Document and Process Control
The requirement wording has been updated to provide greater clarity, and new guidance on root cause analysis (RCA) has been added under the requirement "A chemical incident management system is implemented". This strengthens expectations for investigating chemical incidents, identifying underlying causes, and implementing effective corrective actions to help prevent recurrence.
The requirement wording has been updated
Previous requirements:
1. Identify and maintain documents related to the chemical management system
2. Prepare a SOP on document control
3. Implement an incidents management system
4. Ensure general maintenance and housekeeping standards are met
Updated requirements:
1. The facility maintains key documents to support its chemical management system
2. The facility controls documents related to the chemical management system
3. A chemical incident management system is implemented
4. General facility maintenance and housekeeping are managed
Root cause analysis (RCA) guidance has been newly added under the requirement: A chemical incident management system is implemented
This addition strengthens the guidance on Root Cause Analysis (RCA) and Corrective Action Plans (CAPs) by introducing practical methodologies, including Fishbone analysis, 5-Why analysis, and data-driven investigation approaches. It enables facilities to systematically identify underlying causes of incidents and implement effective corrective actions to prevent recurrence and drive continuous improvement.