Document 3NR876LG50b21QBjOOQNYO26E

SM-32 (REV. 5*78) Shell Oil Company Interoffice Memorandum AUGUST 10, 1988 7^77. FROM: STAFF INDUSTRIAL HYGIENIST, PRODUCTS HEALTH & SAFETY TO: SEE ATTACHED DISTRIBUTION LIST SUBJECT: HEALTH & SAFETY RESOURCE INFORMATION Attached for your information are a new health and safety procedure and set of audit checklists which are now in use by Wood River Mfg. Complex. You may want to consider any applicability the attached resource has to your location. P. J. Snyder P0S:bjd Attachment cc w/attachment 0. D. Long cc w/o attachment R. C. Newell BJT8822302 LAM 002769 DPMC-08898 DISTRIBUTION LIST MANUFACTURING LOCATIONS ANACORTES REFINERY MANAGER, HEALTH, SAFETY AND ENVIRONMENT DEER PARK MANUFACTURING COMPLEX MANAGER, HEALTH AND SAFETY GE1SMAR PLANT MANAGER, HEALTH, SAFETY AND ENVIRONMENT MARIETTA PLANT MANAGER, HEALTH, SAFETY AND ENVIRONMENT MARTINEZ MANUFACTURING COMPLEX MANAGER, HEALTH AND SAFETY NORCO MANUFACTURING COMPLEX MANAGER, HEALTH, SAFETY AND MEDICAL ODESSA REFINERY MANAGER, HEALTH, SAFETY AND ENVIRONMENTAL TAFT PLANT SAFETY AND TRAINING REPRESENTATIVE WILMINGTON MANUFACTURING COMPLEX MANAGER,'HEALTH, SAFETY AND ENVIRONMENTAL PRODUCTS DISTRIBUTION LOCATIONS METAIRIE PLANT MANAGERTHEALTH, SAFETY AND ENVIRONMENT/Q.A. SEWAREN PLANT MANAGER, Q.A./HEALTH, SAFETY AND ENVIRONMENT 2 BJT8822302 LAM 002770 DPMC-08899 SHELL OIL COMPANY WOOD RIVER MANUFACTURING COMPLEX WRMC INDUSTRIAL HYGIENE REVIEW PROGRAM PAGE 1 OF 3 COMPLEX PROCEDURE BOOK I, S 1.09 ORIGINAL ISSUE 5/88 PURPOSE This procedure is intended to assure that WRMC is meeting the objective of maintaining a healthy work place and meeting the requirements of health regulations. SUMMARY To meet the objective, this program requires a review of each BPU, Central Maintenance, QA, and Purchasing every two years. The review will be a combined effort of Departmental personnel and the H&S-staff. The review will focus on the requirements of the existing IH related Complex Procedures. TOPICS COVERED The review will include the following topics: -Hearing Conservation -Respiratory Protection -Radiation -Ceramic fibers -Reporting Suspect Hazards -Hazard Communications -Chlorine -Embryo-fetus -VDT's -Benzene -Asbestos -Lead -Acid King and PVC protective clothing -Work around Inerted Equipment . -Hazardous waste sites -Mandatory H&S Training -Environmental Monitoring Equipment -Ventilation Systems S 1.05 S 3.05 S 1.07 S 1.03 S 1.08 S 1.04 F 3.01 memo memo S 1.01 S 1.02 S 1.06 S 3.04 S 4.04 memo S 4.13 Lam 002771 COMP PROC S 1.09 DPMC-08900 SHELL WOOD RIVER MANUFACTURING COMPLEX WRMC INDUSTRIAL HYGIENE REVIEW PROGRAM PAGE 2 OF 3 V COMPLEX PROCEDURE BOOK I, S 1.09 ORIGINAL ISSUE 5/88 REVIEW TEAM MEMBERSHIP A Review Team will be formed to conduct each review. The Team will include two representatives from H&S and two representatives from the department being reviewed. The membership should be selected to promote effective communication between the Department personnel and the H&S staff. A good understanding of IH requirements is essential to the success of the program. It is expected that the Review Team members will gain information that will increase WRMC capability to do the preventive activities necessary to have a healthy work place both in procedure and practice. GUIDELINES Checklists or self audits covering the IH requirements have been developed to facilitate the reviews and focus on requirements. During the review, comments in response to compliance with a particular requirement should be written directly on the checklists. Industrial Hygiene will maintain and update the lists as needed. RESPONSIBILITIES A. SENIOR INDUSTRIAL HYGIENIST 1. Has overall responsibility for the program. 2. Publish a schedule each year of the units to be reviewed. Approximately one every two months. 3. Select the H&S participants for each review. 4. Designate the H&S participant to be team leader. 5. Assure checklists/self audits are updated. 6. Request names of department participants. B. DEPARTMENT MANAGER BEING REVIEWED 1. Select two department participants for the review. 2. Issue status report every two months to his Superintendent and Manager H&S until all items are resolved. COMP PROC S 1.09 lam 002772 DPMC-08901 SHELL WOOD RIVER MANUFACTURING COMPLEX WRMC INDUSTRIAL HYGIENE REVIEW PROGRAM PAGE 3 OF 3 V COMPLEX PROCEDURE BOOK I, S 1.09 ORIGINAL ISSUE 5/88 C. REVIEW TEAM LEADER 1. Arrange the date within the assigned month to conduct the review. 2. Conduct a planning meeting with review participants to schedule interviews, determine records to be spot checked, and which checklists are applicable. 3. Conduct the review in one day. 4. Verbally report out to the Department Manager at the close of the review. 5. Issue a written report to the Manager within one month of the review including the checklists. APPROVAL: SUPERINTENDENT TTTle REVIEWER: MANAGER HEALTH l SAFETY TITLE ORIGINAL ISSUE COMP PROC S 1.09 LAM 002773 DPMC-08902 RESPIRATORY PROTECTION PROGRAM & RESPIRATORY MANUAL S 3.05 Yes Are the jobs or activities in the area classified per Table I? Are employees training records maintained (Section 7 Manual)? Is the content of the training documented? Are employees in the department physically able to wear a respirator? If needed, do personnel required to wear full face respirators have the spec kit? Are respirators available and ready for routine or emergency use? Are respirators properly stored, inspected? Do personnel know how to get and return respirators? Are JEP's in Appendix A of Respirator Manual? Are personnel familiar with the positive and negative field fit procedure (Section 8 - Manual)? Do employees have respirator type/size sticker on hard hat? Are supervisors/employees familiar with selection criteria for respirators (Appendix C)? Do employees maintain facial hair so that it does not interfere with proper fit and operation of the respirator? No WMC/mah 3/10/88 WRR2940/8807002 - 1 GENS LAM 002774 DPMC-08903 HAZARD COMMUNICATION PM 15.12 SELF AUDIT Aj, APPROVAL OF NEW CHEMICAL SUBSTANCES (II)* 1. REQUIREMENT - All new chemical substances must receive a Health and Safety review by Industrial Hygiene prior to being brought into the Complex. 2. ASSESSMENT Do people in the Department who approve purchases understand this requirement? yes________ no_______ . Have any new chemical substances been purchased during the last year? yes_______ no_______ If so, check purchase requisitions for IH initials. yes_______ no_______ B. IDENTIFICATION OF CONTENTS OF "FIXED VESSELS" (III,B,1) 1. REQUIREMENT -- The person operating a unit must be able to identify the contents of fixed vessels (tanks, columns, exchangers etc.) in the area. Also, the operator must locate the appropriate MSDS for the contents of a vessel and convey that information to crafts and others verbally and by the precautionary measures on a permit. 2. ASSESSMENT or area? Are signs posted at normal approaches to the unit yes no -refers to section in procedure LAM 002775 DPMC-08904 F'M 13.12 SELF AUDIT page2 Is the Fixed Vessel Toxic Substance book available? yes_______ no_____ Does the operator on duty know what the contents of the exchangers, tanks, vessels, pumps, piping are? (pick four fixed vessels at random and ask what is in the vessel and ask to see the MSDS) knew_______ didn't know________ Do the permits forvessel work (where the vessel will be opened) indicate the process contents and appropriate protective equipment? - Check the last three permits. yes_______ no_____ EQUIPMENT THAT LEAVES THE OPERATING AREA (111,B,2) 1. REQUIREMENT - When equipment leaves the custody of the responsible operating department, it must be properly tagged. 2. ASSESSMENT Do the operating and maintenance foremen know this is required? Do the truck drivers picking up the equipment know? ves no operations yes no maintenance ves no truck drivers required service? Do the foremen know that an additional red tag for equipment that has been in acid or caustic yes_______ no_______ is Has any equipment left the unit during the last month? Where was it sent? If yes, check with receiving department to determine if the equipment was properly tagged. properly tagged_______ not D_^_ QUALITY CONTROL SAMPLES ( 11 I , B , 2 ) 1. REQUIREMENT -- All samples being sent to the QA lab or taken to the unit lab must have sample tags that identify the con ten ts. LAM 002776 DPMC-08905 F'M 15.12 SELF AUDIT paqe3 2. ASSESSMENT Do the operators know this requirement? yes_______ no_______ Check three samples. Are tags on? If so, are the contents noted? yes_______ no_______ Are special cautions such as acid, caustic noted? yes_______ no_______ Ei. LABELS ON CONTAINERS ( 111 , A , 2 ). 1. REQUIREMENT - All containers other than those covered under `fixed vessels' must be properly labelled (examples: 55 gal. drum, lubsters, anti-freeze, 5 gal. cans, cardboard barrels.) 2. ASSESSMENT Do people understand the requirement? Randomly ask six unit personnel. yes_______ no_______ Check all containers for legible labels. Drums, bags, lab reagents. yes_______ no_______ F. MATERIAL SAFETY DATA SHEETS (IV) 1. REQUIREMENT -- Using departments are responsible for acquiring and maintaining MSDS's for all chemical substances they have present. The MSDS book must be indexed and readily available to employees. 2. ASSESSMENT room? Is there a MSDS book in the zone shop and control yes yes. no. no control room zone shop Is there a Shell `Users Guide- there also? LAM 002777 DPMC-08906 PM 15-12 SELF AUDIT page4 Is there an alphabetized listing of the substance and Shell MSDS number? yes_______ no_______ Do the MSDS's all have a Shell control number? yes_______ no_______ Is someone assigned to keep the MSDS's up to date? yes_______ no_______ Does that person know how to request an MSDS? yes_______ no_______ F. EMPLOYEE TRftININS AND INFORMATION (V) 1. REQUIREMENT -- Employees who work with chemical substances must receive training prior to assignment and annual refresher training. 2. ASSESSMENT they have months. Check the records of five employees to received refresher training within the see that last 12 yes_______ no_______ Have any new people been assigned in the last three months? Do the records show they received either basic training (new employees) or department specific training (transferred employees) at the time of their assignment? yes_______ no_______ Are there copies of the training outline for new and transferred employee? yes______ no LAM 002778 DPMC-08907 ASBESTOS AUDIT. SHEET YES 1.) Are units and buildings which contain asbestos insulation properly posted? 2.) Are BPO personnel familiar with the health hazards associated with over exposure to asbestos? Ask 3 people. 3.) Are BPU personnel familiar with precautions that need to be taken before during and after asbestos removal? Ask 3 people. 4.) Are BPO personnel familiar with procedures for identifying asbestos insulation? Ask 3 people. 5.) Are BPU supervisors and insulators familiar with asbestos disposal procedures? Ask 2 supervisors. 6.) Is supervision aware of EPA notification requirements? Ask 2 supervisors. 7.) Are BPO personnel aware of areas that contain asbestos insulation? Includes management. Ask 2 people. 8.) Do BPO personnel observe Regulated Areas? 9.) Are signs and banner tape (asbestos) used to demarcate a Regulated Area? 10.) Is personal protective equipment worn when it is needed? NO LAM 002779 DPMC-08908 11.) Have BPU personnel been given asbestos awareness training in the last year? Check 3 employee training records. 12.) Is there exposed asbestos insulation in the area? Includes buildings. 13.) If the answer is yes to 12 then are measures being taken to fix the problem? 14.) Are there areas which need immediate attention? 15.) Does BPD manager have long range plan for dealing with asbestos containing materials in his/her area? LAM 002780 DPMC-08909