6.2 EHS Incident and Non-Compliance Investigations

On this page:
6.2.1 Reporting and Recording
6.2.2 Preventive and Corrective Actions

When accidents or incidents occur, or events of non-compliance are observed, it is important to investigate to determine the root cause or causes, and to initiate and confirm completion of appropriate corrective action.

6.2.1 Reporting and Recording

Accidents or incidents involving injuries, and illnesses to employees, are part of the OSHA reporting and record keeping procedures, as described in the Injuries and Illnesses OSHA Reporting SOP.

Incidents involving potential harm to the environment, such as a major chemical or oil spill, are to be reported to the EHS Office immediately. Please see Spill Response Procedures SOP for definition of major spills. The EHS Office has in place procedures for emergency response and for notifying the appropriate agencies regarding such incidents. Procedures for contacting regulatory agencies are described in the EHS Communications to External Parties SOP.

Accidents and incidents are investigated at different levels of detail, depending on their severity. Emergencies are investigated by the EHS Office and selected DLC representatives to determine the cause of the emergency, equipment malfunction, or operating procedure problem. A Root Cause Analysis is completed to determine root causes or contributing causes of the incident, underlying factors, and the roles that design, skills, maintenance, and procedures played in the occurrence of the incident. The EHS Office develops a report with recommendations for corrective action, and coordinates with the affected parties to ensure that the corrective measures are carried out. When corrective action is required by the DLC, the EHS Coordinator is responsible for initiating and confirming completion of the corrective action. When corrective action is required by the EHS Office, or by the MIT administration, EHS Office management initiates and confirms completion of the corrective action.

For employee injury and illness, the DLC PIs/Supervisors investigate the accidents and complete the Supervisors' Report of Occupational Injury/Illness. The EHS Office and the DLC may investigate certain accidents in greater detail if needed.

6.2.2 Preventative and Corrective Actions

An After Action Review can be initiated by the Managing Director of EPO, EHS office Director, or Emergency and Business Continuity Planner after an incident to determine the level and quality of response from the DLCs involved. The After Action Review report is completed by a team assembled by the EHS Office after the incident and includes:

• incident information (including non-compliance or non-conformance items),
• date and time,
• location,
• contacts,
• reporter,
• description,
• corrective action,
• preventative action,
• and verification of implementation.

Where corrective actions (including non-compliance or non-conformance items) are identified through the After Action Review, the After Action Review team and the DLC representatives are responsible for:

• Identifying appropriate corrective and preventative actions (including modifying or creating procedures and work practices) in a written report,
• Planning and implementing corrective and preventative actions, and
• Verifying the completion and effectiveness of corrective and preventative actions through the use of a tracking database.