Document O3m4jzk43O0g8nXGbELg0o3Lp

T. MICHAEL JONES & ASSOCIATES Regulatory Management Consultants______________ P.O. BOX 890482 HOUSTON, TEXAS 77289-0482 (713) 286-8001 Mr. Mike Guyer Plant Manager - Henry The GEON Company RR#1 Box 15 Henry Dlinois 61537 October 12, 1994 Dear Mike, It was certainly a pleasure to visit the Henry plant and hopefully to provide a useful service that will add value to the organization. I have enclosed one draft copy of the PSM assessment narrative for your review. Please review this document for accuracy and completeness as discussed during the wrap-up meeting Make comments in red as necessary and return to my attention in Houston, Texas. I will make final draft, bind and supply copies per your direction. Feel free to call for any clarification that may be necessary. I will be in the Far East from October 19 through October 30. I can be reached through my office voice mail so call if I can be of help. 1 will get back to you as soon as possible. Thanks for the good cooperation and I look forward to future services that I may provide. T% 1 cc: ENVIRONMENT HEALTH SAFETY NGC 12320 PROCESS SAFETY MANAGEMENT ASSESSMENT HENRY PLANT OCTOBER 3 THRU 7,1994 The purpose for conducting this review was to audit the requirements of OSHA's 1910.119 Process Safety Management ofHighly Hazardous Chemicals standard respective to the implementation status at the Henry facility. Through this process, opportunities for improvement and recognition of exceptional safety systems already implemented to address the PSM standard would be achieved. An assessment of the implementation status of each element of the 1910.119 standard is included in this document, The implementation status corresponds to the following classification and is based on findings during the assessment process. Stage I No action Stage H Evaluating plant practices against system requirements Stage III Developing plans to implement system requirements Stage IV Implementing action plans Stage V System in place Stage VI Improvement reviewed and reaffirmed this year A narrative summary for each element of the process safety management standard is included in order to provide a rationale for the status ofeach element. The Geon Company and the Henry, Illinois plant were extremely cooperative during this assessment process. NGC 12321 PROCESS SAFETY MANAGEMENT Facility: Review Date: Reviewer: Henrv Illinois October 3 thru 7 1994 T. Michael Jones IMPLEMENTATION STATUS PSM ELEMENT 1 II III IV V VI Application Employee Participation Process Safety Information Process Hazard Analysis Operating Procedures Training Contractors Pre Start-Up Safety Review Mechanical Integrity Hot Work Permit Management of Change Incident Investigation Emergency Planning/Response Compliance Audit Trade Secret X X y X X X X * * X X X X X X HIV BiAl.t*/. IMP. IH REAPFifc. ac "Safety - A Continuous improvement Process" TM^hiAN.tO04 3 NGC 12322 is an PROCESS SAFETY MANAGEMENT ASSESSMENT SUMMARY Application: 1910.119 (a) Documentation of the rationale for including a facility in the PSM program is oftentimes overlooked. Presently vinyl chloride monomer, because of its flammability, is the only material used in the process which causes the Henry plant to be included in the 1910.119 PSM program The inventory amount ofthis material should be listed to include storage in spheres, railroad cars, processing tankage and process piping under normal operating parameters. The facility should graphically illustrate clear delineation of the PSM area from all other parts ofthe facility and document this drawing in the PSM file. There was sufficient information available to assemble the application file however, it was cumbersome to discover documentation and records. In order to enhance the retrieval process it is recommended that a central filing system be established containing appropriate information for each element of the process safety management standard. This may also be achieved by establishing a index system which identifies the location of all the various components ofthe PSM standard and the person(s) responsible for same. ( Opportunity Nos. A9401, A9402 ) Employee Participation: 1910.119(c) The standard requires an employer to involve its employees at an elemental level respective to the PSM program. Minimum requirements of an employee participation program must include a written plan of action for implementing employee consultation on the development of process hazard analyses and other elements of process hazard management contained in the 1910.119 standard. It should be noted that employers shall make available all information required to develop this standard. The Henry plant has in place an employee safety committee comprised of representation from each discipline within the organization. This forum will help to facilitate information up and down the organization and provides an opportunity for employees to participate in the day- to-day safety effort. ( Opportunity No. EP9403 ) Process Safety Information: 1910.119 (d ) Complete and accurate information relating to the process is essential for an effective process safety management program and for conducting process hazard analyses. In order to comply with paragraph (e) (1) of the standard the employer is required to compile 3 NGC 12323 LJ U written process safety information on process chemicals, process technology and process equipment before conducting any process hazard analysis. Material safety data sheets on vinyl chloride monomer will satisfy paragraph (d) (1). It will be necessary to assemble and in some cases develop the following information to comply with paragraph (d) (2). => Block flow diagram for suspension and dispersion resins => Process chemistry => Maximum intended inventories => Safe upper and lower limits (temperatures, pressures, flow, etc. ) => Evaluation ofconsequences of deviation( including safety and health of employees) The plant is thought to be dealing with consequences of deviation through its operating procedures developed by WPS. This should be verified at the first opportunity as discussed during the wrap-up meeting 7 October. The Henry plant recognizes the importance for having this type ofprocess data and in fact has most of the information. Collecting this information in a retrievable format will insure that complete and accurate data is available. ( Opportunity No. PSI9404 ) Process Hazard Analysis: (1910.119 (e) Employers are required with employee participation to develop a thorough, orderly, systematic approach for identifying, evaluating and controlling processes involved in highly hazardous chemicals. The Henry plant needs to identify areas of the plant where process hazard analyses must be achieved based on the process material involved. (Opportunity No. PHA 9405 ) There are six specific sections of the PHA which needs to be addressed and are listed below. 1. Setting priorities: Prioritize and schedule identified PHA areas based on; 1) extent of the process hazard, 2) number of affected employees including BFG, 3) age of the process, 4) operating histoiy.( Opportunity No. PHA 9406) 2. Appropriate methodology: Document the hazard evaluation method the plant intends to utilize in accomplishing its PHA requirements.(Opportunity No. 9406) When conducting PHA's on the process covered by the standard it is required to address facility sitings and human factors. Employee work stations, valve location, engress/egress from units, lighting are some examples of human factors to be considered. Location of new construction such as tankage, control rooms, offices, prevailing wind directions are considerations respective to plant or equipment locations (siting). Documentation that these, two elements have been considered is required by the standard. ( Opportunity No. PHA 9407) ........... .... .......~ "7 4 NGC 12324 Q. 3. Disposition and Resolution of Team Fiqdfotgs^ ATormal closure and/or reason for action must be documented. The plant needs to assure that a system exists to promptly address team findings and recommendations to include documentation and communications to all affected plant and contract personnel^ Opportunity No. PHA 9408) 4. Process Hazard Analyses Will Address: Previous process incidents (accidents, releases, spill, fires, explosions, etc.) at the facility and posQe^ther .similar Geon operations can provide experience yielding opportunities to prevent recurrence. The Company culture of sharing this type information will provide dividends in this area. In order to comply with this section ofthe standard this historical data must become part ofthe information considered during PHA's. ( Opportunity No. PHA9409 ) 5. Process Hazard Analyses Team: Team membership should include experience from the work force as required to address the task at hand. This team must include experience from plant and process engineering, operating personnel, safety and environmental as appropriate and at least one person skilled in the HAZOP methodology being utilized. It is recommended as PHA team members are assembled that a biographical profile be completed on each team member and included as part of that specific PHA file. ( Opportunity No. PHA 9410 ) 6. Engineering/Code Standards: It is recommended that as the PHA's are being conducted that applicable regulations and codes that are being considered during the evaluation process be identified and included as part of the PSM documentation ie., ASME, API, ASTM, ANSI, NEC, or internal engineering design standards for piping specifications, materials for construction and other design parameters. ( Opportunity No. PHA9411 ) Operating Procedures: 1910.119(f) The requirement of this paragraph is for the employer to provide clear instructions for safely conducting activities involved in the covered process consistent with the process safety information assembled by the Henry plant. The standard requires that the operating procedures be reviewed as often as necessary to assure that they reflect current operating practice and technology. Annually, the procedures must be certified that they are current and accurate. ( Opportunity No. OP9412 ) Note: This service may be provided by WPS. Operating procedures must include operating limits that outline consequences of process deviation and steps to correct or avoid these deviations. Discuss this PSM section, (1910.119 (f)(lXii), with WPS to assure that this requirement is being achieved. ( Opportunity No. OP9413 ) The plant should be commended on the fine effort put forth in rewriting the plants process operating procedures. The procedure books in the field are user friendly and most important are being utilized by the operating personnel in the units as verified through employee interviews. 5 Training: 191 \9<&) The purpose of this paragraph is to help employees understand the nature and causes of problems arising from process operations. Training will increase an employees awareness with respect to the hazards particular to a process. An effective training program can significantly reduce the number and severity of incidents arising from process operations and can be instrumental in preventing small problems from becoming or leading to catastrophic events. Minimum training programs must include initial training, refresher training and documentation. Initial training has been achieved and is well documented. The plant has gone the extra mile in that actual certification under the WPS training procedures has been achieved rather than simply "grandfather" existing operators. The plant is commended for this effort. Refresher training is presently within the three year cycle as required by the standard. The plant is reminded that their obligation as an employer under the standard is to consult with employees in the operating process to determine the appropriate frequency for refresher training. ( Opportunity No. 9414 ) Contractors: 1910.119 (h) The intent ofthis paragraph is to require employers who use contractors to perform work in and around or near processes that involve highly hazardous chemicals to establish a screening process so that they retain and use contractors who can accomplish an assigned task without compromising the safety and health of employees at the Henry plant. The contractor as an employer also has responsibilities and must assure their employees are trained on performing the job at hand safety. Additionally the contractor must communicate to their employees the hazards of the job and understand the provisions of the owners emergency response plan. The Geon plant at Henry is doing a good job handling contractors. A three-hour contractor training program was attended involving several contractors doing different jobs in the plant and instructions and evaluations were very good. Since the Geon Company is now a separate business it is recommended that Geon files for contractor questionnaire, performance evaluations, training documentation, contractor's verification of training and etc. be established beginning January 1, 1995. (Opportunity No. C9415 ) 6 *GC 12326 Pre-Startup Safety Revj \\ New facilities and modified facilities that necessitate a change to the plant's process safety information dictates certain considerations before highly hazardous chemicals are introduced into the process. These requirements include a pre-startup review to confirm that the following actions have been addressed. 1. Construction and equipment is in accordance with design and specifications. 2. Safety, operating, maintenance and emergency procedures are in place and are adequate. 3. A process hazard analysis has been performed and all recommendations have been addressed and communicated to appropriate personnel 4. Management ofchange and training ofeach involved employee/contractor in the process has been completed. Although pre-startup safety reviews have been routinely achieved at this facility for some time and documentation is in place. There is a need to develop a check list to verify that the four items listed in the paragraph above takes place prior to introduction of highly hazardous chemicals to the process. ( Opportunity No. PSSR9416 ) Mechanical Integrity: 1910.119 (j) The mechanical integrity section of the standard establishes requirements to assure that equipment used to process, store, or handle highly hazardous chemicals is designed, constructed, installed and properly maintained in order to minimize the risk of release of the chemicaL Elements of a mechanical integrity program includes the identification and categorization of equipment and instrumentation, development of written maintenance procedures, training for process maintenance activities, inspection and testing, correction of deficiencies in equipment that are outside acceptable limits defined by the process safety information and development of a quality assurance program. The plant needs to develop its own written mechanical integrity procedure to comply with the PSM standard. During the assessment it was noted that many of the requirements of the PSM mechanical integrity paragraph were being addressed. However, a procedure must be developed to assure that all element of this critically important section of the standard is achieved and documented. ( Opportunity No. MI9417 ) One specific consideration which needs to be emphasized is to carefully and completely document each inspection and test. There is no doubt that the activity is being carried out but there is an opportunity to improve the system with good documentation. ( Opportunity No. M19418 ) 7 NGC 12327 Employers must control, in a consistent manner, non-routine work in the PSM areas covered by this standard. Specifically this paragraph is concerned about permitting hot work operations associated with welding and cutting in highly hazardous chemical process areas. Minimum requirements to comply with this section include meeting the requirements of OSHA's 1910.252 (a). Hot work is tightly controlled in this plant as expected. Hot work for category I areas are all pre planned. Good contractor understanding is being achieved evidenced by interviews. Disciplinary action for failure to follow plant hot work procedures is on record. There are no recommendations thought necessary at this time. Management of Change: 1910.119 (1) Careful consideration of all modifications to procedures, raw materials and process conditions other than ``replacement in kind" must be controlled by identifying and reviewing prior to implementing a change. The Henry plant needs to develop and implement its own management of change procedure to address the following parameters ( Opportunity No. MOC9419 ) 1. Technical basis for proposed change. 2. Impact of change on safety and health of employees. 3. Modifications to the operating procedures. 4 Necessary time period for the chance. 5. Authorization requirements for change. A key consideration of the M.O.C. policy is to provide communication to all affected Geon and contract personnel and to make certain that all impacted procedures, of any kind, are updated appropriately. ( Opportunity No. MOC9420 ) Incident Investigation: 1910.119 (m) Every incident that occurs in the plant that did or could have resulted in a catastrophic release of a highly hazardous chemical in the work place must be investigated. The plant's culture is to report any incident with potential. Root cause analysis to pin point why incidents occur is taking place. The plant needs to develop a system to document closure relating to incident investigation recommendations/corrective actions and the same information should become part of the PSM file if the incident occurs in a PSM area. (Opportunity No. II9421) 8 NGC 12328 Emergency Planning and Respon This paragraph requires employers to address what action employees are to take when there is an accidental release of a highly hazardous chemical. The plant has an adequate emergency response plan. In-house personnel are trained to handle fires, spills, and release scenarios. The plant has a limited number of response personnel ( including BFG ) to manually intervene in a large fire situation. Careful plans should be developed as pre-fire \ "<? fighting action to be implemented based on the limited personnel to respond. There is one area that will enhance the emergency response plan and that is to illustrate areas at which information concerning an emergency can be obtained and where assembly points are located if the plant is evacuated. These maps are to be placed in high traffic areas for maximum visibility. ( Opportunity No.EPR9422 ) " Compliance Audits: 1910.119 (o) Employers are required to audit the effectiveness of their PSM program in order to identify improvement opportunities and too take appropriate corrective action to resolve deficiencies. Minimum requirements include: 1) Audit at least every three years. 2) Maintain at least the last two audits. 3) Track to completion the audit findings and document the closure action. Trade Secrets: 1910.119 (p) This paragraph requires employers to provide all information necessary to comply with personnel developing section (d) process safety information,(e) process hazard analysis, (f) operating procedures,(u) emergency planning and response and (o) compliance audits without regards to possible trade secrets. The one recommendation thought to be in order would be to develop a secrecy agreement document to be signed by specific contract employees that work in sensitive areas ofthe Henry plant. ( Opportunity No. TS9423 ) 9 NGC 12329 Opportunities for Improv< Henry Piant^ A9401 Develop a central filing system for all PSM information. A9402 Graphically illustrate the plant's PSM areas and list VCM storage capacity complete with locations. EP9403 Develop a written GEON employee participation procedure to involve employees in the development ofPHA's and all other elements ofthe 1910.119 standard. PSI9404 Assemble all required process safety information in a central file system or index to identify where data is located and person responsible for same. PHA9405 Identify and document areas ofthe plant where PHA's (HAZOP) must be achieved. PHA9406 Prioritize and schedule identified PHA's to meet internal GEON requirements. PHA9406 Document preferred method(s) for hazard evaluation at Henry and insure appropriate personnel are trained in the methodology(s). PHA9407 Provide documentation that PHA's address human factors and facility siting. PHA9408 Provide a system to address PHA recommendations in a timely manner including communication to impacted personnel PHA9409 Historical data (previous incidents) must be considered during PHA's. Document that this information is utilized and make part of each PHA file when available. PHA9410 Develop biographical profiles on each HAZOP team member. Include this information in the PHA file. PHA9411 Include in PHA file documentation the specific regulations or codes being considered while conducting PHA's. OP9412 To comply with paragraph (f) (3) of the standard the plant needs to annually certify that operating procedures in the PSM area are current and accurate. OP9413 Review with WPS to assure they have addressed operating limits that outline consequences ofprocess deviation and steps to correct or avoid deviations. T9414 Consult with employee in the operating process to determine the appropriate C9415 frequency for refresher training. Establish GEON files for contractor safety information to include reasons for selection, training documentation, contractor's verification oftraining, selection process, performance evaluation etc. PSSR9416 Develop a check list for conducting pre-startup reviews to address paragraph (i) (2) ofthe standard. MI9417 Develop a written mechanical integrity procedure to comply with the standard. MI9418 Provide documentation of each inspection and test required by the standard. MOC9419 Develop and implement a GEON management of change procedure to comply with the standard. MOC9420 Insure a system exists to address communication issues. All impacted employees must be advised of changes. NOC 12330 V\\II^21 &- Develop a system to track to closure ail incidents which require investigation in a PSM area. EPR9422 Provide evacuation orientation maps to clearly indicate safe assembly and/or evacuation routes. Post in high traffic areas. TS9423 Develop a secrecy agreement for contractors who work in sensitive areas of the plant. NGC 12331 ASSESSMENT REPORT PROCESS SAFETY MANAGEMENT OF HIGHLY HAZARDOUS CHEMICALS 29 CFR 1910.119 FOR HENRY PVC PLANT HENRY, ILLINOIS Auditor Thomas M. Jones October 3 through 7, 1994 Prepared By T.Michael Jones & Associates P. O. Box 890482 Houston, Texas PROCESS SAFETY MANAGEMENT ASSESSMENT Henry PVC Plant October 3 through 7, 1994 The purpose for conducting this review was to audit the requirements of OSHA's 1910.119 Process Safety Management of Highly Hazardous Chemicals standard respective to the implementation status at the Henry facility. Through this process, opportunities for improvement and recognition of exceptional safety systems already implemented to address the PSM standard would be achieved. An assessment of the implementation status for each element of the 1910.119 standard is included in this document. The implementation status corresponds to the ,, following classification and is based on findings during the assessment process. Stage I: No action Stage II: Evaluating plant practices against system requirements Stage III: Developing plans to implement system requirements Stage IV; Implementing action plans Stage V: System in place Stage VI: Improvement reviewed and reaffirmed this year A narrative summary for each element of the process safety management standard is included in order to provide a rationale for the status of each element. The GEON Company and the Henry, Illinois Plant were extremely cooperative during this assessment process. fGC 12333 Process Safety Management Assessment Henry Plant Page 2, * ' * ' 'i PROCESS SAFETY MANAGEMENT | Facility: Review Date: Reviewer: .HENRY ILLINOIS____ October 3 through 7. 1994 T. Michael Jones_____ PSM ELEMENT Application Employee Participation Process Safety Information Process Hazard Analysis Operating Procedures Training contractors Pre Start-Up Safety Review Mechanical Integrity Hot Work Permit Management of Change Incident Investigation Emergency Planning/Response Compliance Audit Trade Secret IMPLEMENTATION STATUS I II III IV V VI X X X X X X X X X X X X X X X NA EVAL DEV IMP IN REAFF1R PLC TMJ-JAN.1804 "Safety A Continuous Improvement Processu NGC 12334 Process Safety Management Assessment Henry Plant Page'3 PROCESS SAFETY MANAGEMENT ASSESSMENT SUMMARY Application: 1910.119(a) Documentation of the rationale for including a facility in the PSM program is oftentirries overlooked. Presently vinyl chloride monomer, because of its flammability, is the 6nly material used in the process which causes the Henry Plant to be included in the 1910.119 PMS program. The inventory amount of this material should be listed to include storage in spheres, railroad cars, processing tankage and process piping under normal operating parameters. The facility should graphically illustrate clear delineation of the PSM area from all other parts of the facility and document this drawing in the PSM file. There was sufficient information available to assemble the application file however, it was cumbersome to discover documentation and records. In order to enhance the retrieval process, it is recommended that a central filing system be established containing appropriate information for each element of the process safety management standard. This may also be achieved by establishing an index system which identifies the location of all the various components of the PSM standard and the person(s) responsible for same. (Opportunity Nos. A9401, A9402) Employee Participation: 1910.119(c) The standard requires an employer to involve its employees at an elemental level respective to the PSM program. Minimum requirements of an employee participation program must include a written plan of action for implementing employee consultation on the development of process hazard analyses and other elements of process hazard management contained in the 1910.119 standard. It should be noted that employers shall make available all information required to develop this standard. The Henry Plant has in place an employee safety committee comprised of representation from each discipline within the organization. This forum will help to facilitate information up and down the organization and provides an opportunity for employees to participate in the day-to-day safety effort (Opportunity No. EP9403) NGC 12335 Process Safety Management Assessment Henry Plant Process Safety Information: 1910.119(d) Complete and accurate information relating to the process is essential for an effective process safety management program and for conducting process hazard analyses. In order to comply with paragraph (e)(1) of the standard, the employer is required to ; compile written process safety information on process chemicals, process technology and process equipment before conducting any process hazard analysis. Material safety data sheets on vinyl chloride monomer will satisfy paragraph (d)(1). It will be necessary to assemble and in some cases develop the following information to comply with paragraph (d)(2). ^ Block flow diagram for suspension and dispersion resins Process chemistry ' Maximum intended inventories , Safe upper and lower limits (temperatures, pressures, flow, etc.) Evaluation of consequences of deviation (including safety and health of employees) The plant is thought to be dealing with consequences of deviation through its operating procedures developed by WPS. This will be verified by WPS during their retainer visit in November} December, 1994. The Henry Plant recognizes the importance for having this type of process data and in fact has most of the information. Collecting this information in a retrievable format will insure that complete and accurate data is available. (Opportunity No. PSI9404) Process Hazard Analysis: 1910.119(e) Employers are required with employee participation to develop a thorough, orderly, systematic approach for identifying, evaluating and controlling processes involved in. highly hazardous chemicals. The Henry Plant needs to identify areas of the plant where process hazard analyses must be achieved based on the process material involved. (Opportunity No. PHA9405) There are six specific sections of the PHA which needs to be addressed and are listed below. 1. Setting Priorities: Prioritize and schedule identified PHA areas based on; 1) extent of the process hazard, 2) number of affected employees including BFG, 3) age of the process, 4) operating history. (Opportunity No. PHA 9406) NGC 12336 Process Safety Management assessment Henry Plant Pages c 2. Appropriate Methodology: Documentthehazardevaluationmethodtheplant intends to utilize in accomplishing its PHA requirements. (Opportunity No. PHA9407) When conducting PHA's on the process covered by the standard, A is required to address facility sitings and human factors. Employee work stations, valve location, ingress/egress from units, lighting are some examples of human factors to be considered. Location of new construction, such as tankage, control rooms, offices and prevailing wind directions, are ; considerations respective to plant or equipment locations (siting). Documentation that these two elements have been considered is required by jthe standard. (Opportunity No. PHA9408) 3. Disposition / Handling Team Findings: A formal closure and/or reasons for action must be documented. The plant needs to assure a system exists to promptly address team findings and recommendations to include documentation :;.:-/arid communications to all affected plant and contract personnel. (Opportunity. No. PHA 9409) ^; . 4. Process Hazard Analysis Will Address: Previous process related incidents (accidents, releases, spilt, fires, explosions, etc.) at the facility and other similar GEON operations can provide experience yielding opportunities to prevent recurrence. The company culture of sharing this type information will provide dividends in this area. In order to comply with this section of the standard, this ^historical data must become part of the information considered during PHA's. (Opportunity No. PHA9410) 5. 'Process Hazard Analysis Team: Team membership should include experience from the work force as required to address the task at hand. This team must include experience from plant and process engineering, operating personnel, safety and environmental, as appropriate, and at least one person skilled in the HAZOP methodology being utilized. It is recommended as PHA team members are assembled that a biographical profile (Figure No. 1) be completed on each team member and included as part of that specific PHA filed. (Opportunity No. PHA9411) 6. Engineering / Code Standards: it is recommended as the PHA's are being conducted that applicable standards and codes which are being considered during the evaluation process be identified as part of the PSM documentation i.e,, ASME, API, ANSI, or internal company engineering standards for piping specifications, materials for construction and other design parameters. (Opportunity No. PHA9412) NOC 12337 Process Safety Management Assessment Henry Plant page 6 Operating Procedures: 1910.119(f) The requirement of this paragraph is for the employer to provide clear instructions for safely conducting activities involved in the covered process consistent with the process safety information assembled by the Henry Plant. The standard requires that the operating procedures be reviewed as often as necessary to assure that they reflect current operating practice and technology. Annually, the procedures must be certified that they are current and accurate. Note: This service is provided by WPS but documentation is needed. (Opportunity No. OP9413) Operating procedures must include operating limits that outline consequences of process deviation and steps to correct or avoid these deviations. Discuss this PSM section (1910.119(f) (1 )(ii) with WPS to assure that this requirement is being achieved. (Opportunity No. OP9414) The plant should be commended on the fine effort put forth in rewriting the plant's process operating procedures. The procedure books in the field are user friendly and most important are being utilized by the operating personnel in the units as verified through employee interviews. Training: 1910.119(g) The purpose of this paragraph is to help employees understand the nature and causes of problems arising from process operations. Training will increase an employee's awareness with respect to the hazards particular to a process. An effective training program can significantly reduce the number and severity of incidents arising from process operations and can be instrumental in preventing small problems from becoming or leading to catastrophic events. Minimum training programs must include initial training, refresher training and documentation. Initial training has been achieved and is welt documented. The plant has gone the extra mile in that actual certification under the WPS training procedures has been achieved rather than simply "grandfather*1 existing operators. The plant is commended for this effort. Refresher training is presently within the three year cycle as required by the standard. The plant is reminded that their obligation as an employer under the standard is to consult with employees in the operating process to determine the appropriate frequency for refresher training. (Opportunity No. T9415) NGC 12338 Process Safety Management Assessment Henry Plant Page 7 Contractors: 1910.119(h) The intent of this paragraph is to require employers who use contractors to perform work in and around processes that involve highly hazardous chemicals to establish a screening process so that they retain and use contractors who can accomplish an assigned task without compromising the safety and health of employees at the Henry Plant. The contractor as an employer also has responsibilities and must assure their employees are trained on performing the job at hand safely. Additionally, the contractor must communicate to their employees the hazards of the job and understand the provisions of the owner's emergency response plan. The GEON Plant at Henry is doing a good job handling contractors. A three-hour contractor training program was attended involving several contractors doing different jobs in the plant and instructions and evaluations were very good. Since the GEON Company is now a separate business, it is recommended that GEON files for contractor questionnaire, performance evaluations, training documentation, contractor's verification of training, etc. be established beginning January 1, 1995. (Opportunity No. C9416) Pre Start-up Review: 1910.119(1) New processes and modified processes which necessitate a change to the plant's process safety information dictates certain considerations before highly hazardous chemicals are introduced into the process. These requirements include a pre start-up review to confirm that the following actions have been addressed: 1. Construction and equipment is in accordance with design and specifications. 2. Safety, operating, maintenance and emergency procedures are in place and adequate. 3. A process hazard analysis has been performed and all recommendations have been addressed and communicated to appropriate personnel. 4. Management of change and training of each involved employee i contractor in the process has been completed. Although pre-startup safety reviews have been routinely achieved at this facility for some time and documentation is in place, there is a need to develop a check list to verify that the four items listed in the paragraph above takes place prior to introduction of highly hazardous chemicals to the process. (Opportunity No. PSSR9417) NGC 12339 Process Safety Management Assessment Henry Plant pages Mechanical Integrity: 1910.119(1) *'j . The mechanical integrity section of the standard establishes requirements to assure that equipment used to process, store, or handle highly hazardous chemicals is ' designed, constructed, and maintained in order to minimize the risk of ^ chdrhjdal release. Elements of a mechanical integrity program includes the identification and categorization of equipment and instrumentation, development of written maintenance procedures, training for process maintenance activities, inspection, testing, correction of deficiencies in equipment that are outside acceptable limits defined by the process safety information and quality assurance program. The plant needs to prepare its own written mechanical integrity procedure to comply with the PSM standard. During the assessment, it was noted that rriany of the requirements of the PSM mechanical integrity paragraph were being addressed. However, a procedure must be developed to assure that all elements of this critically important section of the standard is achieved and documented. '(Opportunity:No. MI9418) One specific consideration which needs to be emphasized is to carefully and completely document each inspection and test. There is no doubt that the activity is being carried out, but there is an opportunity to improve the system with good documentation. (Opportunity No. M19419) Hot Work Permit: I9l0.ll9(k) Employers must control, in a consistent manner, non-routine work in the PSM areas ; covered by the standard. Specifically, this paragraph is concerned about permitting hot work operations associated with welding and cutting in highly hazardous chemical process areas. Minimum requirements to comply with this section include meeting the requirements of OSHA's 1910.252(a). Hot work is tightly controlled in this plant as expected. Hot work for category I areas are all pre-planned. Good contractor understanding is being achieved evidenced by interviews. Disciplinary action for failure to follow plant hot work procedures is on record. _ There are no recommendations thought necessary at this time. NGC 12340 Process Safety Management Assessment Henry Plant PAGES^;: , Management of Change: 191 o.l 19(1) Careful consideration of all modifications to procedures, raw materials and process ; conditions other than "replacement in kind" must be controlled by identifying arid reviewing prior to implementing a change. The plant is presently using the BFGoodrich . M.O.C. policy. The Henry Plant needs to develop and implement its own site specific management of change procedure to address the following parameters. (Opportunity No. MOC9420) 1. Technical basis for proposed change. 2. impact of change on safety and health of employees. r3. .Modifications to the operating procedures. 4. Necessary time period for the change. 5. Authorization requirements for change. .w. 'T; A key consideration of the M.O.C. policy is to provide communication to all affected GEQN and contract personnel and to make certain that all impacted procedures, of any kind, are updated appropriately. (Opportunity No. MOC9421) Incident Investigation: I9l0.ll9(m) Every incident that occurs in the plant that could have resulted in a catastrophic : release of a highly hazardous chemical in the work place must be investigated. The plant's culture is to report any incident with potential. Root cause analysis to pin point tohy incidents occur is taking place. The plant needs to develop a system .Jo1 document closure relating to incident investigation recommendations/corrective actions and the same information should become part of the PSM file if the incident occurs iri a PSM area. (Opportunity No. 119422) Emergency Planning and Response: I9l0.l19(n) This paragraph requires employers to address what action employees are to take when there is an accidental release of a highly hazardous chemical. The plant has an adequate emergency response plan. In-plant personnel are trained to handle fires, spills, and release scenarios. The plant has a limited number of response personnel (including BFG) to manually intervene in a large fire situation. Careful plans should be developed as pre-fire fighting action to be implemented based on the limited personnel to respond. NGC 12341 Process Safety Management Assessment Henry Plant Page 10 There is one area that will enhance the emergency response plan and that is to illustrate areas at which information concerning an emergency can be obtained and where assembly points are located if the plant is evacuated. These maps are to be placed in high traffic areas in the plant where people can observe them. (Opportunity No. EPR9423) Compliance Audits: 1910.119(o) Employers are required to self evaluate the effectiveness of their PSM program in order to identify improvement opportunities and to take appropriate corrective action to resolye deficiencies. Minimum requirements include: 1. Audit at least every three years. 2. Maintain at least the last two audits. 3. Track to completion the audit findings and document the closure action. Trade Secrets: 1910.119(p) This paragraph requires employers to provide all information necessary to comply with personnel developing sections (d) process safety information, (e) process hazard analysis, (f) operating procedures, (n) emergency planning and response, and (o) compliance audits without regards to possible trade secrets. The one recommendation thought to be in order would be to develop a secrecy agreement document to be signed by specific contract employees that work in sensitive areas of the Henry Plant. (Opportunity No. TS9424) Date Figure no. 1 HAZOP TEAM MEMBER BIOGRAPHY 1) Name: _______________________________________________ 2) Job Title:______________________________________________________ 3) Previous Positions Held:_______________________________________ 4) Years Experience:_________________________________ 5) Fire School Experience: 6) Emergency Response Team Experience:__________________ __________________ 7) Field of Expertise (ie: Poly Room Head Operator, Charge Operator, Pipefitter): 8) Other Qualifications: TMJ-JAN`94 NGC 12343 PSM AUDIT Application 1910.119(a) Employee Participation 1910.119(C) Process Safety information 1910.119(d) Process Hazard Analysis 1910.119(e) 2 Q O H--A UK>> 44^^. IMPROVEMENT OPPORTUNITIES HENRY PLANT -- A9401 A9402 EP9403 PSI9404 PHA9405 PHA9406 PHA9407 PHA9408 PHA9409 PHA9410 PHA9411 Develop a central filing system for all PSM Information. Graphically illustrate the plant's PSM areas and list VCM storage capacity complete with locations. Develop a written GEON employee participation procedure to involve employees in the development of PHA's and all other elements of the 1910.119. Assemble ail required process safety information in a central file system or index to identify where data is located and person responsible for same. Identify and document areas of the plant where PHA's (HAZOP) must be achieved. Prioritize and schedule identified PHA's to meet Internal GEON requirement. Document preferred method(s) for hazard evaluation at Henry and insure appropriate personnel are trained in the methodology(ies). Provide documentation that PHA's address human factors and facility siting. Provide a system to address PHA recommendations in a timely manner including communication to Irripacted personnel. - ' Historical data (previous incidents) must be considered during PHA's. Document that this information is utilized and make part of each PHA file if available. Develop biographical profiles on each HAZOP team member. Include this information In the PHA file that person served on. 1994 NGC 12345 IMPROVEMENT OPPORTUNITIES - 1994 Henry Plant Process Hazard Analysis 1910.119(e) (continued) Operating Procedures 1910.119(f) Training 1910.119(g) Contractors 1910.119(h) Pre-startup Safety Review 1910.119(i) Mechanical Integrity 1910.119(0 Management of Change 1910.119(1) PHA9412 Include in PHA fNe documentation, the spectra regulations or codes being considered while conducting PHA's. OP9413 OP9414 T9415 C9416 PSSR9417 To comply with paragraph (f)(3) "of the standard, the'plant needs to annually certify that operating procedures in the PSM area are current and accurate. Review with WPS to assure they have addressed operating limits that outline consequences of process deviation and steps to correct or avoid deviations have been addressed. Consult with employee in the operating process to determine the appropriate frequency (if less than three years) for refresher training. Document the results. Establish GEON files for contractor safety information to include reasons for selection, training documentation, contractor verification of training, selection process, performance evaluation, etc. Develop a check list for conducting Pre-startup safety reviews to address paragraph (i)(2) of the standard. MI9418 MI9419 MOC9420 MOC9421 Develop a written mechanical integrity procedure to comply with the standard. Provide documentation of each inspection and test, required by the standard. Develop and implement a GEON management of change procedure to comply with the standard. T Insure a system exists to address communication issues to all impacted employees and to assure procedures that are : Impacted are revised. ;v Page 2 Ir' NGC 12346 Improvement Opportunities -1994 Henry Plant Incident Investigation 1910.H9(m) Emergency Planning and Response 1910.119(n) Trade Secrets 1910.119(p) 119422 EPR9423 TS9424 Develop a system to track to closure all incidents which require investigation in a PSM area Provide evacuation orientation maps to dearfy indicate safe assembly and/or evacuation routes. Post in high traffic areas. Develop a secrecy agreement for contractors who work in sensitive areas of the plant. Page 3 AUDITOR QUALIFICATIONS 'a < T. Michael Jones: Mike Jones has worked in the petrochemical industry with The BFGoodrich Chemical Company, Diamond Shamrock Chemicals, Cain Chemical and Occidental Chemical Corporation for 29 years. He was the Corporate Manager - Facility Safety and Industrial Hygiene for OxyChem until he elected early retirement in September, 1993, to form the company of T.Michael Jones & Associates. Mike is a Certified Safety Professional with extensive experience in plant operations, maintenance, engineering design/construction, safety, industrial hygiene, emergency management, and process safety management. Product manufacturing experience includes synthetic rubber, PVC resin, vinyl chloride monomer, olefins and aromatics, ethylene dichloride, caustic soda, chlorine, and ethylene oxides/derivatives. He holds a B.S. Degree in Industrial Arts and Chemistry from Stephen F. Austin University and a M.S. Degree in Engineering Management from Louisiana State University Baton Rouge. NGC 12347 0<m>ee*3~l ,/9^4 sA/fe fPrr 1910.119 (c): EMPLOYEE PARTICIPATION c I. PROGRAM SUMMARY The intent of this paragraph is to require employers to involve employees at an elemental level of the PSM program. Minimum requirements for an Employee Participation Program for PSM must include a written plan of action for implementing employee consultation on the development of process hazard analyses and other elements of process hazard management contained within 1910.119. The employer must also provide ready access to all the information required to be developed under the standard. n. QUALITY CRITERIA REFERENCES A. 1910.119(c): Employee Participation m. VERIFICATION OF PROGRAM ELEMENTS CrM* Rcfcwi Um Y/N A. Records Review 1. Does a written program exist regarding employee participation? FIELD NOTE REFEXENCE0): CodOCftT TO <HFOKj RdLJC Y - PG^trVJTLY U5)U(p- .119(C) (1) (Jo j 2. Does the written program include consultation with employees and their representatives on the conduct and development of process hazard analyses and on the development of other elements in the PSM standard? FIELD NOTE lEFEKENCEOh To DC'J ^Lop .119(c) (2) 1 3. Does the written program provide employees and their representatives access to process hazard analyses and all other information developed as required by the PSM standard? HELD NOTEILEFEHEXTEHh UfcKP TO PtNVt-Op O).119(c) B. On-site Conditions Not applicable. A-5 Wa. Li NGC 12348 C. Interviews 1. Baaed on interviews with a representative number of employees and their representatives, have they been consulted on the conduct and development of the process hazard analyses? FIELD NOTE REFERENCED .119(c) (2) 2. Based on interviews with a representative number of employees and their representatives, have they been consulted on the development of other elements of the Process Safety Management program? FIELD NOTE REFERENCED .119(c) (2) 3, Based on interviews with a representative number of employees and their representatives, have they been provided aceess to process hazard analyses and to all other information required to be developed by the PSM standard? (Ask about unreasonable delays in access to information and whether time is given during the working hours to access information required by the PSM standard.) FIELD NOTE REFERENCED .119(c) (3) Ves A-6 1910.119 (d): PROCESS SAFETY INFORMATION I. PROGRAM SUMMARY The intent of thie paragraph is to provide complete and accurate information concerning the process which is essential for an effective process safety management program and for conducting process hazard analyses. Therefore in accordance with the schedule set forth in paragraph (e)(1) the employer is required to compile written process safety information on process chemicals, process technology, and process equipment before conducting any process hazard analysis* IT. QUALITY CRITERIA REFERENCES A. 1910.119(d): Process Safety Information B. 1910.119(e)(1): Process Hazard Analysis B. 1910.1200: Hazard Communication m. VERIFICATION OF'PROGRAM ELEMENTS Citato tat Y/N A. Records Review 1. Has written process safety information been compiled before conducting any process hazard analysis (PHA)? FIELD NOTE RLFERENCEiSJ: ^ k<J E BoT WOT CD 119(d) See Ao+c A--7 / 2. I8 information included pertaining to the hazards of the highly hazardous chemicals used or produced by the process, and does the information include at least: toxicity information PEL'S physical data reactivity data corrosivity data thermal and chemical stability data hazardous effects of inadvertent mixing of different materials that could foreseeable occur? NOTE: MSDS'a meeting the requirements of 29CFR1910.1200(g) may be used to the extent they contain the information required. AtefcArFIELD NOTE REFERENCED): VCNA B&tSfr USQ>. .119(d) (1) .1200 <g) 3. Is information included concerning the technology of the .119(d) process, and does it include at least: (2) a block flow diagram or simplified _ process flow diagram? process chemistry? *jr maximum intended inventory? DftOl 4OAU406 MtJT 4$5V-40t > safe upper and lower limits? an evaluation of the consequences of deviations? UOT (Where the original technical Information no longer exists, it may be developed in conjunction with the PHA.) FIELD MOTE REFERENCED); TO C)AT7V- flO \ 4. Is information included pertaining to equipment in the process, and does it include at least: materials of construction? piping and instrument diagrams (PfilD's)? electrical classification? relief system design and design basis? ventilation system design? design codes and standards employed? material and energy balances for processes built after May 26, 1992? safety systems (e.g. interlocks, detection or suppressions systems)? FIELD NOTE REFESENCElS): ttA.Loa.HOCr A-srM, Sravovaw, A-Pi, A-smc, .119(d) (3)(i) 0 6 < * A"d NGC 12351 5. Has the employer documented that equipment complies with recognized, generally accepted good engineering practices? (Review the documentation for evidence that compliance with the appropriate consensus standards haB been researched.) FTELO NOTE *EFEAENCE(5}: .119(d) <3> (ii.) ' 6. Has the employer determined and documented that existing equipment designed and constructed in accordance with codes, standards, or practices no longer in general use are designed, maintained, inspected, tested, and operating in a safe manner? (Documentation may be through methods such as: documenting successful prior operation procedures; documenting that the equipment is consistent with the appropriate editions of codes and standards; or performing an engineering analysis to determine that the equipment is appropriate for its intended use.) HELD NOTE REFEXENCEOT: .119(d) (3) (iii) B. On-site Conditions .119(d) 1. Do observations of a representative sample of process chemicals and equipment indicate that the process Information Is complete? (Information that does not correspond to the actual conditions demonstrates incomplete information. Check critical equipment and components to see if they have been properly identified.) F1F1.D NOTE *EFE*ENCEtS): 2. Do observations of a representative sample of process components indicate that the process complies with recognized and generally accepted good engineering practice? (Review a representative number of safety devices such as pressure relief devices for proper sizing according to the maximum anticipated pressure.) FIELD NOTE JLEFEXENCEtf): .119(d) (3)(ii) A--9 NGC 12352 3. Do observations of a representative sample of the existing equipment designed and constructed according to codes, standards, or practices no longer in general use indicate that this equipment is inspected and is operated in a safe manner (as documented by the employer)? FIELD NOTE REFERENCES); -119(d) (3) (iii) C. Interviews Process Hazard Analysis (PHA) Team: 1. Based on interviews with a representative munber of PHA team members, was the process safety information complete before the process hazard analysis was conducted? FIELD NOTE *HPU-KCEISte .119(d) i*ce Operators: 2. Based on interviews with a representative number of operators, is MSDS information readily available to the operators who work with hazardous materials? FIELD NOTE HEFEJUENCEOfc -1200 fes Engineers (if any; or other qualified persons capable of providing the information requested; see HOTS, p. A-2): 3. Based on interviews with a representative number of engineers, has the employer documented that the process equipment complies with recognized and generally accepted good engineering practice? (Ask about the technical bases for design and selection of equipment, the materials of construction, electrical classifications, relief devices Bizing versus maximum anticipated pressures, installation procedures to assure equipment meets design specifications, etc.) FIO-D NOTE REFERENCES^ DtS0^|OlJ .119(d) (3)(ii) for more information on Process safety information, see Appendix D, references 8. and 9. A-10 me 12353 1910.119 (e): PROCESS HAZARD ANALYSIS I. PROGRAM SUMMARY The intent of this paragraph is to require the employer to develop a thorough, orderly, systematic approach for identifying, evaluating and controlling processes involving highly hazardous chemicals. Minimum requirements include: (1) Setting a priority order and conducting analyses according to the required schedule; (2) using an'appropriate methodology to determine and evaluate the process hazards; (3) Addressing process hazards, previous incidents with catastrophic potential, engineering and administrative controls applicable to the hazards, consequences of failure of controls, facility siting, human factors, and a qualitative evaluation of possible safety and health effects of failure of controls on employees; (4) Performing PHA by a team with expertise in engineering and process operations, the process being evaluated, and the PHA methodology used; (5) Establishing a system to promptly address findings and recommendations, assure recommendations are resolved and documented, document action taken, develop a written schedule for completing actions, and communicate actions to operating, maintenance and other employees who work in the process or might be affected by actions; (6) Updating and revalidating PHA*s at least every 5 years; and (7) Retaining PHA's and updates for the life of the process. n. QUALITY CRITERIA REFERENCES A. 1910.119(e): Process Hazard Analysis m. VERIFICATION OF PROGRAM ELEMENTS Mat Y/H A. Records Review 1. Has the employer determined and documented a priority order for conducting initial PHA*a based on a rationale that includes at least these factors: the extent of process hazards number of potentially affected employees age of process operating history? .119(e) (1) nELD HOTE REFERENCED e5" A&G PA&& Of nte PfUgCLiT-'-f U^r fruft Cl+tC* U-lft'ftT XFft, 06TO TO Otwtftop gofehJOt/lg-------------------------------------------------------------------- A-ll 2. Are the initial PHA's for proceaeee covered by the PSM standard being performed as soon as possible? nEUNOTBOTENCEff>= /VLTO ffco. BJU&TUV UJOftK u3H^Oe fbS*iBce. KifSp *uo ptfeewr i foco* Jh^T Cfc^T DsAOUMCS .119(e) (1) 3. Does the priority schedule for PHA's assure that all initial PHA's will be performed by 5/26/97 and that: No less than 25% of the PHA's shall be completed by 5/26/94? ( No less than 50% of the PHA's shall be completed by 5/26/95? No less than 75% of the PHA's shall be completed by 5/26/96? .119(e) (1) Jo (PHA's completed* after Hay 26, 1987 which meet the requirements of this paragraph are acceptable as initial PHA's; they must be updated and revalidated at least every 5 years.) FIELD NOTE REFERENCE**: tfj&2p c-tH*DOL4S C&JStXT QULCUT- AtAcftO ACCe*-g><X5lt^> 4. Does the hazard evaluation use one or more of following PHA methodologies: What-if? (v/esN Checklist? What-if/Checklist? ^ Hazard & Operability Study (HAZOP)? Failure Mode and Effects Analysis (FMA)? Fault Tree Analysis (FTA)? Other appropriate methodology? the .119(e) (2) (See Appendix 3 for a discussion of appropriate methodologies). HELD NOTE REFERBiCEjS* O f-VtJV/T Litrto Doco (>} y& A-12 S. Does the PHA address the following; The hazards of the process? FIELD NOTE REFOLEHCFfSV. .119(e) O) ies, Previous incidents with likely potential for catastrophic consequences? FIELD NOTE KEFOEMCEISfc Consequences of failure of engineering and administrative controls? (For example, potential injury, maximum hazardous materials, property damage, etc.> Fl&D NOTE REFERENCED: release of i&s S. (Continued) Does the PHA address the following: Engineering and administrative controls applicable to the hazards and their interrelationships? (Such controls may include appropriate application of detection methodologies to provide early warning of releases; inventory reduction; substitution of less hazardous materials; protective systems such as deluges, monitors, foams; increased separation distances; modification of the process temperature or pressure; redundancy in instrumentation; etc.) FIELD NOTE lEFEXEMCEOt: .119(e) (3) Facility siting? (Review calculations, charts, and other documents that verify facility siting has been considered. For example, gafa distances for locating control rooms- may be based on studies of the individual characteristics of equipment involved such asx. types of construction of the room, types and quantities of materials, types of reactions and processes, operating pressures and temperatures, presence of ignition sources, fire protection facilities, capabilities to respond to explosions, drainage facilities, location of fresh air intakes, etc.) FIELD NOTE REFEKENCEfS)! Human factors? (Such factors may include a review of operator/process and operator/equipment interface, the number of tasks operators must perform and the frequency, the evaluation of extended or unusual work schedules, the clarity and simplicity of control displays, automatic instrumentation versus manual procedures, operator feedback, clarity of signs and codes, etc.) FIELD NOTE REFEJtENCECT: A qualitative evaluation of a range of possible safety and health effects of failure of controls on employees in the workplace? FIELD NOTE IFE>MCE(S)e PeiM/VTK4- ? M/k, UJtu6 mJ 1/vrts.r tri^noio or SoRUJ^E" A--14 NGC 12357 6. Are the process hazard analyses performed by teams with expertise in engineering and process operations, including at least dne employee with experience and knowledge specific to the process being evaluated and one member knowledgeable in the specific PHA methodology used? FIELD NOTE REFERENCED . 119(e) 7. Has a system been established to promptly address the team's findings and recommendations? TfW PORnod 15 ro U2rto*J dp PfM-/w .A- TA06i3fr 'S^&TSM to tOdufte rAcnou 'Tkwe* ptAtner uo*r ee Review a representative sample of the documentation. Has the system been able tor .119(e) (5) UD . Assure* that the recommendations are resolved and documented in a timely manner? FIELD NOTE REFERENCED JO Document actions to be taken? FIELD MOTE REFERENCED Complete actions as soon as possible? FIELD NOTE REFERENCE: Develop a written schedule of when actions are to be completed? FIELD MOTE REFERENCE!** Communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions? FIELD NOTE REFERENCED: 3. Are the PHA's updated and revalidated at least every five years by a qualified team meeting the requirements in paragraph (e)(4), to assure that the process hazard analysis lb consistent with the current process? FIELD NOTE SEFERENCElSl: CHCJJ^> .119(e) (6) h/a- A-15 NGC 12358 9. Are all initial PHA's, updates or revalidations, and documented resolutions of recommendations kept for the life of the process? FIELD MOTE REFERENCED Pi.f^C-C Oft. Reftotio &ereunfJ . -119(e) (7) B. Oa-site Conditions 1. Do observations of a representative sample of process-related equipment indicate that obvious hazards have been identified, evaluated, and controlled? (For example, hydrocarbon or toxic gas monitors and alarms are present; electrical classifications are consistent with flammability hazards; destruct systems such as flares are in place and operating; control room siting is adequate or provisions have been made for blast resistant construction, pressurization, alarms, etc.; pressure relief valves and rupture disks are properly designed and discharge to a safe area; pipework is protected from impact; etc.) FIELD NOTE REFERENCED jffctvde'T ScP^> ^ .119(e) UJ * K $ 2. Do observations of a representative sample of process-related equipment indicate that PHA recommendations have been promptly resolved? FIELD NOTE REFERENCED .119(e) (5) pu.o. (bit> nor oBStf*) C. Interviews PHA Team Members: 1. Based on interviews with a representative number of the PHA team members, are the PHA methodologies used appropriate for the complexity of the process? FIELD NOTE REFERENCED: .119(e) (1) 'te 2. Based on interviews with a representative number of the PHA team members, is the priority order for conducting PHA's based on the extent of the process, the number of potentially affected employees, the age of the process, and the operating history of the process? FIELD NOTE REFERENCES): -119(e) (1) q*>. A-16 me 12359 3. the Based on interviews with a representative number of PHA team members, have the following been addresseds The hazards of the process? Previous incidents with likely potential for catastrophic consequences? Engineering and administrative controls applicable to the hazards? Consequences of control failures? Facility siting? Human factors? {Ask about shift rotations, extended schedules, and other possible sources of error.) A qualitative evaluation of a range of possible safety and health effects of failure of controls on employees in the workplace? FIELD NOTE REFEREKCECS: .119(e) (3) 4. Based on interviews with a representative number of the PHA team members, do the members have the appropriate expertise in engineering, process operations, and the process methodology used? Does one member of the team have experience and knowledge in the specific process? FIELD HOTS REFElENCEBfe -119(e) (4) 5. Based on interviews with a representative number of the PHA team members, does the system established by the employer address the team's findings and recommendations promptly? FIELD NOTE REFERENCE!?): .119(e) <5) Operators and maintenance: 6. Based on interviews with a representative number operator and maintenance employees, have the PHA's addressed the recognized hazards of the process and previous incidents which had a likely potential for catastrophic consequences? FIELD NOTE REFEXENCB0R .119(0) <3) 7. Based on interviews with operator, maintenance, other employees who may be affected by recommendations, have actions taken to resolve findings been communicated to these employees? and PHA PHA FIELD NOTE REFQIENCEIS): -119(e) (S) For more Information on PHA, see Appendix D, referencest 8.; 9.; 10.; 11.; 12 . ; 13.; 14.; 15.; 16.; 17.; 25.; 26.; 27, Part X, Section UG-125; 31.; 32.; and 33 . A--17 NGC 12360 1910.119 (f): OPERATING PROCEDURES I. PROGRAM SUMMARY The intent of thia paragraph ia to provide clear inatruction for conducting activitiea involved in covered procesaea that are consistent with the process safety information. The operating procedures must address steps for each operating phase, operating limits, safety and health considerations, and safety systems and their functions. n. QUALITY CRITERIA REFERENCES A. 1910.119(f) B. 1910.120 C. 1910.147 D. 1910.1000 S. 1910.1200 D3. VERIFICATION OF PROGRAM ELEMENTS Mb Y/N A. Records Review 1. Do written operating procedures exist for each covered process? Do the procedures provide clear instructions for conducting activitiea safely? FIELD MOTE REFEXEMCEOT: 119(f) (1) 2. Do the operating instructions address, as a minimum, steps for each operating phase, including: Initial start-up? Normal operations? Temporary operations? Emergency shutdowns? Conditions requiring emergency shutdown? Assignment of shutdown responsibility to qualified operators? Emergency operations? Normal shutdown? Start-ups following a turnaround or emergency shutdown? 1 NOTE KEFEKENCEO: 119(f) (1) < i > A"18 MGC 12361 3. oo the operating procedures include operating limits that outline consequences of process deviation and steps required to correct or avoid deviations? HEP NOTE REFERENCED): .119(f) <DUi) 4. Have safety and health considerations been included in the operating procedures? Oo they include at a minimum: Properties of, and hazards presented by, chemicals used in the process? Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment? Control measures to be taken if physical contact or airborne exposure occurs? Quality control for raw materials and control of hazardous chemical inventory levels? Any special or unique hazards? k)t>r<dnH PteOfSZ. FIELD NOTE REFERENCED* -119(f) U) (iii) 5. Are safety systems and their functions included in the operating procedures? FIELD NOTE REFERENCED): ,119(f) (1) (W) 6. Are the operating instructions consistent with the process safety information? FIELD NOTE REFERENCED): .119(f) (1) lftes 7. Are operating procedures readily accessible to employees who work in or maintain a process? FIELD NOTE REFERENCED): 119(f) (2) A--19 NGC 12362 8. Are operating procedures reviewed as often as necessary to assure that they reflect current operating practice? Are they certified annually by the employer that they are current and accurate? Do they reflect current operating practice that have resulted from changes in: Process chemicals? Technology? Equipment? Facilities? ftelo*JOTtREreaiucssfc sfgf CAViOfO. .119(f) (3) to 9. Have safe work practices been developed and implemented for employees and contractors to control hazards during operations such as: Lockout/tagout? Confined space entry? Opening process equipment or piping? Control over entrance into a facility by maintenance, contractor, laboratory or other support personnel? FIELD MOTE KEFEHNCECat -119(f) (4) B. On-site Conditions 1, Does observation of a representative sample of processes indicate that the written operating procedures are being implemented? FIST NOTE EEFEREXCEtffc .119(f) (1) to 2. Does observation of a representative sample of processes indicate that the written operating procedures are readily accessible to employees who work or maintain a process? FIELD NOTE HEFDtENCEOfe .119(f) (2) to 3. Does observation of a representative Bample of processes indicate that operating procedures reflect current practice, including changes that result from process chemicals, technology, equipment, and facilities? {Observe to see if actual procedures match the written operating procedures.) FIELD NOTE REFERENCfiS): .119(f) (3) to 4. Does observation of representative operations indicate that safe work practices have been implemented for company and contractor employees? Do such work practices include, where appropriate: Lockout/tagout? Confined space entry? Opening process equipment or piping? Control over entrance into a facility by maintenance, contractor, laboratory, and other support personnel? FIELD ?*OTE REFEMWCEOfc 119(f) (4) C. Interviews 1. Based on interviews with a representative number of operators, are the written operating procedures implemented for each covered process? FIELD NOTE REFERENCED): .119(f) (1) %5 2. Based on interviews with a representative number of operators, do operating procedures provide clear instructions for safely conducting activities? (Specifically ask for conditions requiring emergency shutdown, the operating limits of a particular process or item of equipment, what might occur if a deviation from those limits should take place, steps to avoid the deviation, and precautions necessary to prevent exposure to hazardous chemicals.) feud note refekb^ceisv 119(f) U> 3. Based on interviews with a representative number of employees who work in or maintain a process, are the operating procedures readily accessible? FI&D NOTE ftSTEUNCEO}; 119(f) (2) ft* 4. Based on interviews with a representative number of operators and maintenance employees, do the operating procedures reflect current operating practice? HELD NOTE REFERENCED 119(f) (3) Help A-21 NGC 12364 1910.119 (g): TRAINING I. PROGRAM SUMMARY The Intent of this paragraph helps employees understand the nature and causes of problems arising from process operations, and increases employee awareness with respect to the hazards particular to a process. An effective training program significantly reduces the number and severity of incidents arising from process operations, and can be instrumental in preventing small problems from leading to a catastrophic release. Minimum requirements for an effective training program include: Initial Training, Refresher Training, and Documentation. n. QUALITY CRITERIA REFERENCES A- 1910.119(g): Training B. 1910.119(f)(1): Operating procedures III. VERIFICATION OF PROGRAM CMMUMmi ELEMENTS A. Records Review 1. For employees involved in operating a process^jio initial and refresher training records exist? Do the records contain the identity of the employee, the date of the training, and the means used to verify that the employee understood the training? FIELD NOTE REFERENCED .119(g) (1)(i) tM Yfl* 2. Has each employee been trained before being involved in a newly assigned process (except employees involved in operating a process prior to 5/26/92)? FIELD NOTE REFERENCED: .119(g) (1)(i) A--22 NGC 12365 Hi 3. If initial training has not been given to employees involved in operating a process prior to 5/26/92, is there written certification that they have the required knowledge, skills and abilities to safely carry out the duties and responsibilities specified in the operating procedures? (Review the documents to make sure the certification has not be invalidated by a change in duties.) FtEUJ HOTE KEFEMHCEOT: LOlOV 119(g) (1)(ii) 4. Has each employee involved in operating a process been trained in an overview of the process and the operating procedures including: Stepsa for each operating phase? Initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, and startup following a turnaround or emergency shutdown Operating limits? Consequences of deviations and steps required to avoid deviations Safety and health considerations? Properties and hazards of chemicals used and precautions for preventing, exposure^ Safety systems and their functions? FtBJ> NOTE H7EKS<CE<S): .'119(g) (1)(i) OefcPV lUtTH- u# Y<> S. Has the employer consulted with employees involved in operating the process to determine the appropriate frequency for refresher training? Is the frequency at least once every 3 years? FIELD NOTE IEFEPLENCE(S): 1*5 lTW M(JHL'^'TAPT - " - 3e KaU&vo ewe of B. On-site Conditions Verification is not required. H9(g) (2) Oo -119(g) (1) or (2) w [/V- A-2 3 NGC 12366 A '0 C. Interviews 1. Based on interviews with a representative number of employees, has their training emphasized specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to their tasks? FIELD NOTE *FERNCE<S^ -119(g) (i)(i) 2. Baaed on interviews with employees named as having provided consultation, has the employer consulted with employees involved in operating the process to determine the appropriate frequency of refresher training? FIELD NOTE EEFEXENCEO: .H(92()g) D.Ki.o. A-24 V NGC 12367 1910.119 (h) CONTRACTORS I. PROGRAM SUMMARY The intent of this paragraph is to require employers who use contractors to perform work in and around processes that involve highly hazardous chemicals to establish a screening process so that they hire and use contractors who accomplish the desired job tasks without compromising the safety and health of employees at a facility. The contractor must assure that contract employees are trained on performing the job safely, of the hazards related | to the job, and applicable provisions of the emergency action plan. II. QUALITY CRITERIA REFERENCES A. 191,0.119 ( h) B. 1910.119(f)(4) C. 1910.119(n) T----------- ` " H ' - ................. - m. VERIFICATION OF PROGRAM ELEMENTS T Criteria Rifaaa Mm V/N A. Records Review - Employer's Program 1. Does the program include all contractors performing maintenance or repair, turnaround, major renovation or specialty work on or adjacent to covered processes? (Contractors performing incidental services which do not influence process safety such as janitorial work, food and drink services, laundry, delivery, and other supply services need not be included.) FIELD MOTE EEFEREMCEfSh .119(h) U) 1 2. Is the information regarding the contractor's safety a 'performance and programs obtained and evaluated for selection U of contractors? | FIELD NOTE KE7EKMCE(S)i .119(h) (2)(i) A- 2 5 NGC 12368 3 3. Are the contract employers informed of the known potential fire, explosion, or toxic release hazards related to the contractor's work and the processes? FIELD NOTE LEFEKEKCEfS): 119(h) (2)<li) X 4. Are contract employers informed of the applicable provisions of the emergency action plan required by .119(n)? FIELD NOTE REFERENCES}: .119(h) (2) (iii) Yes- S. Have safe work practices to control presence and exit of contract employers employees in covered process areas been imp1emented? the entrance, and contract developed and FIELD NOTE LEFERENCEfTh 119(h) <2)<iv> 119(f) (4) Ye? 6. Are contract employers evaluated' for their performance in fulfilling their obligations to: Assure their employees are trained in safe work practices needed to perform the job? Assure their employees are instructed in the known potential fire, explosion, or toxic release hazards related to the job and the applicable provisions of the emergency action plan? Document the required training and the means to verify their employees have understood the training? Assure their employees follow the facility safety rules and work practices? Advise the employer of unique hazards presented by the contractor's work? FIELD NOTE REFERENCED): .119(h) (2>(v) Yes 7. Does the employer maintain a contract employee injury and illness log related to the contractor's work in process areas? '.119(h) (2)(vi) YeS FIELD NOTE REFERENCES^ Records Review - Contractor's Programs 8. Are all contractor employees trained in the work practices necessary to perform their jobs safely? FIELD NOTE REFERENCED) .119(h) (3)(i) A-26 NGC ^369 9. is each contract employee instructed in the known potential fire, explosion, or toxic release hazards related to his/her job and the processes and applicable provisions of the emergency action plan? FIELD NOTE JlEFBIBtCEOT: .119(h) (3)(ii) 10. Is there documentation that each contract employee has received and understands the required training? FIELD NOTE LEFEJlQKECTfc -119(h) (3) (iii) 11. Do the contract employee training records contain the following: The identity of the employee? The date of the training? The means used to verify that the training was understood? FIELD NOTE REFERENCES): POf R^L*^TS>. .119(h) (3) (iii) 12. Are there means to assure that contract employee follow the safety rules of the facility, including safe woirk practices required in .119(f)(4)? (Review evidenge of enforcement by the contractor.) .119(h) (3)(iv) .119(f) (4) FIELD MOTE REFEUNCEBte i 13. Is the employer advised of any unique hazards presented by the contract employer's work or a*ny hazards found by the contract employer's work? .119(h) (3)(v) HELD NOTE REFERENCE#): B. On-site Conditions 1. Based on a representative sample of observations of contractor employees, has the employer's program to control their entrance, presence, and exit been implemented? FIELD NOTE REFStEHCEtS): .119(h) (2)(iv) . A-27 NGC 12370 | 2. Baaed on a representative sample of observations of contractor employees, do they follow the safety rules of the facility? {These rules include the employer's safe work practices such as Lockout/tagout, confined space entry, and opening process equipment or piping; they may also include other rules such as excavation procedures or use of PPE.) FIELD NOTE REFERENCED .119(h) (3)(iv) C. Interviews 1. Based on interviews with contractor employers, have they been informed of the known fire, explosion, or toxic release hazards related to their work and the processes in which they are involved? FIELD NOTE REFERENCED .119(h) (2)(ii) Yes 2. Based on interviews with contractor employers, have they been informed of the applicable provisions of the employer's emergency action plain? FIELD NOTE REFERS!CE0): .119(h) (2) (lit) 3. Based on interviews with contractor employers and employees, have work practices to control their entrance, presence, and exit of covered process areas been implemented? FIELD NOTE REFERENCED .119(h) (2){iv) 4. Based on interviews with the contractor employer, haB the employer evaluated the contractor's performance in - fulfilling the obligations required in .119(h){3)7 FIELD NOTE REFERENCES): <9gi/VlO "DefW. .119(h) (2)(v) 5. Based on interviews with a representative number of contractor employees, are they being instructed in the known potential fire, explosion, or toxic release hazards related to their work and the processes in which they are involved? .119(h) (3)(ii) FIELD NOTE REFERENCED A'-2 8 NGC 12371 \ 6. Based on Interviews with a representative number of contractor employees, have they been instructed in the applicable provisions of the emergency action plan? (Ask them to explain the plan and evacuation procedures.) FIELD NOTE REFEXENCEtfh .119(h) <3)(ii) 7. Based on interviews with a representative number of contractor employees, has the contract employer assured that they follow the safety rules of the facility? (Ask how safe work practices, entry restrictions for the facility, and use of required PPB are enforced.) FIELD NOTE lEFERENOtSfc .119(h) (3)(iv) For additional information on Contractors, see Appendix D, reference's. A-29 r* 1910.119 (i): PRE-STARTUP SAFETY REVIEW I. PROGRAM SUMMARY The intent of this paragraph is to make sure that, for new facilities and for modified facilities when the modification necessitates a change to process safety information, certain important considerations are addressed before any highly hazardous chemicals are introduced into the process. Minimum requirements include that the pre-startup safety review confirm the following: construction and equipment is in accordance with design specifications; safety, operating, maintenance, and emergency procedures are in place and adequate; for new facilities, a PHA hae been performed and recommendations resolved or implemented; modified facilities meet the requirements of paragraph (1), management of change; and training of each employee involved in the process has been completed. n. QUALITY CRITERIA REFERENCES A. 1910.119(1): Pre-startup Safety Review B. 1910.119(1): Management of Change m. VERIFICATION OF PROGRAM ELEMENTS ClMi A. Records Review 1. Has a pre-startup safety review been performed for all new facilities and for modified facilities when the modification is significant enough to require a change in process safety information? field motc unxoKm* . 119(i) <1) 2. Do pre-startup safety reviews confirm that prior to the introduction of highly hazardous chemicals to a process: Construction and equipment is in accordance with design specifications? FELD NOTE HEFERENCBSk 119(i) (2) kJo Safety, operating, maintenance, and emergency procedures are in place and adequate? HELD NOTE JLEFEJIENCEfSV $ f A~3 0 NGC 12373 I 2. (Continued) Do pre-startup safety reviews confirm that prior to the introduction of highly hazardous chemicals to a process: For new facilities, a PHA has been performed and recommendations resolved or implemented before startup? FIELD NOTE REFEBEHCEfS): ? Modified facilities meet requirements of paragraph (1) FIELD NOTE XEFEKBfCEtffe .119(1) (2) Training of each employee involved in operating the process has been completed? FIELD NOTE REFEBENCECT: On-site Conditions 1. Do observations of new or modified facilities Indicate that prior to the introduction of highly hazardous chemicals: * Construction and equipment is in accordance with design specifications? Safety, operating, maintenance, and emergency procedures are in place and adequate? FIELD HOTS REFEBENCEtf): {. 119 i) (2) 0*10. C. Interviews [s note, p. a-2.j 1. Based on interviews with a representative sample of operators, maintenance employees, and engineers, can it be confirmed that the construction and equipment are in accordance with design specifications prior to introducing highly hazardous chemicals to a process? FIELD HOTS lEFSUNCEA: .119(1) 2(i) 2. Based on interviews with a representative sample of operators, maintenance employees, and engineers, are safety, operating, maintenance, and emergency procedures in place prior to introduction of highly hazardous chemicals into a process? Are these procedures adequate? HELD NOTE REFEBENCEO): .119(1) {2 ii) "fe . A-31 NGC 12374 3. Based on interviews with a representative flap1 o#^ operators, maintenance employees, and engineers, is a/PH*) performed and are recommendations resolved prior to a startup that introduces highly hazardous chemicals into a new process? .119(i) 2(iii) FIELD NOTE KEFEXEKCEfS): 4. Based on interviews with a representative sample of operators, maintenance employees, and engineers, do modified facilities meet requirements of paragraph (1), Management of Change prior to introducing a highly hazardous chemical? FIELD NOTE KEFEXBtCEAi .119(i) 2(iii) 5. Based on interviews with a representative sample of operators, is training completed for each employee Involved in operating the procees prior to the introduction of a highly hazardous chemical? FIELD NOTE REFERENCED: .119{i) 2(iv) fe A-32 NGC 12375 1910.119 (j): MECHANICAL INTEGRITY I. PROGRAM SUMMARY The intent of this paragraph is to assure that equipment used to process, store, or handle highly hazardous chemical is designed, constructed, installed, and maintained to minimize the risk of releases of such chemicals. This requires that a mechanical integrity program be in place to assure the continued integrity of process equipment. The elements of a mechanical integrity program include the identification and categorization of equipment and instrumentation, development of written maintenance procedures, training for process maintenance activities, inspection and testing, correction of deficiencies in equipment that are outside acceptable limits defined by the process safety information, and development of a quality assurance program. H. QUALITY CRITERIA REFERENCES A. .119(j): Mechanical Integrity m. VERIFICATION OF PROGRAM ELEMENT'S CriMfk Irtwn Mm YVH A. Records Review 1. Does the written mechanical integrity program include? Pressure vessels and storage tanks -- Piping systems and components such as valves Relief and vent systems and devices Emergency shutdown systems Controls (including monitoring devices and sensors, alarms and interlocks) Pumps 119(3) (1) See 04c A-dfrttA-ecfc M" OiPfiCSJUC 2. Are there written procedures to maintain the on-going integrity of process equipment? Does the documentation indicate the procedures have been implemented? *119(3) (2) HELD NOTE W3TXEWCE(S>: fjgfcp TO pOfc?Pft<2^ (=> fL l4 I 0-D A-3 3 3. Has training been provided to each employee involved in maintaining the on-going integrity of process equipment in the following: An overview of the process and its hazards? Procedures applicable to the employee's job tasks to assure that the employee can perform the job tasks in a safe manner? (Review certification documents for employees doing non destructive tests, welding on pressure vessels, etc., where these certifications are required.) FIELD NOTE REFERENCEIS): .119(j) (3) 4. Are inspections and testa performed on each item of process equipment included in the program? HELD NOTE REFERENCES): .119(j) (4)(i) 5. Do inspection and testing procedures follow good engineering practices? nm> NOT* REFEREHCSOk (4)(ii) 6. Are inspection and test frequencies consistent with the manufacturer's recommendation and good engineering practice? Are inspections and tests performed more frequently if determined necessary by operating experience? FIELD NOTE REFERENCES): .119(j) {4 ) (iii) 7. Is there documentation of each inspection and test that has been performed including all of the following: Date of the inspection or test? ^v Name of person performing the procedure?Aurn<H Serial number or other identifier of equipment on which procedure was performed? Description of inspection or test performed? Results of inspection or test? FIELD NOTE REFERENCED* 119(j) (4)(iv) Yes A--3 4 \ 8. Are deficiencies in equipment that are outside limits (as defined in process safety information) corrected before further use or in a safe and timely manner when necessary means are taken to assure safe operation? FIELD NOTE REFBIENCEIS): .119(j) (S) 9. In the construction of ne& plants and equipment, does the employer assure that equipment as it is fabricated is suitable for the process for which it will be used? FIELD NOTE RJEFEEENCEOte TO Ik>?T?K-tAnoO PUfL Rd& -119(j) (6) U> 10. Have appropriate checks and inspections been made to assure equipment is installed properly and consistent with design specifications and manufacturer'3 instructions? (Include contractor supplied equipment.) FIELD NOTE REFEJUUCEtSfc .119(j) <6)(ii) fee- 11. Does the employer assure that maintenance materials, spare parts, and equipment are suitable for the process application for which they are used? (Include contractor supplied equipment.) HELD NOTE *FH*SCEfc .119(j) (S) (Ut) B. On-site Conditions 1. Do observations of a representative sample of process equipment indicate deficiencies outside acceptable limits? (Compare process safety information criteria with the conditions of the equipment found in the process.) FELD NOTE REFERBNOCS): .119(3) (5) Go 2. if new plants or equipment are being constructed, do observations indicate that the equipment as it is fabricated is suitable for the process application? 119(j) (6)(i) FELD NOTE REFERENCED: Q) > fOT (^D - ^ ^ A-35 NGC 12378 3. Do observation* of a representative sample of maintenance materials, spare parts, and equipment indicate that they are suitable for the process application for which they will be used? NOTEFTELD REFERENCED AT TlMr Of= TIH5 Pfr&JTOr Cxsoif BF6- 6>u5uJfc3 C. Interviews .119(3) (6) (ill) Engineers (if any; or other qualified persons capable of providing the information requested; see NOTE, p. A-2): 1. Based on interviews with a representative number of engineers, have procedures to maintain the on-going integrity of the process equipment been implemented for: Pressure vessels and storage tanks? Piping syeteotys and components such as valves? Relief and vent systems and devices? Emergency shutdown systems? Controls (including monitoring devices and sensors, alarms and `interlocks)? Pumps? (Ask about the possibility of safety .critical equipment being inadvertently rendered inoperative. For example, a relief device might be isolated by closing an upstream valve.) (jJltLFIELD More REFERENCE*!)! A'CtflfeJE -119(3) (2) QUO. 2. Based on interviews with a representative number of engineers, do the inspection and testing procedures follow recognized and generally accepted good engineering practice? Has prior operating experience indicated a need for a more frequent test and inspection schedule than has been implemented? FIELD NOTE REFERENCED .119(3) (4) Ves, 3. Based on interviews with a representative number of engineers, are equipment deficiencies corrected before use when they are outside the acceptable limits? If not, are the deficiencies corrected in a timely manner and are necessary means taken to assure safe operation? FIELD NOTE REFERBCED .119(3) (5) `fa* A-36 NGC 12379 4. Based on interviews with a representative number of engineers, has the employer assured that, for new plants and equipment, the equipment as it is fabricated is suitable for the process application? Are appropriate checks and inspections made to assure equipment is installed properly and consistent with design specifications and manufacturer's instructions? Are maintenance materials, spare parts, and equipment suitable for the process application for which they will be used7 (Ask about contractor supplied items.) FIELD NOTE REFERENCE#): 119(j) (6) i c d.o Kaintenance t 5. Based on interviews with a representative number of maintenance employees, have the written procedures for maintaining the on-going integrity of process equipment been implemented? FIELD NOTE REFERENCE#): .119(j) (2) 6. Based on interviews with a representative number of employees involved in maintaining the on-going integrity of the process, have they been trained to assure they can perform their tasks in a safe manner? Did the training include an overview of the process, its hazards, and procedures applicable to the job? (Determine if certification, specialized training, unique qualifications are required.) FIELD NOTE REFERENCE#): or .119(j) {3) He? 7. Baaed on interviews with a representative number of maintenance employees, do test and inspection procedures follow recognized and generally accepted good engineering practices? Is the frequency of inspections and tests consistent with applicable manufacturer's recommendations and good engineering practices? Are more frequent inspections and tests necessary due as indicated by prior operating experience? FIELD NOTE REFERENCE#): .119(j) (M He? A-37 NGC 12380 8. Based on interviews with a representative number of maintenance employees, are equipment deficiencies that are outside acceptable limits corrected before further use? If not, are corrections made in a timely manner ai^d are necessary means taken to assure operation? FIELD NOTE *FE*NCE45>: 3<Kl&T |l) ^31 .119(j) <5) Ve* 9. Based on interviews with a representative number of maintenance employees, are maintenance materials, spare parts and equipment suitable for the process application for which they are intended? {Ask about availability and use of substitutes.) FIELD NOTE REFERENCES): .119(j) (6) For Additional information on Mechanical Integrity, see Appendix D, references: 9.; 18.; 19.; 20.; 21.; 22.; 23.; 27.; 28.; 29.; and 34. A~38 NGC 12381 1910.119 (k): HOT WORK PERMIT I. PROGRAM SUMMARY The intent of thia paragraph is to require employers to control, in a consistent manner, nonroutine work conducted in process areas. Specifically, this subparagraph is concerned with the permitting of hot work operations associated with welding and cutting in process areas. Minimum requirements include: that the employer issue a hot work permit for hot work operations conducted oh or near a covered process and that hot work permits shall document compliance with the fire prevention and protection requirements of 29 CPU 1910.252(a). n. QUALITY CRITERIA REFERENCES A. 1910.119(k): Hot Work Permit 8. 1910.252(a): Fire Prevention and Protection m. VERIFICATION OF PROGRAM ELEMENTS CriMte Mat y/tt A. Records Review 1. Have hot work permits been issued for all hot work operations conducted on or near a process covered by this standard? FIELD NOTE FHCE(Sfc .119(k) (1) 2. Do the hot work permits indicate the date(s) authorized for hot work performed? FIELD NOTE RSEXENCESfc .119{k) (2) 13. Do the hot work permits describe the object on which the hot work is to be performed? FIELD NOTE KEFEEENCECT: .119{k) (2) A-39 NGC 12382 4. Have the hot work permits been kept on file until the hot work operations were complete? FIELD NOTE REFOLDCBS): .119(k) (2) 5. Have the hot work permits identified openings, cracks and holes where sparks may drop to combustible materials below? FIELD NOTE REFERENCBSh .252(a) (2)(i) 6. Have the hot work permits described the extinguishers required to handle any emergencies? FIELD NOTE REFERENCED): fire .252(a) <2)<ii) YO 7. Have the hot work permits assigned fire watchers whenever welding is performed in locations where other than a minor fire might develop? FIELD NOTE REFOtENCEA: .252(a) (2) (HI) TO 8. Are the hot work permits being authorized, preferably in writing, by the ''individual" responsible for all werlding and cutting operations? Is authorization preceded by site inspection and designation of appropriate precautions? FIELD NOTE REFERENCED* -252(a) (2)<iv) s .252(a) (2) (xiii) (A) 9. Have the hot work permits described precautions associated with combustible materials on floors or floors, walls, partitions, ceilings or roofs of combustible construction? FIELD NOTE REFERENCED* .252(a) (2)(v) & .252(a) (2)(ix) *-fe 10. Has hot work permitting been successful in prohibiting welding in unauthorized areas, in sprinklered buildings while such protection is impaired, in the presence of explosive atmospheres, and in storage areas for large quantities of readily ignitable materials? FIELD NOTE REFERENCED): .252(a) (2)(vi) YO A-4 0 KGC 12383 11. Have the hot work permits required relocation of combustibles where practicable and covering with flameproofed covers where not practicable? FIELD NOTE REFERENCED .252(a) (2) (vii) 12. Have hot work permits identified for shutdown any ducts or conveyors systems that may convey sparks to distant combustibles? FtOJ) NOTE REFERENCED .252(a) (2) (viii) 13. Have hot work permits required precautions whenever welding on components (e.g., steel members, pipes, etc,) that could transmit heat by radiation or conduction to unobserved combustibles? FIELD NOTE REFERENCED .252(a) (2)(x) & .252(a) (2) (xii) 14. Have hot work permits identified hazards associated with welding on walls, partitions, ceilings or roofs with combustible coverings or welding on walls or panels of sandwich-type construction? FIELD NOTE REFERENCED .252(a) <2)(xi) IS. Has management established areas and procedures for safe welding and cutting based on fire potential? FIELD NOTE REFERENCED * 252(a) (2) (xiii) 16. Has management designated the "individual" responsible for authorizing cutting and welding operations in process areas? FIELD NOTE REFERENCED .252(a) (2) (xiii) (B) 17. Has management ensured that welders, cutters and supervisors are trained in the safe operation of their equipment? FIELD NOTE REFERENCED .252(a) (2) (xiii) (C) A-41 NGC 12384 18. Haa management: advised outside contractors working on their site about all hot work permitting programs? FIELD NOTE REFERENCED: .252(a) (2) (xiii) (0) iep 19. Has the Supervisor determined if combustibles are being protected from ignition prior to welding by moving them/ shielding them, or scheduling welding around their production? FIELD NOTE REFERENCE!Sh .252(a) (2) (xiv) (A)(B) & <C) 20. Has the Supervisor, prior to welding, secured authorization from the responsible "individual" designated by management?. FIELD NOTE REFERENCED: .252(a) (2) (xiv) <D) B* On-Site Conditions 1. Conduct checks of current weldina and cuttina operations to ensure compliance with the requirements of 1910.119(k) and 1910.252(a). The twenty items listed above in "Records Review" mav serve as an audit checklist. A manaoement representative, the "individual" responsible for welding operations and the supervisor should all be invited to participate in this on-site check. FIELD NOTE REFERENCED: (jU (VfWZ- OI-> Qj .119(k) fi .252(a) C. Interviews - Employees and Contractors 1. Based on interviews with a representative number of maintenance and contractor employees, has the Supervisor visited welding work operations to verify that: Welders have approval for safe go ahead prior to welding? Fire protection and extinguishing equipment is properly located at the work site? Fire watches are functional, where required? FIELD NOTE REFERENCED: .252(a) (2) (xiv) (E),(F) & (G) D.0`0 2. Baaed on interviews with a representative number of maintenance and contractor employees, have hot work permits been issued for all hot work operations conducted on or near a process covered by this standard? FIELD NOTE IFESMCE(S)t .119(k) (1) 1 3. Based on interviews with a representative number of maintenance and contractor employees, have the hot work permits been kept on file until the hot work operations were complete? FIELD NOTE HEFEEEHCEB): . 119(k) (2) 4. Based on interviews with a representative number of maintenance and contractor employees, have the hot work permits identified openings, cracks and holes where sparks may drop to combustible materials below? FtHJ> NOTE KFERENCEff): .252(a) (2)(i) 5. Based on interviews with a representative number of maintenance and 'contractor employees, have the hot work permits assigned fire watchers whenever welding is performed in locations where other than a minor fire might develop? FIELD NOTE REFEB-EHCEtTfc .252(a) (2) (111) 6. Based on interviews with a representative number of maintenance and contractor employees, are the hot work permits being authorized, preferably in writing, by the "individual" responsible for all welding and cutting operations? Is authorization preceded by site inspection and designation of appropriate precautions? FIELD NOTE REFEXENCEilfc .252(a) (2)(iv) & .252(a) (2) (xiil) (A) He* 7. Based on interviews with a representative number of maintenance and contractor employees, have the hot work permits described precautions associated with combustible materials on floors or floors, walls, partitions, ceilings or roofs of combustible construction? FIELD NOTE JtEFER&ICECSh .2S2(a) (2)(v) fi .252(a) (2)(ix) A-43 NGC 12386 8. Baaed on interviews with a representative number of maintenance and contractor employees, has hot work permitting been succeseful in prohibiting welding in: Unauthorized areas? Sprinklered buildings while such protection is impaired? The presence of explosive atmospheres? Storage areas for large quantities of readily ignitable materials? FIELD NOTE KEFEXEXCEttk .252(a) (2)(vi) 9. Based on interviews with a representative number of maintenance and contractor employees, have the hot work permits required relocation of combustibles where practicable and covering with flameproofed covers where not practicable? FIELD NOTE XFERNCS(5h -252(a) (2) (vii) 10. Based on interviews with a representative number of maintenance and contractor employees, have hot work permits identified for ahufrflown any ducts or cooyeyors systems that may convey sparks to distant combustibxf' FIELD NOTE REFnB*CE(S): .252(a) (2) (viii) 11. Based on interviews with a representative number of maintenance and contractor employees, have hot work permits required precautions whenever welding on components (e.g., steel members, pipes, etc.) that could transmit heat by radiation or conduction to unobserved combustibles? FIELD NOTE RFEJlNC&Sk -252(a) (2)(x) & -252(a) (2) (xii) 12. Based on interviews with a representative number of maintenance and contractor employees, have hot work permits identified hazards associated with welding on walls, partitions, ceilings or roofs with combustible coverings or welding on walls or panels of sandwich-type construction? FELD NOTE KEFOENCEgfr .252(a) (2) (xi) A-44 NGC 12387 13. Baaed on interviews with a representative number of maintenance and contractor employees, has management established areas and procedures for safe welding and cutting based on fire potential? FIELD HOTS lEFE*NCECTfc AOp T*G F^-AfJT \AW fe^MIT .252(a) (2) (xiii) '-fe=> 14. Baaed on interviews with a representative number of maintenance and contractor employees, has management designated the "individual" responsible for authorizing cutting and.welding operations in process areas? FIELD HOTE HEFKKENCECfc .252(a) (2) (xiii) (B> VeS 15. Based on interviews with a representative number of maintenance and contractor employees, has management ensured that welders, cutters and supervisors are trained in the safe operation of their equipment? FIELD MOTE REFBUENCEfS): -252(a) (2) (xiii) (C) 16. Based on interviews with contractors and contractor employees, has management advised outside contractors working on the eite about all hot work permitting programs? HELD KOTC HEFE&EMCEO): .252(a) (2) (xiii) * (D) yes 17. Based on interviews with a representative number of maintenance and contractor employees, has the Supervisor determined if combustibles are being protected from ignition prior to welding by moving them, shielding them, or scheduling welding around their production. FIELD F*CTTE REFEXEMCEfS): .252(a) (2) (xiv) (A)(B) & (C) A-45 12388 1910.119 (1): MANAGEMENT OF CHANGE I. PROGRAM SUMMARY The Intent of this paragraph is to require management of all modifications to equipment, procedures, raw materials and processing conditions other than "replacement in kind" by identifying and reviewing them prior to implementation of the change. Minimum requirements for management of change include: establishing written procedures to manage change; addressing the technical basis, impact on safety and health, modification to operating procedures, necessary time period, and authorizations required; informing and training employees affected; and updating process safety information and operating procedures or practices. n. QUALITY CRITERIA REFERENCES A. 1910.119 (1): Management of Change m. VERIFICATION OF PROGRAM ELEMENTS Crittfh Kafci-- Y/N A. Records Review 1. Are there written procedures for managing changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures and changes to facilities that affect a covered process? .119(1) (1) (Jo (Review procedures that address responsibilities, steps for assessing risks and approving changes, requirements for reviewing designs for temporary and permanent changes, steps needed to verify that modifications have been made as designed, variance procedures, time limit authorizations for temporary changes, and steps required to return the process to status quo after temporary changes.) HELD NOTEREFESEMCEm: P^6iOP (Gt3b^ frDD&sSnJV- M AC'a- R2t&ttU Policy . see rvofe* ;> 2. Do the procedures assure that the technical basis for the proposed change is addressed prior to any change? FIELD NOTE REFOLENCEOfc .119(1) {2)(i) nc*c Sbo/C A~4 6 NGC 12389 3. Do the procedures assure that the impact of the change on safety and health is addressed prior to any change? FIELD NOTE REFERENCE: 4* Do the procedures assure that modifications to operating procedures is addressed prior to any change? FIELD NOTE REFERENCE: .119(1) (2)(ii) A-m .119(1) (2) (iii) 5. Do the procedures assure that the necessary time period for the change is addressed prior to any change? FIELD NOTE REFERENCE: .119(1) (2)(iv) 6. Do the procedures assure that the authorization requirements for the proposed change are addressed prior to any change? 119(1) (2)(v) FIH-D NOTE REFERENCE: 7. Are employees involved in operating a process, and maintenance and contract employees whose job tjasks will be affected by change informed of, and trained in, the change prior to start-up of process or affected part of process? FIELD NOTE REFERENCE: .119(1) (3) 8. Is the process safety information required by paragraph (d) updated if changed? FIELD NOTE REFERENCED .119(1) (4) 9. Are the operating procedures or practices required by paragraph (f) updated if changed? FIELD NOTE RCTERENCE: .119(1) (5) 1 A-47 NGC 12390 B. On-site Conditions 1. Do observations of new or recently modified process chemicals, technology, equipment, or procedures (except "replacement in kind") indicate that the Management of Change procedures have been implemented? (Determine procedures facility.) if records for new or are available to support revised processes found in the the FIELD NOTE REFERENCES): .119(1) (1) C, Interviews Operators, Maintenance, and Contractor Employees: 1. Based on interviews with operators, maintenance employees and contractor employees, are procedures implemented to manage changes to existing process chemicals, technology, equipment, facilities, and procedures? FIELD NOTE REFERENCES)! .119(1) (1) Vgj, 2. Based on interviews with operators, maintenance employees and contractor employees, is training in process changes provided to employees whose job tasks will be affected by the changes prior to atart-up? FIELD NOTE REFERENCES): .119(1) (3) For additional information on Management of Change, see Appendix D, reference 9., Chapter 7. A-48 NGC 12391 1910.119 (m): INCIDENT INVESTIGATIONS I. PROGRAM SUMMARY The employer is required to investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemical in the workplace. An investigation shall be initiated no later than 48 hours following the incident. An investigation team shall be established and a report prepared which includes: 1) Date of incident 2) Date investigation began 3) Description of incident 4) Factors that contributed to the incident 5) Recommendations from the investigation. The employer is required to establish a system to promptly address the incident report findings and recommendations, documenting all resolutions and corrective actions. Incident reports shall be reviewed with all affected personnel whose job tasks are relevant to the investigation and retained for five years. n. QUALITY CRITERIA REFERENCES A. 1910.119(m).: Incident Investigations m. VERIFICATION OF PROGRAM ELEMENTS CriMfk Bifc.wf Mai Y/N A. Records Review 1. Has each incident been investigated which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemicals in the workplace? FIELD NOTE JtEFEXEMCEm: .119(m) (1) -te. 2. Have incident investigations been initiated as promptly as possible, but not later than 48 hours following the incident? FIELD NOTE REFEXENCEO: .119(ns) (2) A-49 3. Have incident investigation teams been established? Do the teams contain at least one person knowledgeable in the process involved in the incident,, and other members with appropriate knowledge and experience to thoroughly investigate and analyze the incident? Has a contractor employee been included in the team if the incident involved work of the contractor? field note referenced: .119(m) (3) 4- Have incident investigation reports been prepared at the * conclusion of the investigation which include at minimum: Date of the incident? Date the inspection began? A description of the incident? The factors that contributed to the Incident? Any recommendations resulting from the investigation? .119 <m) (4) FIELD NOTE REFERENCED: te 5 *. Has a system been established to promptly address and resolve the incident Investigation report findings and rscommendations? FIELD NOTE REFERENCES): fOlAGfijUife {bUjXU " 1' (XoDt/T +ftrry . 1 .119(m) <S) YeS 6. Have resolutions and corrective actions from the incident investigation reports been documented? FIELD NOTE REFERENCED: .119(m) (5) 7. Have incident investigation reports been reviewed with all affected personnel whose job tasks are relevant to the incident findings including contract employees, where applicable? FELD NOTE RFERBCEm: .119)m) (6) 8. Are incident investigation reports retained for five years? FIELD NOTE REFERENCED: .119(m) (7) .. A--50 NGC 12393 B. On-site Conditions 1. Do observations of a representative sample of process components involved in incident investigations indicate that recommendations have been resolved? (Compare the corrective actions outlined in the investigation documentation with the actual equipment# procedures, material use, etc.) FIELD NOTE EETEXENCEtf): .119(m) (5) YtrS C. Interviews 1. Baaed on interviews with a representative number of operators, maintenance employees and contractor employees, have all incidents that resulted in or could reasonably have resulted in a catastrophic release of highly hazardous chemicals in the workplace, been investigated? FIELD NOTE UFGUNCEOk .119(m) Yes (1) 2. Based on interviews with a representative number of the members of past investigation teams, do the teams contain at least one person knowledgeable in the process involved in the incident, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident? Has a contractor employee included in the team if the incident involved work of the contractor? FIELD NOTE REFE3LENCEIS): .119{m) (3) 3. Based on interviews with a representative number of employees whose job tasks are relevant to the past incident investigation findings, have the investigation reports been reviewed with the affected personnel? FIELD NOTE RFEJlJ*CEa>: 119(m) (6) ie. For additional information on Incident Investigations# see Appendix D, references 9. and 24. A-51 ngc 12394 1910.119 (n): EMERGENCY PLANNING AND RESPONSE I. PROGRAM SUMMARY Xha intent of this paragraph is to require the employer to address what actions employees are to take when there is.an unwanted relaane of highly Hazardous chemicals. The employer must estaivxj.sn ana implement an emergency action plan in accordance with the proviaiona of 29 CFR 1910.38(a) and include procedures for handling small releases,. Certain provisions of the hazardous waste and emergency response standard, 29 CFR 1910.120(a), (p), and (q), may also apply. [NOTE: 1910.120(a) addresses scope, application, and definitions for the entire standard. 1910.120(p) addresses treatment, storage, and disposal (TSD) facilities under the Resource Conservation and Recovery Act (RCRA). 1910.120(q) addresses requirements for facilities that are not RCRA TSD's, where there is the potential for an emergency incident involving hazardous substances. Cleanup operations--including corrective actions and post emergency response cleanup--are covered by 1910.120(b) through (o). For further guidance, refer to the forthcoming directive on 29 CFR 1910.120.) n. QUALITY CRITERIA REFERENCES A. 1910.119(n) B. 1910.38(a) C. 1910.120(a),(p),(q) D. 1910.165 E. 1910.1200 F. 1910.36(b) m. VERIFICATION OF PROGRAM ELEMENTS Mm Y/N A--52 MGC 12395 A. Records Review 1* Has an emergency action plan been established and implemented for the entire plant in accordance with the requirements of 1910.38? Does the plan address the following: Escape procedures and routes? Procedures for poet~evacuation employee accounting? Preferred means to report emergencies? Duties and procedures of employees who: Remain to operate critical equipment? Perform rescue and medical duties? The names for persons or locations to contact for more action plan information? Employee alarm systems? HELD MOTE REFERENCES): .119(n) or .38(a) (2) 2. Is the plan written if the facility has more than ten employees? , FIELD NOTE REFERENCED .38(a) (1) 3* Is there sufficient number of persons designated and trained to assist in the safe and orderly emergency evacuation of employees? FIELD NOTE RS'ERENCEIS): .38(a) (5)(i) 'te 4. is the plan reviewed with each employee covered by the plan: initially when the plan is developed; and whenever the employees' responsibilities or designated action under the plan change; and whenever the plan is changed? FIELD NOTE REFERENCE**): 38(a) (5)(ii) He* S. Does the emergency action plan cover procedures for handling small releases? FIELD NOTE REFERENCED* .119{n) A~53 N0c 12396 6. la an alarm system established and implemented which complies with 1910.165? Are the alarms: -- Distinctive for each purpose of the alarm? Capable of being perceived above ambient noise and light levels by all employees in the affected portions of the workplace? Distinctive and recognizable as a signal to evacuate the work area or perform actions designated under the plan? Maintained in operating condition? Tested appropriately and restored to normal operating condition as soon as possible after test? Non-supervisad systems tested not less than every two months? Supervised systems tested at least annually? Serviced, maintained, and tested by appropriately trained persons? Unobstructed, conspicuous and readily accessible, if they are manual alarm systems? FIELD NOTE lFEUNCEOh .165 (b-e) 7. Does the written emergency response plan meet the requirements of 1910.120 (a), (p), and (q), if appropriate? (See the NOTE at I., Program Summary. clean-up operations required by a governmental body are addressed in .120(a); treatment, Btorage, and disposal (TSD) facilities under the Resource conservation and Recovery Act are addrassed in .120(p); and .120(q) addresses requirements for emergency response no matter where they occur, except that it does not cover employees engaged in operations at TSD facilities or hazardous waste sites.) FIELD NOTE JLEFttB+CECtt: .120(a) .120(p) .i20(q) 6 0 A-54 12397 8. If employees are engaged m emergency response (except clean-up operations), does the plan address the following: Coordination with outside parties? -- Personnel roles, lines of authority, training, and communication? Emergency recognition and prevention? Safe distances and places of refuge? Site security and control? Evacuation routes and procedures? Decontamination? Emergency medical treatment and first aid? Emergency alerting and response procedures? Critique of response and followup? PPE and emergency equipment? FIELD NOTE ftEFEftBfCECT? % A - yUjfc |/2|- Tt>T#t) L-CTtfL- ft*. Cc*C G*COp . 120(g) \ B. On-site Conditions 1. Do observations of a representative sample of alarm systems indicate that they comply with the requirements in .16S(b-e>? Are the alarms: Distinctive for each purpose of the alarm? Capable of being perceived above ambient noise and light levels by all employees in the affected portions of the workplace? Distinctive and recognizable as a signal to evacuate the work area or perform actions designated under the plan? Maintained in operating condition? Tested appropriately and restored to normal operating condition as soon as possible after test? (Be present for an alarm teat if possible or review video if available.) Tested no greater th?n every two months? Serviced, maintained, and tested by appropriately trained persons? Unobstructed, conspicuous and readily accessible, ~if they are manual alarm systems? HELD NOTE HEFEUENCEOk . 165 (b-e) 2. Do observations of the evacuation routes indicate that they are not blocked, locked, or barricaded? HELD NOTE HEFEJUENCEO: .36(b) (4) A.-55 NGC 12398 3. Do observations of the evacuation routes indicate that there arB readily visible signs for evacuation routes leading to safe locations? HELD NOTE REFERENCES* frC-E 10 P&OO&OQjZ &0OfJ - TO P&tflPQ' TitflcxXM^cxjr PurtJT so PttJ&oE (Ajolu Routed fuufi) -36(b) (5) 4. Do observations of a representative sample of the evacuation route signs during dark conditions indicate that they are adequately illuminated? FIELD NOTE REFERENCED): -36(b) (6) C. Interviews 1. Based on interviews with employees who have been identified as likely to discover releases or assigned other emergency response duties, are they provided training? Is the training based on the duties they are expected to perform? .120(q) (6) FIELD NOTE REFERENCED* 2. Based on interviews with employees who are likely to discover hazardous substance releases, can they demonstrate 'competency in the provisions listed in the first responder awareness level: Understanding what hazardous substances are, and the risks associated with them in an incident? Understanding potential outcomes associated with an emergency when hazardous substances are present? Ability to recognize the presence of hazardous substances in an emergency? Ability to identify the hazardous substances, if possible? Understanding the role of the first responder awareness individual in the employer's emergency response plan, including site security and control and the U.S. Dept- of Transportation's Emergency Response Guidebook? Ability to realize the need for additional resources, and make' appropriate notifications to the communication center? 120(q) (6)(i) FTFI H NOTE REFERENCED): tVS r A-56 NGC 12399 8. If employees are engaged in emergency response (except, clean-up operations), does the plan address the following: Coordination with outside parties? -- Personnel roles, lines of authority, training, and communication? Emergency recognition and prevention? Safe distances and places of refuge? Site security and control? Evacuation routes and procedures? Decontamination? Emergency medical treatment and first aid? Emergency alerting and response procedures? Critique of response and followup? PP6 and emergency equipment? nELDwre*EFEMcEtr 4'TeaJtfC4ft*5 ft*. Cc*e GeoJ *eup- - Tt>Trtu) -120{q) B. On-site Conditions 1. Do observations of a representative sample of alarm systems indicate that they comply with the requirements in .165(b-e)? Are the alarms: Distinctive for each purpose of the alarm? Capable of being perceived above ambient noise and light levels by all employees in the affected portions of the workplace? Distinctive and recognizable as a signal to evacuate the work area or perform actions designated under the plan? Maintained in operating condition? Tested appropriately and restored to normal operating condition as soon as possible after test? (Be present for an alarm test if possible or review video if available.) Tested no greater than every two months? Serviced, maintained, and tested by appropriately trained persons? Unobstructed, conspicuous and readily accessible, `if they are manual alarm systems? HELD NOTE KEFEUNCEBfe . 165 (b-e) !i 2. Do observations of the evacuation routes indicate that they are not blocked, locked, or barricaded? FIELD NOTE XEFEXEHCECS): .36(b) (4) v A-55 NGC 12400 3. Do observations of the evacuation routes indicate that there are readily visible signs for evacuation routes leading to safe locations? -36(b) (5) FIELD NOTE EEFEMXCEO): (U P&>t&OQ. &OC(* - r0eBt> TO P(2W& Ttf&atJiM-c*Jr PuttJT 5o pfctt_e -MATTOil 4. Do observations of a representative sample of the evacuation route signs during dark conditions indicate that they are adequately illuminated? FIELD NOTE REFSlBfCE(5te -36(b) (6) C. Interviews 1. Based on Interviews with employees who have been identified as likely to discover releases or assigned other emergency response duties, are they provided training? Is the training based on the duties they are expected to perform? . 120(q) (6) FIELD NOTE REFEUNCEtSk 2. Based on interviews with employees who axe likely to discover hazardous substance releases, can they demonstrate competency in the provisions listed in the first responder awareness level: Understanding what hazardous substances are, and the risks associated with them in an incident? Understanding potential outcomes associated with an emergency when hazardous substances are present? Ability to recognize the presence of hazardous substances in an emergency? Ability to identify the hazardous substances, if possible? Understanding the role of the first responder awareness individual in the employer's emergency response plan, including site security and control and the U.S. Dept, of Transportation's Emergency Response Guidebook? Ability to realize the need for additional resources, and make* appropriate notifications to the communication center? .120(q) <6)(i) FIELD NOTE REFERENCED j V A-56 NGC 12401 3. Baaed on interviews with employees who will take defensive action in containing and controlling a release as part of the response, can they demonstrate the competencies for a first responder operations level: Knowledge of the basic hazard and risk assessment techniques? Knowledge of how to select and use proper PPE provided to them7 Understanding of basic hazardous materials terms? Knowledge of how to perform basic containment, confinement, and control operations within the capability of their unit? Knowledge of how toimplement basic decontamination procedures? Knowledge of relevant standard operating procedures and termination procedures for a response? 120(q) (6)(ii> FIELD NOTE REFERENCE!S): 4. Based on interviews with employees who will take offensive action in containing and controlling, a release as part of the response, can they demonstrate the competencies for a hazardous materials (HAZMAT) technician: Knowledge of how to implement the employer's emergency response plan? Knowledge of the classification, identification, and verification of known and unknown materials using field survey instruments and equipment? Ability to function within an assigned role in the Incident Command System? Knowledge of how to select and use proper specialized chemical PPE provided to them? Understanding of hazard and risk assessment techniques? Ability to perform advanced control, containment, and/or confinement operations within the capability of their unit? Understanding of how to implement decontamination procedures? Understanding of termination procedures? Understanding of basic chemical and toxicological terminology and behavior? .120(q) (6) (iii) FIELD NOTE REFERENCES* 5. Based on interviews with a representative number of operator and maintenance employees, do they know the emergency action plan to protect themselves in an emergency? FIELD NOTE REFERENCED): -38(a) A-57 NGC 12402 1910.119 (o): COMPLIANCE AUDITS I. PROGRAM SUMMARY The intent of this paragraph is to require employers to self-evaluate the effectiveness of their PSM program by identifying deficiencies and assuring corrective actions. Minimum requirements include: audits at least every three years; maintenance of audit reports for at least the last two audits; audits conducted by at least one person knowledgeable in *the process; documentation of an appropriate response to each finding; documentation that the deficiencies found have been corrected. II. QUALITY CRITERIA REFERENCES A. 1910.119(0): Compliance Audits B. 1910.119(c): Employee Participation m. VERIFICATION OF PROGRAM ELEMENTS C(M> m------- Mm Y A. Records Review 1. Has the employer certified in writing that there has been an audit of compliance with PSM at least every three years? FIELD NOTE REFERENCED: .119(0) u> 2. Do the audit reports include an evaluation of all the required paragraphs of the PSM standard? FIELD NOTE REFERENCED: .119(0) (1) 3. Was the compliance audit conducted by at least one person who was knowledgeable in the process? FTELD NOTE REFERENCES): .119(0) (2) 4. Has a report of the findings been developed for each audit? FIELD NOTE REFERENCED .119(0) (3) i % , * A-58 NGC 12403 5. Haa the employer promptly determined and documented an appropriate response to each of the findings? FIELD NOTE REFERENCED): .119(0) (4) Yif5 6. Does the employer document that deficiencies have been corrected? FIELD NOTE REFERENCED): .119(0) (4) Ye> 7. Has the employer retained the two most recent compliance audit reports? HELD NOTE REFERENCED): .119(0) <5) B. On-site Conditions No observations are required; on-site conditions will be cited under other paragraphs* .119(0) (4) C. Interviews 1. Based on interviews knowledgeable in processes? FIELD NOTE REFERENCED): with auditors, are they .119(0) (2) 2. Based on interviews with a representative number of employees and their designated representatives, do they have access to compliance audit information? FIELD NOTE REFERENCED): .119(c) (3) `' ' ' "1I -1 --1~ ' i i. i B A-59 NGC 12404 1910.119 (p): TRADE SECRETS I. PROGRAM SUMMARY The intent of this paragraph La to require employers to provide all information necessary to comply with the standard to personnel developing paragraphs (d), (e), (f), (n) and (o) without regard to possible trade secrets. In addition, employees and their designated representatives shall have access to trade' secret information contained within documents required to be developed by the standard. II. QUALITY CRITERIA REFERENCES A. 1910.119(p): Trade Secrets B. 1910.1200: Hazard Communication m. VERIFICATION OF PROGRAM ELEMENTS Cnwria Hihwrna YMat If* A. Records Review 1. Has all information necessary been provided to those persons responsible for compiling the process safety information (paragraph d), those assisting in development of the PHA (paragraph e), those responsible for developing the operating procedures (paragraph f), and those involved in incident investigations (paragraph m) and emergency planning and response (paragraph n), and compliance audits (paragraph o) been yithout regard to possible trAde secret status of such information? FIELD NOTE HEFEXENCE/S): (P) (1) 2. Do employees and their designated representatives have access to trade secret information contained in the PHA and to other documents required to be developed by the standard, subject to the provisions set forth in 1910.1200(i)(1) ?through (i)(12) FIELD NOTE RFEKEHCE(S>! .119(p) 13) B. On-site Conditions Not applicable. A-60 NGC 12405 C. Interviews Employees involved in specific duties: 1. Baaed on interviews with a representative number of employees involved in compiling the process safety information, developing PHA's, developing operating procedures, investigating incidents, planning and responding to emergencies, and auditing compliance, has all information necessary been provided to them without regard to possible trade secret status of such information? FIELD NOTE REFERENCE'S): -119(p) (1) Employees and Representatives* 2. Baaed <3n interviews with a representative number of employees and their designated representatives*, do they have access to trade secret information contained within the PHA and other documents required to be developed by the standard? (Note that this access is subject to the provisions set forth in 1910.1200(1)(1) .) .U9(p) (3) FIELD NOTE REFE&ENCECT: ii------iJU. mms------ 111 1-----L._i-- j_g-igsi--------------------- -- ; j j A-61 NGC 12406