Document BRqdo610B2KENoL81LvpLX59L

u INTERNATIONAL TECHNOLOGY CORPORATION February 5, 1992 A Mr. Bruce Trego Safety Director Vista Chemical Company P.O. Box 91 New Highway 25 Aberdeen, Mississippi 39730-0091 Dear Mr. Trego: Please find enclosed the final copy of our trip report from the meeting we had with you and your colleagues at the Aberdeen Vista Chemical facility on July 30 regarding OSHA's proposed standards on process safety management and medical surveillance. We wish to thank you and your colleagues again for the time you spent with us and the timely manner in which you responded to our request for review of the draft site visit report. If you have any additional questions, please feel free to call me at (513)-782-4700. Sincerely, IT CORPORATION Maiy Beth Foerst Project Engineer Enclosure IT Environmental Programs, Inc. (Formerly PEI Associates, Inc.) 11499 Chester Road Cincinnati. Ohio 45246 Phone (513) 782-4700 FAX (513) 782-4807 VAB 0oo1166988 IT Environmental Programs, Inc. is a wholly owned subsidiary of International Technology Corporation A SITE SURVEY REPORT: CHARACTERIZATION OF PROCESS SAFETY MANAGEMENT AND MEDICAL SURVEILLANCE PROGRAMS OF VISTA CHEMICAL COMPANY, ABERDEEN, MISSISSIPPI (SIC 2821) DATE OF SURVEY JULY 30, 1991 Prepared by INTERNATIONAL TECHNOLOGY CORPORATION 11499 Chester Road Cincinnati, Ohio 45246 Contract No. J-9-F-0012 JTN 833002-1 Prepared for U.S. DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION OFFICE OF REGULATORY ANALYSIS WASHINGTON, D.C. 20210 September 1991 ` -t -ll ! -- n 'i pp'-" fi.r - > : 1.1p I lV-HP" 1 >:. > p ..iji .'j.ij. p. . VAB.0001166989 A TABLE OF CONTENTS Purpose of Survey Employer Representatives Contacted Survey Team Company Background Process Safety Management Program Medical Surveillance Program Completed Site Visit Questionnaire Appendix A - Pre-employment and periodic medical examinations performed at Vista Chemical Company 1 1 1 2 3 3 5 A-1 ii l*i -- .,h L^r. 1* *S. p* i-1*^ -*-IV*fPi|:<V |K*ll!"i i'**r|^ll *. i -*i-**M*rB-(flM i*>- VAB.0001166990 PURPOSE OF SURVEY On July 30, 1991, representatives of IT Corporation met with representatives of Vista Chemical Company, a major manufacturer of polyvinyl chloride resins (SIC 2821) at one of their manufacturing facilities in Aberdeen, Mississippi. The purpose of the meeting was to gather information on various aspects (current practices, costs, bene fits, etc.) of the company's process safety management (PSM) and medical surveil lance (MS) programs. These data will be used to obtain an understanding of the po tential impacts of the proposed Occupational Safety and Health Administration (OSHA) PSM standard (29 CFR 1910.119) and a proposed standard addressing medical sur veillance. EMPLOYER REPRESENTATIVES CONTACTED The following company representatives participated in the meeting to discuss the PSM and MS programs at the facility: Robert W. Seymour, Plant Manager Bruce L Trego, Safety Director Rendell Newton, Chief Process Engineer SURVEY TEAM The survey team consisted of two individuals from IT Corporation: E. Radha Krishnan, P.E., and Mary Beth Foerst. A VAB.0001166991 -r-- COMPANY BACKGROUND Vista Chemical Company's Aberdeen, Mississippi, plant is a major manufacturer of polyvinyl chloride resins (SIC 2821) and compounds that are used in a wide range of applications. The Aberdeen plant was built in 1963 by the Thompson Apex Compa ny and was acquired by Conoco Chemicals Company a year later. Conoco was pur chased by DuPont in 1981 and Vista was formed through a leveraged buyout in 1984. There are nine Vista Chemical locations throughout the U.S. The Aberdeen facility currently employs approximately 250 workers. Of these, approximately 170 are hourly employees. The facility operates 24 hours per day, utiliz ing 12-hour shifts. With respect to OSHA's data-gathering activities on the PSM and MS programs, Vista recently completed the Phase II PSM and MS questionnaire surveys for OSHA. The IT site visit was conducted to augment and elaborate on the information recently gathered by OSHA's contractor, KCA Research, Inc., through the questionnaire sur veys. Information gathered during the onsite visit and from the questionnaires strictly reflects the Vista era of the plant. Many of the procedures practiced during the DuPont/Conoco eras have been incorporated into the current operations, with some changes and additions by Vista. A = .............................- i P rf' . i J -L| .. ||. | |M., . '-H-* i"*-. -H i-H VAB.0001166992 A PROCESS SAFETY MANAGEMENT PROGRAM The formal Conoco PSM program was continued at the Vista Chemical Aber deen facility when Vista was formed in 1984. Types of hazard analyses performed at this facility include HAZOP, what-if, checklist, and failure modes and effects analysis (FM EA). A hazard analysis is performed on all new capital projects and is currently being done for existing plant operations. Several process changes have been made to enhance process safety in the plant. Vista is a member of the Chemical Manufac turers Association (CMA) and the International Loss Control Institute (ILCI). These associations provide safety information to their members, as well as universal safety concerns experienced by other companies. Vista also participates in CMA's Responsi ble Care Program. Vista has well-established and integrated PSM and MS programs. The pro grams are coordinated with the Plant Manager, Safety and Health personnel, Engineer ing, and the workers' union. Emergency response has been coordinated with the local fire department, which is kept up-to-date on the chemicals used at Vista. Em ployee participation is encouraged on safety teams at Vista Chemical. Additional information on the company's PSM program is provided on the completed site visit information form. MEDICAL SURVEILLANCE PROGRAM The medical surveillance program at Vista is under the direction of the Corpo rate Medical Director. A full-time Registered Nurse is located at the Aberdeen plant. The MS program was initiated prior to the 1984 formation of Vista and carried over as a Vista program. Currently, each prospective employee of the Vista Aberdeen plant is required to have a preplacement medical examination. Periodic medical examinations are offered to all employees at the plant. These include annual and interim examina tions. The purpose of the medical tests (other than being required by law) is to pro vide a baseline health examination for new employees and to identify health problems of occupational, as well as nonoccupational, origin. 3 VAB.0001166993 r-- . K. nj .L.L| n M.. ... . ,-j. .J .. ... . + . 4 I. I" -- .................... .-.-I-- -tv-r p p- -I Ip I -I.. . p.l-'fif-p-l 1*" -- Additional information on the company's MS program is provided on the com pleted site visit information form. A VI -II' I -h t VAB.0001166994 . ij.- . Site Visit Information form: Vista Chemical Company (SIC 2821) A 1. Employment History (Data from 1990 and every five years back as far as possible, or use what is available) Year Total Employment Production Employment Turnover rate 1990 1984 249 243 170 7.9% 168 1.8% 2. History of Medical Surveillance Program (If possible, identify separately pre-employment, pre-placement, periodic, etc. Data from 1990 and every five years back as far as possible or use what is available) Year Initiated: 1984 Reason for initiating program: To be aware of health problems associated with occupational exposure and to identify and assist employees with nonoccupational health problems, as well as to be in compliance with OSHA health standards. Year by year history: (Data may be obtained in format other than this one) Year Coverage 1984-90 Pre-employment exams 1988-90 Periodic exams 1988-90 Interim exams 1984-87 Periodic exams 1984-87 Interim exams 3. Program Records Tests See Appendix A See Appendix A See Appendix A See Appendix A See Appendix A Use of Data Baseline examination Identify any occupational illnesses Identify any occupational llnesses Identify any occupational llnesses Identify any occupational llnesses What methods of recordkeeping do you use for health and safety data? Vista maintains the records at the corporate office i^lHorizon^'exas. The records are kept at the Vista Corporate Medical Department on microfilm. Vista maintains the records from computer printouts and microfilm at the Cor porate Medical Department in Houston, Texas. Health Examinatics, Inc., gen erates and stores these records on computer. * . .. ,.-c-|-.b- h--i T 'I i "i lu" | p - r- t ..................................... -3 t>ti--i mi |i| h. VAB.0001166995 Do you analyze your data for trends? Yes If so, how? The medical data is analyzed and compared to a reference population of over 50,OCX) workers corresponding to employee age and sex. Any abnormal conditions are fully investigated by the Safety Director and other appropriate plant personnel. How is employee confidentiality maintained? The plant nurse and the Corporate Medical Director maintain all employee medical records. 4. Health Conditions Found by Medical Surveillance Program (Data from 1990 and every five years back as far as possible, or use what is available) Type of Year Number Condition Cause Action No trend detectable. 5. Workplace Monitoring (Chemicals, other hazardous substances, ergonomic stress conditions and other physical hazards such as noise, radiation, etc.) Chemicals and Hazards Present Hazard/ Chemical Number of Employees Exposed Controls (Including Respirators) Frequency of Monitoring Typical Exposure Levels Vinyl chloride 134 Ammonia Chlorine Lead 7 5 127 Noise 237 Engineering controls 1000 samples/year Avg. 1% over expo sure/year Engineering controls Not available Not available Engineering controls Not available Not available Engineering controls 250 samples/year Avg. 1% over expo sure/year Shift rotation, hear Periodic evaluation Not available ing protection, by outside consultant equipment modifications A 6 VAB.0001166996 6. Changes Attributed To Medical Surveillance Program Non-Quantitative Analysis: Please indicate what changes (if any) that your company has realized as a result of implementing your medical surveillance program. Employees have a greater health awareness and are taking the Initiative for improving their health. Quantitative Analysis: Has your company noticed any changes in any of the following as a result of implementing your medical surveillance program? Illnesses, Injuries, Fatalities - Injuries/Illnesses decreased. Employees are detecting health problems earlier and are improving their overall wellness. Worker Comp Claims - Data not available. Insurance Costs - Data not available. Absenteeism - Data not available. Turnover - Data not available. Productivity - If yes, how is this measured? - Data not available. Legal Expenses - Data not available. Safety Awareness - Data not available. Other - Health care costs have decreased. (Please provide data as available) 7. OSHA 200 Information (For employees under MS only, if possible. Primary focus: illnesses. Injuries, if ergonomic related. Data from 1990 and every five years back as far as possible, or use what is available) ..................... r -.......................-- t ,-v-p|- *: sj11.1 k _ rip- I irm* H : : i. i i.,. Ji -i s sj . - i . l 1 I :+t L-1 I, - ; . ri; i ?i t ................. :h i+'k i Hi r . m- K' * + 1*. I ** VAB.0001166997 Year LWD Cases NLWD Cases The Aberdeen facility has experienced 12 years without a lost workday case. Recently, Vista has also begun tracking injuries to any on-site contractors. 8. Worker Compensation Cost & Claim Records (Data from 1990 and every five years back as far as possible, or use what is available) Year Employees Under MS Employees not Under MS 1990 1986 9 8 Not available Not available The number of worker's comp cases have remained steady at approximately 8 per year since 1984. All employees are offered physical examinations annual ly. 9. Insurance Costs Did you coordinate or use any criteria in setting up your medical surveil lance (MS) program with your health insurance carrier? Yes. If yes, please describe. Vista utilizes several insurance carriers. Representatives of the insurance company audit the plant for safety, and industrial hygiene issues. Findings are written up as action items and are sent to the General Manager, who monitors the status of the completion of the items. Have your insurance rates changed because of: 1) Your medical surveillance program? 2) Your process safety management program? The lower insurance rates are not directly attributable to either program, but is most likely a combination of both programs. If so, what were the changes? The insurance costs for the plant have decreased. A ^.-1. ... . . .-I| - .v r . , | ................................. 1 i 1 ! I I "! M =,!-*! :s I 7- T4T H|. '"h mr:' q.ftHH-i-nf .................... - VAB.0001166998 10. Management of PSM Chemical Hazards Do you manufacture, process, or use any of the chemicals on the at tached list above the threshold quantity indicated? (Appendix A PSM list of highly hazardous chemicals to be attached) Chlorine Do you manufacture, process, or use any other toxic, flammable, or explosive chemicals at this facility? Yes. if yes, please list: Anhydrous ammonia Vinyl chloride Propane Lead compounds Gasoline 11. History of Process Safety Management Program Do you have a program in place for minimizing the consequences of catastrophic releases of toxic, flammable or explosive chemicals? Yes. If yes, please describe. Safety audits, industrial hygiene monitoring, and HazOp studies are used to identify possible process hazards. Safety audits are performed by both plant personnel and outside consultants. Monitoring for chemical releases is per formed on an as-needed basis. Daily tests of the ventilation sytem in the lead dumping area are performed by the operators and periodically rechecked by safety personnel. HazOp studies are performed for all newly installed capital projects and have been completed for at least one-third of the existing facili ties. Formalized HazOp training of corporate and plant engineers has been performed by an outside consultant. Maintenance and operating personnel are also involved in the HazOp studies for utilization of their knowledge of the plant equipment. When was this program established? Prior to 1984 by the previous owner. A i'.-'- rpt i. -hhi -->- i rs l-l ' lr i i . -r+ I -Vm. . ........ - , ^ ! M i I J : -I : i Tl ig--" ' .rl. .Hi Pl -I I- 1- -.T-Miy H'M- fyt.--MF.-F->--- h-l-il - VAB.0001166999 Do you have a program in place dealing with chemicals, other hazardous substances, ergonomic stress conditions, and other physical hazards such as noise, radiation, etc.? Yes. If yes, please describe. A formalized ergonomic program is not in place because there is very little repetitive motion or lifting at this facility. Ergonomic improvements have been made as a result of job analyses. One such case involved the repetitive stack ing of bags onto pallets. A pallet lift was installed to eliminate the need for operators to bend over to stack the bags of plastic pellets. An outside con sultant has performed noise monitoring and some areas of the plant have been designated as a hearing protection area. Equipment that generates noise above the threshold limits is analyzed each year for noise level. Abnor mal levels would warrant maintenance of the equipment. When was this program established? Prior to 1984 by the previous owner. 12. Process Safety Management as Part of Hazard Management What activities/procedures are incorporated into your process safety management program (e.g., hazard analyses, safety audits, etc.)? Safety audits, industrial hygiene monitoring, safety committees, HazOp studies, and use of outside consultants to audit processes and sponsor training pro grams, are all integrated into the PSM program. All employees are initially trained on their specific jobs. Does your facility maintain records of process hazards identified from your process safety management program? Yes. What method of recordkeeping do you use for your process safety management program? The records are kept in the form of safety audit reports, monthly safety minutes, accident reports, and industrial hygiene measurements. Each department keeps it own records for projects. *- P I- V '.4 Ml `-'I- ' '-S I !i I - - -I -f |i iHB : Inip1 T-f- VAB.0001167000 Who in your company is responsible for your process safety management program? The General Manager, Plant Manager, Safety Director, Chief Process Engi neer, and Operating Department Superintendent. How much time per week does this individual devote to this program? The Safety Director has three full-time assistants. There is one full-time environmental person and one that assists part-time to this program. A typical HazOp, study for a new process (e.g., 3 to 4 P&IDs) can be completed by four people in ~2 days. The time required to do HAZOPs in existing units will be significantly higher. 13. Major Changes in Facility (Major renovation, automation, product mix changes. Data from 1990 and every five years back as far as possible, or use what is available) Year Type of Change (Describe) Reason 1989 New wheel chock for vinyl chloride monomer rail car An accident occurred in the past where the rail car brake failed. Flexible hoses attached to the rail car broke, releasing vinyl chloride. Since then a new wheel chock has been designed and used to prevent reoccurence of this type of acci dent. A new project to install an auto matic chemical transfer shutoff system at the railcar is currently being considered. 1991 I nstallation of a new incineration unit More efficient incineration of vapors which provides a decreased chance for exposure. 1989 Elimination of hot caustic in wastewater treatment system Eliminate exposure to caustic. 14. Process Changes Resulting from Process Safety Management Program Would you provide us with details on examples of process changes that have resulted in increased safety for a specific process or operation at your facility? Please attach copies of any available papers or reports. Several changes have been made at Vista Chemicals to increase safety. A VAB.0001167001 ' i-t H  A bleeder plugging program was instigated to reduce chemical releases from open-ended lines. A line opening procedure was developed to prevent operators from being sprayed by chemicals while opening lines. Centralized control rooms were installed for the remote control of critical process equipment. Batch sizes were modified so that an entire bag of pigment is used in a batch to reduce exposure to lead during bag handling. A metering system for addition of pigments is being installed. The system to add inhibitor in the case of a runaway reaction has been automated for the remote "killing'* of a reaction. A propane unit has been installed to be used as boiler fuel in case of the loss of natural gas. A fire and leak detection system and deluge system were added to the propane unit in 1990. Have any process modifications led to changes in any of the following? Chemical release - Decreased. Incidents - Decreased. Explosions - No explosions have occurred at this facility. Fires - Decreased. Product quality - increased. n Equipment downtime - Decreased. p Employee exposures - Decreased. Please provide any quantitative analysis you may have on the changes which occurred. 15. Administration/Cost A ......... -.1+'-. r.L-pUr |- 1 - h .t- 'i 'Tti nr-.:-:-- nr.'.--i . k* i*r r .( ii * 'l|M P :!1. 1 'Iff*" I VAB.0001167002 Would you provide us with the costs and benefits associated with implementation of these changes? It is estimated that the cost to update the process and instrumentation diagrams (P&IDs) for the processes at this facility will be $150,OCX). Is your process safety management program integrated/coordinated with your medical surveillance program? Yes. If yes, how does this occur? See answer below. Is your process safety management program integrated/coordinated with any other health and/or safety program such as exposure monitoring? Yes. If yes, list program(s): Industrial hygiene monitoring Safety audits Accident reports How does this occur? The PSM program is integrated by communication through the Plant Manager. Programs such as industrial hygiene monitoring and safety audits are used to identify potential problems. A Central Safety Committee integrates all of the programs through direct communication of appropriate plant personnel. The General Manager communicates all LWD accidents and other safety concerns to all of the Vista Chemical plants. A Joint Safety Committee is sponsored by the worker's union and the company. A Safety Director is located at each plant and is responsible for implementing company-wide changes to improve safety. A '1 i-r.- - : -- .............................................. ; ^ j. | P P I" ' I 11 ' : I lr' lifSfcL- J. .. VAB.0001167003 16. Changes Attributed to Process Safety Management Program Non-Quantitative Analysis: Please indicate what changes (if any) that your company has realized as a result of implementing your process safety management program. Increased safety awareness among plant personnel. Quantitative Analysis: Has your company noticed any changes in any of the following as a result of implementing your process safety management program? Illnesses, Injuries, Fatalities - Reduced exposure to vinyl chloride mono mer through reduced emissions. Changes were made to operating proce dures and equipment to achieve a substantial reduction in emissions. Worker Comp Claims - Reduced by more than 50 percent. Absenteeism - Not applicable. Turnover - Not applicable. Productivity - If yes, how is this measured? Yes. Decrease in equip ment downtime allows for more time for production. Legal Expenses - Data not available. Safety Awareness - Increased. Other - None. (Please provide data as available) A -r r \>` .k; h ; in .p./l ,/i. VAB.0001167004 n- . A APPENDIX A PRE-EMPLOYMENT AND PERIODIC MEDICAL EXAMINATIONS PERFORMED AT VISTA CHEMICAL COMPANY . r*-- ............................ i i - : - i j i r- -*. hi 1= h 1 -<,r VAB.0001167005 AmcnSHT A Medical History Hematology with Differential Urinalysis SMAC Chest Xray EKG Spirometry Audiometry Drug Screen Physical Examination A J . - i -i F - + -U.-. > .r s 4fnrH". J-- -i -li-' M MIL m 4^1 J-i-ir S-i w -u-i--ar-p | | i V *n 1 '! :> " : r---1 im1!' f '*i f i ip . iPT |-| .'|fi y|>a fr *............. #-J1- ;r . w -I -l . if. fn-i r,.i VAB.0001167006 ATTACHMENT B Medical History Anthropometry Vision Tonometry Audiometry Spirometry Chest xray EKG Hematology with Differential Urinalysis SMAC Hemoccult Blood Lead for Lab, Compound, and Maintenance I i % \ A t ... - H |1. f + - -t ... - -r- r >..i k nv > .' . f\ "i'Mi.t1 ' " 'ir ^' *- *- -i ,+ VTIJ-X" MIM.' rfiT: i k-4F-a-9- VAB.0001167007 ATTAOtlKIIT C Medical History Comparative Data Hematology with Differential Urinalysis sme Blood Lead for Compound, Lab, and Maintenance A VAB.0001167008 ATTAOtlKHT D Medical History Trend Analysis Anthropometry Vision Tonometry Audiometry Spirometry Chest Xray BKG Hematology with Differential Urinalysis SMAC Hemoccult Lipid Profile Blood Lead for Compound, Lab, and Maintenance A t frhr x: : 1 -j . . pi -4 Ifpi.n- f .4,. | ill -1^ I f | ! i ' VAB.0001167009 v'l'ir-" i ht. ATTACttffNT 8 Medical History Trend Analysis Hematology with Differential Urinalysis SMAC Blood Lead for Compound, Lab, and Maintenance AJ H . -I P ii ji n.--i.' in- I -.ft- r VAB.0001167010