Document 3QZ09m6QDzg5Xwj80pxEDVwq6

M- May 3, 1991 Bob Grahek Glenn Higby W. C. Holbrook Mike Marshall Bill Patient Ken Millings RE: HS&E ASSURANCE AUDIT REPORT Enclosed is the final report from the HS&E Assurance Audit conducted at the Avon Lake Technical Center the week of March 18-22, 1991. -f-r Also enclosed is the HS&E Documents Security Procedure, along with a copy of instructions for your HS&E Corrective Actions Report. .Please have your Corrective Actions Report to me by July 1, 1991. If you have any questions, or need any assistance, please do not hesitate to give me a call on (216) 374-3574. Dan Dimas DGD/jp NGC 13206 HSftB ABBURAHCB APPIT CORRECTIVE ACTIONS REPORT An important element of the Company HS&E Assurance Audit Program is the Corrective Actions Report. This report is essentially an action plan that addresses the methods a facility has developed to correct deficiencies noted in the report of audit findings. The following describes the requirements for the completion of a Corrective Actions Report: 1. The facility manager or his/her designee (a person who has the responsibility and the authority to implement corrective actions on behalf of the plant manager) is responsible to issue the Corrective Actions Report. 2. The Corrective Actions Report should be received by the audit program manager (Dan Dimas, CHQ-2) within 60*calendar days of issuance of the final audit report. 3. All findings contained in the final report must be addressed. Xf the finding was corrected prior to the issuance of the final report, include a description of what was done and the date it was completed. 4. Non-completed corrective action must include: o Expected date of completion. o Identification of the person(s) responsible to complete the corrective action. 5. A quarterly status report is required for all outstanding corrective actions. If the finding was corrected after issuance of the Corrective Action Report, include in the status report a description of what was done and the date it was completed. 6. Long range corrective action projects should be included in the annual HS&E Forward Plan and the Business Plan for the business. Dan Dimas 01/03/91 1221-1/jp "NGC 13207 HS&E ASSURANCE AUDIT - DOCUMENTS SECURITY PROCEDURE o Working Papers Each auditor is required to send working papers to the Audit Program manager after the Draft Audit Report has been completed. Send these papers to: Daniel 6. Dimas The BFGoodrich Company 3925 Embassy Parkway Akron, Ohio 44333-1799 o Exit Meeting Discussion Sheets The facility manager is responsible to destroy this document immediately after the Draft Audit Report has been received. o Draft Audit Report Recipients of the Draft Audit Report must destroy this document immediately after the Final Audit Report has been received. o Final Audit Report Recipients of the Final Audit Report must destroy this document after seven years, or after the facility has had a subsequent audit conducted. NOTE: PLEASE READ AND,ADHERE TO THE REQUIREMENTS LISTED IN THE ATTACHED BFG RESTRICTED COVER SHEET. NOC 13208 Arthir D Little Health, Safety, and Environmental Assurance Audit Avon Lake Technical Center Facility Final Report to The BFGoodrlch Company May 1991 Arthur D. Little, Inc. Center for Environmental Assurance Reference 65475 NOC 13210 Notice This report was prepared by Arthur D. Little, Inc., at the request of The BFGoodrich Company. The material in it reflects the audit team's bestjudgment in light of the information available to it at the time of preparation. Any use that a third party makes of this report, or reliance on, or any decision to be made based on it, is the responsibility of such third party. Arthur D. Little accepts no responsibility for damages, if any, suffered by any third party as a result of decisions made or actions taken based on this repeat. rad NGC 13211 Table of Contents I. Introduction ................. 1'................................................................................. 1 A. Purpose .............................................................................................................. 1 B. Scope ............................................ .................. *................... 1 C. Approach ................. ......................................................................................... 2 D. Report Format...................................................... .............................................. 2 II. Audit Findings ...................................................................................................... 4 A. Overall Opinion ................................................................................... .. 4 B. Industrial Hygiene ............................................................. ............................... 4 1. Chemical Hygiene Plan (CHP).................................................................. 4 2. Hazard Communication Program.......... ..................................................... 4 3. Respiratory Protection............................. 5 4. Medical Examinations.................................... 5 5. Hearing Conservation................................................................................. 5 6. Job Exposure Inventories............................................................................ 5 7. Local Exhaust Ventilation (LEV)............................................................ 6 C. Employee Safety ......................... ........................................................................ 6 8. Lockout/Tagout........................................................................................... 6 9. Eye Protection............................................................................................. 6 10. Peroxide Storage Bunko- .......................................................................... 6 11. Electrical and Process Control Room Pressurization.......................... 6 12. Low Voltage Lights ............................ ................................................... 6 13. Scaffolds .................................................................................................... 6 14. Maintenance Work Order System ............................................................. 6 15. Refrigerated Chemical Storage .................................................................. 7 16. Emergency Electrical Generator .................................................................. 7 D. Loss Prevention and Emergency Response ..................................................... 7 17. Means of Egress........................................................................................... 7 18. Portable FireExtinguishers ....................................................................... 7 19. Flammable and Combustible liquids........................................................ 7 20. Insurance Carrier Reports ......................................................................... 7 E. Air Pollution Control........................................................................................... 8 21. Hydrin Semi-Works Permit to Operate (PTO)......................................... 8 22. SA Poly Reactor Management ................................................. .............. 8 F. Water Pollution Control.................................................................................... 8 G. Drinking Water Management............................................................................... 8 H. Spill Control and Emergency Planning............ ................................................ 9 23. Spill Prevention Control and Countermeasures (SPCC) Plan ................. 9 24. Spill Prevention and Control Management................... ............................. 9 25. Secondary Containment............................................................................... 9 I. Hazardous Waste Management ........................................................................ 10 26. Contingency Plan ............................. 10 27. Waste Determination................................. 10 28. Hazardous Waste Accumulation .................................................. 10 29. Hazardous Waste Recordkeeping ........................................................... 11 30. Training Program Documentation ...................................................... 11 31. Spent Isopropyl Alcohol (IPA) Management ...................... .. 11 32. ADVA Process Waste............................................................................... 11 J. Product Safety................................................................... ............................... 11 ArtlurD Little NGC 13212 imd^S47S.(pL6ff1 1. Introduction A. Purpose This report summarizes the results of a health, safety, and environmental assurance audit conducted at The BFGoodrich Company's Avon Lake Technical Center (ALTC) facility. The objectives of the audit were to: Verify the facility's compliance with applicable federal, state, and local laws and regulations; Verify the facility's compliance with company, division, and facility policies, procedures, and standards; Determine whether facility activities are consistent with good health, safety, and environmental management practices and whether systems are in place and functioning; and Help identify actual and potential health, safety, and environmental risks. The objective of this report is to communicate the audit team's findings and observations to The BFGoodrich Company management The audit team consisted of two Arthur D. Little staffmembers (one of whom saved as the team leader), one BFGoodrich staff member, and one member from S. Z. Mansdorf and Associates. This report is not meant to imply legal certification ofcompliance or noncompliance. B. Scope The functional scope of the audit included issues within each of the following functional areas: Industrial Hygiene, Employee Safety, and Loss Prevention and Emergency Response including medical practices as well as regulatory requirements issued pursuant to die Occupational Safety and Health Act Air Pollution Control -- including federal regulations issued pursuant to the Clean Air Act and related state requirements. Water Pollution Control -- including federal regulations issued pursuant to the Clean Water Act, drinking water management and related state requirements. Solid and Hazardous Waste Management -- including federal regulations issued pursuant to the Resource Conservation and Recovery Act and related state requirements; and management ofPCBs and asbestos including federal regulations issued pursuant to the Toxic Substances Control Act and related state requirements. Spill Control and Emergency Planning -- including oil and chemical spill prevention and control and selected requirements of the Comprehensive Environmental Response, Compensation, and Liability Act and the Superfund Amendments and Reauthorization Act NGC 13213 ArthirD Little m*d.65475.tpLfi1 1 1. Introduction Selected requirements of the"Hazardous Materials Transportation Act, Toxic Substances Control Act, and the Food, Drug, and Cosmetic Act, as applicable to the facility. ,, , .v... Overall health, safety, and environmental management systems. C. Approach The fieldwork potion of the audit was conducted from March 18 through March 22, 1991. The period under review was January 1,1990 through March 22,1991. The audit was based on: Physical inspections of the facility; Examination of selected health, safety, and environmental administrative and operating records made available by facility staff at the audit team's request; Interviews and discussions with key facility and corporate management and staff; and Verification procedures designed to assess the facility's application of, and adherence to, health, safety, and environmental laws and regulations, and corporate and plant policies and procedures. In addition, we reviewed the facility with respect to die audit team's view of good industry practice. The process by which this audit was conducted is consistent with the general state of the ait of health, safety, and environmental auditing and die best professional judgment of the audit team members. The audit followed audit protocols developed for BFGoodrich based upon established audit procedures. It should be understood that the audit consisted of evaluating a sample ofpractices and was conducted in a short span of time relative to the review period. Efforts were directed toward sampling major facets of health, safety, and environmental performance during die period under review, but it is important to recognize that this method is intended to uncover major program deficiencies, and this audit may not have identified all potential problems. D. Report Format Because of the nature of the audit and the broad scope of applicable regulatory requirements, this report focuses on exceptions to regulatory requirements or The BFGoodrich Company standards and observations with respect to our view of good health,'safety, and environmental management practices. Where we identified an exception to a regulatory or BFGoodrich standard, specific references to laws and regulations or company policies and procedures are provided. In other cases, we identified situations which do notrelate to specific regulatory or BFGoodrich requirements but which, in the judgment of the audit team, represent deviations from good health, safety, and environmental management practices or potential liabilities. ArithirD Little NGC 13214 nwd.SS476.rpLS/91 2 I. Introduction Section n includes the audit team'soverall audit opinion and specific audit findings by functional area. Within each functional area, the report lists specific exceptions to governmental requirements, exceptions to BFGoodrich policies and procedures, and observations related to die management systems in place to ensure ongoing compliance. Each exception or observation is identified as an exception to a regulatory requirement (Regulatory), an exception to a BFGoodrich policy or procedure (Company Policy), or an observation with respect to die audit team's view of good health, safety, and environmental management practice (Good Management Practice). Arthir D Little ^GC nmd454?&ipL/ei 3 II. Audit Findings A. Overall Opinion On the basis of our review, the audit team believes that the health, safety, and environmental programs and practices that we reviewed generally meet applicable governmental and The BFGoodrich Company policies and procedures, except as noted below. This opinion is based upon our professionaljudgment and the application of established audit procedures. The individual areas where we found deficiencies in the health, safety, and environmental programs and practices are described in the following sections of this report B. Industrial Hygiene 1. Chemical Hygiene Plan (CHP) (Regulatory/Good Management Practice) During a review of the facility's Chemical Hygiene Plan and interviews with employees, we noted the following: a. The plan does not include provisions for supplying information to the physician and obtaining a written opinion from the physician. [29 CFR 1910.1450(e)(3)(vi) and (g)(3)-(4)] b. The plan does not specify the information that must be given to employees. [29 CFR 1910.1450(c)(3)(iv) and (f)(3)] c. The plan does not specifically address reproductive toxins (hazards), including those which are present at the facility, and how they will be handled. [29 CFR 1910.1450(e)(3)(viii)] d. Training required under the plan has not been implemented. [29 CFR 1910.1450(e)(3)(iv) and (f)(4)] e. The information placed on hood inspection cards is inconsistent with what is required in the plan. [Good Management Practice] f. Five out offive individual laboratories reviewed have not prepared standard operating procedures required by the plan. [Good Management Practice] g. The current Level A contractor training is not consistent with the training specified in the plan. [Good Management Practice] 2. Hazard Communication Program (Regulatory/Good Management Practice) During a review of the facility's hazard communication program, we noted the following: a. The facility does not maintain MSDSs for consumer products that are used in an industrial process. [29 CFR 1910.1200(g)(8)] b. The program does not identify a facility coordinator. [Good Management Practice] NGC 13216 Arthir D Little mwf.6547S.ipLSfi1 4