industry.

ISO 9001 Framework

ISO 9001 is all about providing a base framework to ensure Quality. So how is that done you ask? Well, it’s really quite simple and it starts with Documented Information. If you’re part of a company, unless you’re government subsidized, you Do Something or Make Something valuable to other people. Either EVERYTHING is done verbally, which is not efficient and not a good way to ensure quality, or you write something down. Usually you write procedures to tell the next guy you hire how to do the work, or to remind you two years later when you forgot all the great things you came up with in today’s team meeting. Along the way, you’re going to need to check to make sure the parts dimensions are correct, or a checklist to make sure you did everything you set out to do. There is an old saying that I love, and it goes “Nothing good ever happened before pen was put to paper.” So, if you check dimensions or do a checklist, WRITE IT DOWN AND SAVE IT SOMEWHERE. Your “Control of Documented Information Procedure” will tell you where that “somewhere” is. It will tell you who is allowed to put it there, and who is allowed to edit it, and maybe how long you need to keep it. For example, medical records must be kept for 40 YEARS past the last date of employment. So let’s say Jim worked for you for 40 years and had an accident his first week on the job, looks like you have to keep records for 80 years. Good thing you have a well-documented system for keep tracking of procedures and records. Beyond that, say you build a widget, maybe you make the best stapler in the world that always goes through all the pages and can staple 2 or 100 pages together effortlessly. I’ve got news for you, you didn’t design an awesome stapler, you created intellectual property such as material specs, technical drawings, contracts with suppliers, inspection forms that are used during manufacture, and so on. You created a whole heap of intellectual property. If you don’t store it, protect it, and properly track changes and revisions, your business is going to be in serious trouble in a few years. Documentation is where it starts.

“Shameless promotional plug” Texas Quality Assurance has developed software tools that manage ALL you’re documented information, and automates the process. Check out TQA Cloud|QMS simplified .

Leadership

Once your documentation systems are somewhat in place, (they will evolve as your program does) it’s time to get to the work. First, let’s hit on leadership. I’m going to be honest, not all leadership “gets it.” They just know their biggest customer is pushing for ISO 9001, or some other standard, and they are ordering you to “get ISO 9001” as though it were a product to purchase at a supplier. If this is your management team, you have my condolences. All hope is not lost, though. This places you in a WONDERFUL position to develop those dormant leadership skills and inspire your team to action as you show value for each process and each improvement. Show them the light at the end of the tunnel, that fewer reworks, more efficiency, less headache and a more enjoyable job are at the end of the ISO Rainbow. Now that “Leadership” is established, it’s time to get to work on developing a “Quality Policy” – effectively a mission statement for your Quality Management System, but this one has key objectives attached to it, so you can measure how good of a job you did next year.

Whether your leadership is leading the charge or you are, leadership is now involved, and we’ve got to make a plan. Fail to Plan – Plan to Fail, that’s how the old axiom goes, and it is gospel truth. The biggest threat to the Quality of your products and/or services is Risk. This just goes without saying. So from the get-go, make a plan to identify risk, and document how you addressed it. We’ve presented just a few ideas in this article for you to read. Risk Based Thinking – How to solve the problem during transition. Next, you need a plan for changes. What happens when someone needs to update the drawing on that awesome stapler? Who gets notified? Who approves the changes? You need to identify these sorts of things. Last, let’s make a plan to achieve the Quality Objectives. This is your own personal scorecard to measure how great the system is.

Suppliers

Every company has at least one supplier. I heard a story about a company that makes the concrete pads that are used for Verizon cell phone towers out in the middle of nowhere. The company had only 2 employees, and only two suppliers (chicken wire and concrete). Who would’ve thought that the concrete hey used was some special grade that was specifically selected and mixed for this purpose? Even in this most simplistic example, there was a rudimentary supplier approval process. You need to identify your suppliers, and grade them on impact to the quality of your organization, IE commodity (Office Depot, CDW) direct material, or Quality Critical. Then, simply create a plan to get these different suppliers approved, monitor them, and re-valuate them on a schedule that makes sense for your organization. Some companies opt to hire auditors to go check out critical suppliers on an annual basis. But, for crying out loud, don’t make Office Depot go through a supplier approval process unless you’re an arts and crafts company and buy all your paper from Office Depot.

Competence and Training

You’re steadily marching forward, and now it’s time to talk about making sure folks are trained “Competence, Training & Awareness”. By now, you’ve got some process procedures, and best practices identified. Let’s make a matrix of skills folks have to have. Let’s make sure EVERYONE has a job description. Regularly review and make sure folks meet the requirements for their job. There are few things that are worse for Quality AND Moral than an employee who doesn’t know how to do their job and doesn’t feel supported. Nip that in the bud.

Production

With any Quality Management System, including ISO 9001, you’ve got to make sure folks do the work. Production schedules are an amazing way to do this. Get key folks together, get input, and get a plan together to meet deadlines and due dates. Expect things to go wrong during this process becasue they will. That’s OK! You planned for Risk and can handle that! Simple tools such as a “Nonconformance Report (NCR)” will track every little defect and detail of what went wrong. After weeks or months, you can see trends in the data. This might clue you in that these 10 defects might actually be related. Here is where we issue a “Corrective Action Report (CAR)”. The CAR is often quite similar to an NCR, but the goal is vastly different. The goal with a CAR is to find the ROOT CAUSE and eliminate or at least mitigate it.

Monitoring and Measuring

All that’s left now is to monitor your processes-do inspections on your parts, checklists on services. Go ahead and find out what your customers think along the way, after all aren’t they the judge of your Quality? Once your organization is ready, it’s time for an Internal Audit. An Internal Audit can be conducted 100% by your folks, 100% by an outside company such as Texas Quality Assurance, or some mix of the both. The goal is to inspect every process, every department, and judge it against your procedures and the standard, IE ISO 9001. The length of the audit can vary from a 2-day audit to a 10-day audit, depending on how many employees you have. Once everything is said and done, it’s time to gather all the metrics collected during the year, including the results of measuring against the Quality Objectives and results from the Internal Audi and then put together a Management Review. This document has some very specific requirements outlined in the standard, but provided you include these requirements and assemble all the great data your collected it should be a great snapshot of the health of your Quality Management System.

Internal Audit & Management Review

If this is your first round of Internal Audit and Management Review, then you’re likely looking forward to going for certification from a 3^rd party company known as a Registrar. There are many companies qualified to conduct 3^rd party audits. Be wary, not all are created equal. Check out their credentials, sniff it out, check out the company that registered them. If you need some official recommendations, I can recommend NSF, Dekra, and of course the big boys Lloyd’s Register and Bureau Veritas. Its normal to be audited twice. Once for a Stage 1 audit often called a “Readiness Review” and a Stage 2 “Certification” audit. Stage 1 is generally 1-2 days and Stage 2 generally 2-5 days. You can expect at least a month in between audits.

YOU’RE CERTIFIED

Now you’re certified, you got ISO 9001. This is where continual improvement really comes into play. Innovate or die, this is true for getting new products to market, and its true for your Quality Management System. There will always be ways to improve, to streamline, and to get better employee engagement. Take every opportunity, get out there and do the work.

We value your time and energy, and hope you can find something useful in these posts. If you have a question, maybe a suggestion for a new post so you can learn more, or just stuck on a problem, click the button below for more information.
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Business Management, Environmental, Health & Safety, QMS Software, Quality Management, Small Business

Texas Quality Assurance – our roots

For those that don’t know me, I’m Kyle Chambers, Founder of Texas Quality Assurance. I’ve lived my entire life in Texas, raised in the small town of Italy Texas, pronounced “It-Ly” for those of you that don’t know.

My degree is in Management Information Systems, I got my CompTIA A+ certification in the 8th grade, safe to say I’m a Geek. Many years ago I was volunteered to start a Health and Safety program for the company I was working at. See I had been at a hospital doing help desk work and we all agreed it was NOT for me. So I started at this small Gas Turbine Repair company. Within the first year I had their IT needs more than met, website rebuilt and pretty much had worked myself out of a job-not a good position to be in for a newly wed man with a little 6 month old boy at home. I prayed on what to do and later volunteered to get ISO 9001 and OHSAS 18001 certified in less than 12 months. I quickly found myself working incredible hours, all 7 days of the week. By now we had two little boys at home and this life was not working for a family. I knew something had to change, and had to change fast. I took the weekend off, spent time with the family, thought about it, and knew what I was going to do. I marched right into my VP’s office that Monday and told him I was going to take two weeks to shut my door, lock it and unplug the phone. Two weeks later I emerged with the first early version of what would later become TQA-Cloud.

I recall early on when I was working in my new position as “QHSE” Coordinator (catch that, the E was added to QHS) when I completed a Corrective Action Report I would wind up with 3 photo copies of the same ugly Excel spreadsheet made to look like a Word doc. Each had notes from the person that completed one aspect or another. It might take me thirty minutes to an hour minutes just to retype, print, assemble, scan, load, and log a CAR. That’s not to mention the countless times I had to call, text, and email the supervisor to get the report completed.

When I went live with my first version of a cloud based QMS, I issued a CAR that morning to one production supervisor who admittedly only logged into the computer once a year to sign off on his insurance paperwork electronically. Seeing as I was also the Systems Admin, I had verified it was true, he NEVER logged in, not once in the past 9 months.

Much to my surprise within 1 hour of issuing the CAR I got an email from the system informing me the CAR had been completed. I just assumed I’d made a mistake in one of my workflows or filters or who knows what. After pouring through all the geek logs and code, I just decided to open up the CAR. Turns out he’d received the notification on his phone, filled in every field, even attached photos he took with his phone, and took a photo of his completed inspection report.

The fact is that people, even seemingly technology deficient people who cannot even be bothered to log into their computer, CAN engage in something soooo dull as a Corrective Action Report when you build easy to use tools that make sense to the company, process, and people.

Not long after this a consultant we were loosely using was amazed at the simplicity and detail of our system. He had a client that was API Q1 and 6A certified. As you know, if you lose your stamp, you pretty much lose your business. He was given a 60 day ultimatum to get onto an electronic file system. This unnamed client had more file cabinets than I’d ever seen-full of binder upon binder, and 3-4 partially functional computers in the office. I really have no idea how they got things done but they did. I showed up when 47 days were left. So, it was off to the races to not only build a QMS from scratch, but build a server to go with it. Today we use Office 365 as our backbone, but it didn’t exist back then. With 6 days left till his next audit, we got him going.

As they say, the rest is history. It’s a lot of hard work, prayer, struggle and innovation. But, I feel truly blessed to be doing what I’m doing and thank God for the opportunity to do it.

It’s not about the QMS, its all about saving time and energy for what matters most to you. Maybe that is a passion project at the office, maybe you just want to get home in time to see your son’s little league game, or maybe you’re crazy enough to quit a job in search of a dream so others can pursue their own, too.

We value your time and energy, and hope you can find something useful in these posts. If you have a question, maybe a suggestion for a new post so you can learn more, or just stuck on a problem, click the button below for more information.
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Environmental, Health & Safety, Leadership

OSHA’s Revised Rule for Reporting of Work-Related Injuries and Illnesses

Guest blogger today. Pat Patterson it’s LAAP.

OSHA’s Revised Rule for Reporting of Work-Related Injuries and Illnesses

Year-end 2017 companies in certain industries are required to send, electronically, their accident and illness data (OSHA 300 and/or 300A) to OSHA. This has been getting a LOT of attention. However, the more urgent concern that was established in the final rule was the August 10, 2016 deadline for employers to adopt, and communicate to employees, reasonable procedures for reporting of workplace injuries and illnesses. There is, however, another major concern. That concern is OSHA’s assertion in the preamble to the revised regulations that the new rule may very well prohibit certain “blanket” post-injury drug testing policies, as OSHA feels that blanket policies for testing of all employees who are injured on the job is an unreasonable deterrent to reporting an injury and, thus, a violation of the new rule.
Herein lies a huge problem, in our opinion, consistency… Employers MUST conduct a thorough Root Cause Analysis (RCA) on each and every injury and illness to determine, in part, if drugs played, or may have played, a part in the cause of the injury and/or illness. The EEOC protects employees from being discriminated against. Should the employer decide to drug test one employee after an injury/illness, and NOT test another employee after another injury/illness, the employer absolutely MUST be able to document their reasoning, or be subject to an EEOC suit.
However, it’s not rule yet… The drug testing portion of the new rule has been challenged and OSHA has postponed implementing this portion until after November 2016. This is when the courts will hear arguments from the companies who filed the lawsuit.

Our Recommendation:

Make certain your policies are consistent and all employees are treated equally.
Conduct a thorough RCA on each and every injury and illness. This will not only find the Root Cause and prevent recurrence, but also will determine whether or not drugs were, or may have been, involved.
Document, Document, Document….. ALWAYS document your findings that help determine your actions!!!
Conduct a comprehensive safety assessment of your facility and workplaces to remove hazards BEFORE and injury/illness occurs.
Want More Information??
For more information on changes to OSHA regulations, contact LAAP, Inc. at 936-597-7526.

Environmental, Health & Safety

Occupational Health & Safety Management Software

ISO 45001 and Occupational Health & Safety Assessment Series (OHSAS 18001)

Before Texas Quality Assurance I worked as a Quality,Health, Safety, Environment manager (QHSE). In that role I was solely responsible for all OH&S duties and responsibilities. Early in my career as the QHSE manager I found myself inundated with training requirements, audio-grams that needed review, producers to update and track, tool box talks to deliver to shop leadership, and the list goes on and on. If you are among the elite that have been tasked with the health and safety of your company’s employees then you know the struggle I’m referring to. At the end of the day the weight of an HSE manager is not only to protect the safety of the employees but the livelihood of each family who has someone working there. A bad OSHA rate can cost your company millions of dollars and lay offs. Or, even worse, an employee that loses the ability to earn the same income he once did, affecting that family forever. It is something every QHSE manager has to take seriously.

It’s hard to give each employee the one on one attention they need when the paperwork you are keeping up with is piled high on your desk. Let’s not forget about the 2 am phone call that Jeff needs to suit up for a field job and you have to cross check his training record against the matrix to make sure he meets the plant’s minimum requirements. This is all three hours before coffee pot kicks off, as well as your alarm.

Little by little the ground work of what would become Texas Quality Cloud began to develop.

First I dismantled my 122 page Safety Manual into about 30 separate procedures. Now I needed to keep track of the procedures revision and approval status in order to stay compliant to our quality system. This soon turned into a network file share with at least 100 documents, keeping records of each revision, draft, final. It was a mess. Imagine trying to sort a pile of spaghetti and trying to trace which noodle to file where. When did it point there? And does it still point there now?

Second, keeping track of training for more than 100 employees, across 40 different trainings & certifications that connected almost 10 different departments was an absolute nightmare. It started with printing the training matrix. Then, opening the Excel spreadsheet for that employee’s trainings and one by one cross checking the dates and the retrain intervals to see if the employee in question was up to date or not. Let’s not forget the struggle between operations and safety. Safety wants to train as many people as possible, but operations needs as many people on the floor or revenue falls. Now it takes an hour or two to create a list of “only the employees needing training.” You begin to lose precious instruction time and time that could have been better spent making actual revenue dollars for the company.

Third, I struggled keeping track of the many incident rates, DART, OHSA recoverables, Lost Time, etc. The last straw was when because of a fumble on the calculator on a “last minute hot job” where two of our employees onsite got pulled off the job for 6 hours because of my mistake. This was not something I wanted to repeat ever again.

So by now you might be wondering what I did to solve these problems. Well I developed IMS cloud, at least an early version of it to track my OH&S management system. In addition to QMS and OH&S and Environmental, I have more than a decade experience in Information Technology. What is a Geek turned Safety Manager supposed to do other than build a tool to save me time and energy? Truth be told I’m not sure how much longer my wife and kids would have put up with my hours either, going in early and coming home later every day.

Texas Quality Cloud is a one stop shop for all your compliance needs. Texas Quality Cloud is a cloud based software that will not only keep track of all your documents, versions, permissions, etc, but is a full content management suite. We have developed a one of a kind tool for tracking trainings. It’s easier for you to just watch our demo below than for me to type out another 20 lines to explain it to you in detail. Essentially what used to take me an hour at 2 am, can now be done by the VP of Ops within 2 clicks without ever giving me a call in the first place. How great is that? We’ve even plugged all the OSHA calculations into a tool that will keep track of it all for you. Two clicks and you can see who hasn’t been trained. Allowing you to minimize labor off the shop floor. This is key in filling out those 20 page long vendor pre-qualifications, or that “last minute hot job”. At the end of day it’s about saving time for your business, and for you.

We value your time and energy, and hope you can find something useful in these posts. If you have a question, maybe a suggestion for a new post so you can learn more, or just stuck on a problem, click the button below for more information.
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ITC Facing Criminal Charges for Chemical Plant Fire

Harris County DA hits ITC with five environmental charges

So many forms and process… what to do?

NCR, RNC, CAR, CAPA, MOC, CI, ECN, Risk….