Document 0g30B4jvkaJMRXDZRbDRzqVzm

TO: Distribution Interoffice Communication FROM: DATE: SUBJ: T. G. Grumbles March 27, 1991 Safety and Health Audits VIS1A Since the February 28th meeting when we discussed the development of a safety and health audit program, a proposal for the development and administration of the audit program was developed and sent to Tom Huffman (Attachment 1) . He has approved the general concept and asked the ad-hoc team to become a project team, and proceed. This approval is indicated in Attachment 2, a letter to the plant managers. An essential part of the development of the audit program is your development of specific modules for the system. This was discussed and agreed to at our meeting on the 28th. The team has determined module assignments. These are indicated on the following pages with specific guidelines on how to develop the modules. Please read these carefully, as we will need to have consistency in content of these modules. Two example modules are attached for your reference. These are examples to illustrate the style and detail desired. WE NEED THESE ASSIGNMENTS TO BE COMPLETED AND RETURNED TO ME BY MAY 8TH. The team will then meet to review these for consistency and content, and to develop the full audit program. wv 000006215 LCCP LCVCM LCIAB Aberdeen Okc Balt Hammond V: MODULE: ASS IGNMENTS h Safety Control Permitting (IV) Emergency Response (VI) Hazwoper (III) Radiation (XIII) Ethylene Oxide (XI) Safety and Health Training (VIII) General Safety Promotions (XVI) Hearing Conservation (VI) Laboratory Safety/Health (XIV) Electrical Safety (X) Walking/Working Surfaces (XIII) Lighting and Ventilation (VII) Mechanical Safety (IX) Hand & Portable Tools Compressed Gases Welding/Cutting Machine Guarding Lifting Devices/Slings Material Handling (XII) Lead (X) Accident Investigation (III) Fire Protection & Training (V) Contractor Safety (XV) VCM (IX) Asbestos (XII) General Safety Rules (II) Process Safety (VII) Crane Safety (XI) First Aid (XIV) REGULATORY CITATION * 1910, 38, Resp. Care 1910, 120 1910.96 and .97 1910.1047 ** * 1910.95 *** 1910.301-,308;331-360 1910.21; 1910.30 1910.94; * 1910.241-244 1910.101; 1910.169 1910.251-255 1910.211-219 1910.176; 1910.184 1910.176-183 1910. 1 or 5 * Subpart L (1910.155-165) **** 1910.1017 1910.1001; 1926.58 * Draft Regs; Resp. Care 1910.179-181 1910.151 POINTS 300 200 100 50 100 100 50 50 50 100 100 50 250 100 100 100 250 100 100 100 100 300 150 50 VVV 000006216 MODULE ASSIGNMENTS REGULATORY ?? CiTATION:*l::: POINTS:' Houston Medical & Exposure Records (IV) Leadership and Administration (I) Health Hazard Identification & Evaluation (I) Hazard Communication (II) Respiratory Protection (V) Benzene (VIII) 1910.20 * * 1910.1200 1910.134 1910.1028 50 50 100 150 100 100 * These elements are guided by policy and practice. The questions should be developed based on professional judgement consensus standards, and/or responsible care elements if they exist. ** Safety and health training requirements covered in specific standards will be evaluated in those modules. This element should be for those items not covered by standards. *** This element is not meant to be for the OSHA Laboratory Standard. Plant QC labs are not covered by this standard. This element is for "good practice" elements similar to item * above. **** This element is for items not covered in specific standards, such as HAZCOM, and HAZWOPER. vvv 0000062T.7 GUIDELINES FOR MODULE DEVELOPMENT 1. Format should be the same as the examples, Resp. Protection and Benzene, attached. 2. Modules should be applicable to any plant. In other words, not based on your plant's practice. 3. Where a regulation applies the questions should closely parallel the sections/requirements of the standard. 4. The questions should be as objective as possible, utilizing yes/no answers where possible. Where professional judgement is required by the auditor for a specific question, please indicate with a (*PJ) designation. 5. Please indicate points for each question based on your impression of the importance of individual questions. Total points per module are indicated in the "assignments" above. 6. Certain questions in each module will require verification by presentation of written programs, etc. or employee interviews. The team will make this indication when reviewing the modules for consistency. 7. Please provide a hard copy of your assignments and a labeled disk (indicate software used please) to me. This will facilitate developing the final product. We've sent you a lot of information and need a lot of work by May 8th. Please carefully review all the attachments before starting to work. Also, please contact a team member if you have any questions. Good luck! T. G. Grumbles /dlj Distribution: M. Tonkovich-Hammond, B. Trego-Aber, G. LCVCM, R. Gantz-LCLAB Shirley- cc: K. Fogg-LCCP, B. White-Bait, M. Lunsford-Okc PLANT MANAGERS R. W. Seymour-Aber, L. R. Bauer-Balt, G. D. Williams-Blane, J. Pavao-Hmd, J. Friend-LCCP, J. W. Ware-LCLAB, P. Carrico-LCVCM, H. D. Garrison-Okc, P. L. Foote-Prem, V. W. Weiss-Austin T. Huffman 00GQ062ia vvv RESPIRATORY PROTECTION MAJOR CATEGORIES SCORING SYSTEM Category 1. Training 2. Fit/Medical Testing and Records 3. Policy 4. Inspection 5. Selection 6. Maintenance 7. Care 8. Auditing 9. Breathing Air Quality 10. Responsibilities 11. Contractors 12. Work Area Surveillance 13. Emergency Rescue (IDLH) 14. Hose Fittings 15. Prescription Glasses Total points attachment 2 Score Possible 10 10 9 9 8 8 7 7 7 6 5 5 5 2 2 100 00000621^ MEASURE SYSTEM RESPIRATORY PROTECTION 1. Training a. Are users instructed in the proper use of respirators? b. Is training adequate? c. Is training performed as required and records kept? d. Is training evaluated? e. Are users trained in proper selection of respirators? f. Can employees demonstrate proper respirator use? g. Are employees informed about the necessity of fit testing? h. Are employees trained in the proper care of respirators? 2. Fit + Medical Testing/Records a. Is fit testing required? b. Is fit testing performed as required? c. Is medical certification required? d. Are medical certification records kept? e. Is medical certification performed as required? 3. Policy a. Does the plant have a written policy? b. Does the policy meet the requirements of OSHA 1910.134? 4. Inspection a. Are inspections performed and records kept as required? b. Are SCBA inspections performed and records kept? c. Are escape respirator inspections performed and records kept? d. Are respirators inspected before and after each use? Total Points 10 10 9 8 vvv 000006220 VISTA Pnfiw 1 rtf 4 Quench Solids 5. HEALTH HAZARD INFORMATION FIRST-AID' EYES: Immediately flush eyes with plenty of water for at least 15 minutes. Get medical attention immediately. Call a physician. SKIN: Flush skin with plenty of water. Remove contaminated clothing. Call a physician if irritation persists. Wash clothing before reuse. INHALATION: If exposed to excessive amounts, remove to fresh air. If breathing has stopped, administer artificial respiration. INGESTION: DO NOT INDUCE VOMITING! Seek medical advice. MATURE OF HAZARD EYE: In liquid form slight irritation may occur due to solvent content. If dried physical irritation may occur. SKIN: INHALATION: INGESTION: Due to solvent content, repeated or prolonged skin contact may result in irritation and reddening of the skin, progressing to dermatitis. In dried form physical irritation may occur. LPA solvent vapors may cause headache and stupor. If dried, dust may cause physical irritation to upper respiratory tract. Irritation of the stomach and intestines resulting in nausea and vomiting may occur due to solvent content. If dried, negligible hazard is anticipated. EXPOSURE LIMITS ; ..... . fy For LPA Solvent: For Aluminas: If product is dried Vista recommended PEL: 100 ppm, 525 mg/m3 for 8-hour TWA (Exposure limits for Petroleum Distillate - Stoddard Solvent) ACGIH TLV = 10 mg/m3 of total dust and 5 mg/m3 respirable dust. OSHA PEL = 15 mg/m3 of total dust; 5 mg/m3 respirable dust. TOXICTTY DATA This product has not been specifically tested. Data for a similar product is given below. EYE CONTACT: lpa: Alumina: SKIN CONTACT: lpa: Alumina: INHALATION: INGESTION: LPA: Alumina: LPA: Alumina: Primary Eye Irritation Index (Rabbit): Max. average score - 5.0 after one hour (max. score 110) Maximum average Draize score = 7(0*110), minimally irritating. Primary Skin irritation Index (Rabbit): 4.2 out of 8.0 Acute Dermal Toxicity (Rabbit): LD^ 2.0 - 4.0 gm/kg Dermal LD^ >20 g/Kg, practically non-toxic. Primary dermal irritation index * 0.0(0-8), not a primary skin irritant. Not a dermal sensitizer in guinea pigs. VVV 000006222 No toxicity observed in rats exposed for one hour to 24.1 mg/I. Inhalation of fine particles (5-8 microns dia.) for 4 hours by rats resulted in no signs of toxicity. Oral LDS0 5 g/Kg, practically non-toxic. Acute oral LD^ in rats: 20 g/kg. SPECIAL PRECMJTIOtlS7 , , AVOIDINHALATION AND SION-CONTACT: . 1 Quench Solids Absorb spill with inert material, then place in a chemical waste container. For large spills, dike for later disposal. Dispose of according to local, state, and federal regulations. WASTE CLASSIFICATION: If discarded in its purchased form, this product Is not a RCRA hazardous waste. Re-evaluation of the product may be required by the user at the time of disposal, since the product uses, transformations, and mixtures may change the classification. 8. SPECIAL PROTECTION INFORMATION VENTILATION RECOMMENDATIONS Small quantities of LPA Solvent may be present. Use mechanical ventilation in enclosed areas when the material is wet. When dried, use mechanical ventilation to control dust levels below the PEL and TLV. SPECIFIC PERSONAL PROTECTIVE EQUIPMENT EYES: Chemical safety glasses or goggles. - > _________________ _______ - SKIN: As necessary to avoid prolonged or repeated skin contact. RESPIRATORY PROTECTION: Use NIOSH-approved air-purifying dust respirator. A**'? - N J vvv 000006223 Print* 3 nf A------ Quench Solids VISTA SHIPPING INFORMATION This product is not a hazardous material or hazardous substance as defined by the Department of Transportation, nor is it a dangerous good as defined by IATA for air transportation. TRANSPORTATION AND STORAGE ELECTROSTATIC ACCUMULATION HAZARD: None USUAL SHIPPING CONTAINERS: Truck, drums STORAGE/TRANSPORT TEMPERATURE: Ambient STORAGE/TRANSPORT PRESSURE: Ambient LOADING/UNLOADING TEMPERATURE: Ambient HANDLING AND STORAGE MATERIALS AND COATINGS SUITABLE: Carbon steel Abrasion in handling systems may occur. THE ABOVE DATA IS BASED ON TESTS AND EXPERIENCE WHICH VISTA BELIEVES RELIABLE AND ARE SUPPLIED FOR INFORMATIONAL PURPOSES ONLY. VISTA'S PRODUCTS ARE INTENDED FOR SALE TO INDUSTRIAL AND COMMERCIAL CUSTOMERS. VISTA REQUESTS THAT CUSTOMERS INSPECT AND TEST OUR PRODUCTS BEFORE USE AND SATISFY THEMSELVES AS TO CONTENTS AND SUITABILITY. VISTA DISCLAIMS ANY LIABILITY FOR DAMAGE OR INJURY WHICH RESULTS FROM THE USE OF THE ABOVE DATA AND NOTHING CONTAINED THEREIN SHALL CONSTITUTE A GUARANTEE, WARRANTY (INCLUDING WARRANTY OF MERCHANTABILITY) OR REPRESENTATION (INCLUDING FREEDOM FROM PATENT LIABILITY) BY VISTA WITH RESPECT TO THE DATA, THE PRODUCT DESCRIBED, OR THEIR USE FOR ANY SPECIFIC PURPOSE, EVEN IF THAT PURPOSE IS KNOWN TO VISTA. Prepared: B/96 Revised: 4/1/91 5003WP/LC.111 WV 000006224