Good safety plan vital for unusual occurrences

There is no manufacturing process where nothing ever goes wrong. Defects and human errors can have major (financial) consequences. Moreover, there are some special legal obligations if something does go wrong. It is therefore important to have a safety plan that not only focuses on preventing accidents, but also on dealing with and reporting incidents. A good safety plan is essential to limit the consequences.

Manufacturing process risks

Many large production processes involve certain environmental risks. The volume of substances processed and the size of the process can mean that if, for example, a short-term spill occurs, those effects can quickly be felt outside the facility. Moreover, it can never be completely ruled out that something might go wrong.

Reporting unusual occurrences

The Environmental Management Act prescribes that 'unusual occurrences', i.e. events, regardless of their cause, which deviate from normal business activities, must be reported to the competent authority as soon as possible. The obligation to report only applies to the extent that the consequences of the unusual occurrence occur outside the establishment (or threaten to occur outside the establishment).

These need not be very large incidents. The toppling of a jerry can of lubricating oil may qualify as an unusual incident if the lubricating oil flows off the company premises or into the municipal sewer system. But even a small fire (whether self-extinguished or not) on one's own premises is most likely an unusual incident.

When an unusual occurrence occurs, however, the focus is primarily on incident response such as cleaning up, resuming the production process or calling the fire department rather than performing administrative actions or calling the competent authority.

Good safety plan important

It is therefore of great importance that manufacturing companies have a good safety plan. Not only is this often a legal or environmental permit requirement, but just in case something goes wrong, it is important to take into account issues that your employees may not immediately think of at the time.

The safety plan should elaborate on who is responsible for reporting incidents to the competent authority as soon as possible. This should perhaps be someone a little further removed from the incident response. After all, this person has more opportunity to immediately contact the competent authority.

Consequences of not reporting on time

Failure to report in a timely manner may result in enforcement action to prevent recurrence. This may result in penalty payments being imposed. However, failure to comply with the duty to report is also an economic crime. Certainly not every little mistake will be prosecuted immediately, but it is obviously very important to limit this risk as much as possible.

So in a safety plan, don't just address the prevention of incidents, be sure to pay attention to their (legal) resolution as well. That will prevent problems.