A loop or noose with risk assessments?

In past discussions relative to risk assessments, I feel like I've given short shrift to an important part of the process: closing the loop and making sure it stays closed.

In many cases, it's not merely enough to have conducted a risk assessment (EC.1.10, EP #4); there is also an expectation that the interventions you identify to manage the risks "...achieve the lowest potential adverse impact on the safety and health..." (EC.1.10, EP #5).

And, at least as far as the scientific method is concerned, the only way you can be sure that you've achieved that goal is to collect and analyze performance data relative to the intervention.

For instance, there are a number of ways that you can provide your staff members with access to material safety data sheets. Sometimes it seems like new technologies emerge every day in this realm. Be that as it may, OSHA's hazard communication standard, like many of the risk management concerns you're likely to face, is primarily a performance-based undertaking. OSHA doesn't necessarily tell you how to do it, beyond the goal of ensuring access (see these interpretations of the hazcom standard, 1910.1200).

So long as you can demonstrably meet the requirement of ensuring access, from a compliance standpoint you should be in good shape. That said, I'm sure you have processes in place that can also help you comply with the hazcom standard, such as:

• Hazard surveillance rounds
• Spot-checking during fire drills
• Annual evaluations of the hazardous materials and waste management program

Thus, these activities become the source of data in support of, or in opposition to, your organization's compliance.

But wait-we're not done spinning this one . . .