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QS0""1 IMPROVEMENT ACTION REQU^"T IAR is IMPROVEMENT ACTION REQUEST; PAR is PREVENTIVE ACTION REQUEST; CAR is CORRECTIVE ACTION REQUEST AREA/PROCESS Hazardous Waste IAR # PAR # CAR # 11-041 REQUEST ORIGINATOR: Tom Garing REQUEST DATE: 10/18/2011 DUE DATE: 12/6/2011 NAME(S) OF ACTION REQUEST IMPLEMENTER -S): EH&S Manager Jennifer Gutierrez, QA Trainer Julio Pineda a. REVIEW OF THE NONCONFORMITY, STATING THE CIRCUMSTANCES OF THE NC OR OPPORTUNITY FOR IMPROVEMENT San Joaquin County REHS Stacy Rivera inspected the QBR Facility on October 18th, 2011 finding the following deficiencies: 1. onsite hazardous training is being conducted by persons who are lacking current training in accordance with Title 22 regulations, 2. containers larger than 5 gallons that previously held a hazardous material or hazardous waste, shall be marked with the date that they were emptied and managed within one year of being emptied, 3. hazardous waste containers were noted to be stored close to one another, not allowing access for the inspection the drums or their labels. 4. Universal Waste containers with used batteries and empty aerosol cans had labels that did not contain on the "Universal Waste" or the contents of each container (i.e. Used batteries, empty aerosol cans), 5. it is recommended that the organization follow up on US Technologies handling of used shot blast media to assure that it is being handled properly. ACTION PROCESS STEPS: b. DETERMINE THE ROOT CAUSE OF THE NONCONFORMITY OR EVALUATION OF ACTION OPPORTUNITY": 1. The previous EH&S Manager maintained current Hazardous Material training, however, since his departure from the organization, no training had yet been completed by the new EH&S Manager, 2. The date of empiying hazardous material containers had not been previously noted on the Empty Container label, 3. container storage locations need to be oreganized to allow for proper inspections, 4. Universal Waste had not previously been labeled with the type of Universal waste in each of several containers, 5. follow up on the handling of excluded recyclable material had not previously been conducted. c. EVALUATION OF THE NEED FOR ACTION TO ENSURE THAT (ADDITIONAL) NCS DO NOT OCCUR 1. Training on Hazardous Waste Management has been schedule on November 8th, 2011 and November 15, 2011 for the EH&S Manager and the QA Trainer Positions, 2. the Empty Container Label format has been changed to include a field for the empty date for a container that previously held a Hazardous Material, 3. Hazardous Material Inspections will include observations of the placement of containers that will permit proper access for container and label inspections, 4. Universal wast Label formats have been revised to include the Universal Waste and the type of materials in each labeled container, 5. a follow up on each US Tech nologies shipment of excluded recyclable materials will be conducter after each future shipment has been made, to assure that these materials are handled properly. d. DETERMINATION OF ACTION NEED TO BE TAKEN AND IMPLEMENTATION PLAN Jennifer Gutierrez and Julio Pineda attended Hazardous Waste Management training on Tuesday November 8, 2011 and Advanced Hazardous Waste Management training on Tuesday November 15, 2011. QBR internal training on Hazardous Waste Management is scheduled to be conducted by Julio Pineda for all affected QBR associates on Tuesday, December 6, 2011. e. RECORD THE RESULTS (OR ANTICIPATED RESULTS) OF THE ACTIONS TAKEN Jennifer Gutierrez and Julio Pineda are now certified to conduct Hazardous Waste Management training to all QBR associates who handle Hazardous Waste. Training will be conducted initially with a yearly refresher for affected associates. f. DOCUMENT THAT THE ACTIONS TAKEN HAVE BEEN REVIEWED FOR EFFECTIVENESS AND VERIFIED IN THE SPACES BELOW Hazardous Waste Management training material has been updated scheduled for Tuesday December 6, 2011. QBR will document all training and schedule a refresher training for 2012. *NOTE - Thorough NC root cause investigations should include a 5 WHY analysis and/or a FISHBONE DIAGRAM to consider all incident aspects. Sheets 2 and 3 of this file contain forms that outline the basic use of these tools. SUBMITTED FOR APPROVAL BY: Julio Pineda DATE: 11/29/2011 QBR QUALITY MANAGER APPROVAL: Tom Garing DATE: IAR/PAR/CAR VERIFIED TO BE IMPLEMENTED AND EFFECTIVE VERIFIED TO BE IMPLEMENTED AND EFFECTIVE BY DOCUMENTATION VERIFIED TO BE IMPLEMENTED AND EFFECTIVE BY INSPECTION/TEST [ ] REJECTED WITH REASON EXPLAINED BELOW: QS0201Action Request Form Sheet Rev. D VERIFIED/REJECTED BY: Jennifer Gutierrez DATE: 12/29/09