Document OE654GEymDoGko5BL3bazYnQM

CHEMICAL MANUFACTURERS ASSOCIATION Robert A. Roland President January 26, 1990 Mr. Thomas G. Grumbles Environmental Quality Manager Vista Chemical Company 900 Threadneedle Houston, TX 77079 Re: Responsible Care: Draft Process Safety Code of Management Practices and Member Self Evaluation Form Dear Mr. Grumbles: The draft Process Safety Code (PSC) of Management Practices is enclosed for your Company's review. Developed by the Engineering and Operations Committee through its Safe Plant Operations Task Group (roster enclosed), the draft reflects the combined efforts of dozens of experienced professionals from a wide cross section of the chemical industry. A separate code area, which is now being considered for development, will address occupational safety and health issues and will complement the PSC. Ultimately, these two code areas, process safety and worker health and safety, will comprise a single Safe Plant Operations Code. Please review the draft code and provide your comments to CMA by March 26, 1990. A response form is enclosed for your convenience. The Process Safety Code is intended to serve as a plan of action for com panies both large and small in the continuous improvement of their process safety performance. It is, as the purpose states, "designed to prevent fires, explosions and accidental chemical releases". By so doing, the chemical industry can provide even greater protection to its workers, the environment and the communities in which we are located. The elements of the PSC are closely harmonized with the Process Safety Management Principles developed and published by the American Institute of Chemical Engineers' Center for Chemical Process Safety and the American Petroleum Institute's Process Hazard Management Guidelines. Although similar in approach, this code extends beyond the scope of the other documents, as follows: o The code is an obligation of membership whereas the others are voluntary or advisory in nature. VVV 000011089 2501 M Street, NW Washington. DC 20037 202-887-1106 Telex 89617 (CMA WSH) Mr. Thomas G. Grumbles January 26, 1990 Page 2 o The code requires a commitment from senior management to achieve process safety improvements. o The code requires companies to share a relevant safety information, obtained in the course of accident or near-miss investigations, with industry, government and the community. o The code requires companies to substantially address public com ments and concerns in designing and implementing process safety systems in the plant. o The code requires provisions for control in the event of emer gencies caused by external conditions (e.g., earthquakes, hurri canes , etc.). o The code requires the establishment of programs to ensure that safety critical jobs are not performed by persons impaired by drugs, alcohol or other external factors. Implementation of the PSC as an obligation of membership under Responsible Care will require the commitment of significant resources by both CMA and its member companies. Implementation will be supported by both new and existing materials from CMA, as well as other appropriate sources. An implementation resource manual is currently under development by the task group which has developed the code. With this in mind, I urge that the draft code be reviewed by everyone within your company who will be responsible for its implementation. Earlier drafts of the code were reviewed by the Responsible Care Public Advisory Panel, and by the Responsible Care Coordinators who attended the first Coordinators Conference in June, 1989. This draft reflects advice and comments from those groups, as well as from the Engineering and Operations Committee, the Responsible Care Coordinating Group and other CMA work groups and staff. A proposed member self-evaluation form is also enclosed for your review. To assure that all member companies have an opportunity to review the code before it is sent to CMA's Board of Directors for approval in June, please submit any comments you may have in writing. I have attached a response form with questions that target specific issues. Please send the completed form and any supplemental comments to Kyle B, Olson, Director, Safety and Plant Operations, by March 26, 1990. The code drafting group will study and consider all submittals. CMA's Engineering and Operations Committee is holding an Open Forum on March 1, 1990, for member company representatives, to discuss the draft PSC in detail with its authors, raise specific questions and concerns and to suggest improvements, as necessary. The Forum will be held at the Marriott Marquis in Atlanta, Georgia. An Open Forum registration form is enclosed. Please make plans to have a representative from your company in attendance. VVY 000011090 Mr. Thomas G. Grumbles January 26, 1990 Page 3 This code represents the continuing commitment of CMA and the chemical industry to the principles of Responsible Care. It reflects our understand ing that we cannot stand pat on safety if we hope to earn the public's trust. That trust will not be achieved without considerable effort nor will it come quickly. In the long run, however, regaining the public's faith is the key to our industry's continued growth and success. cc: Executive Contacts Engineering Contacts Responsible Care Coordinating Group Attachments VVV 00G011091 DRAFT PROCESS SAFETY CODE OF MANAGEMENT PRACTICES December 11, 1989 PURPOSE The Process Safety Code of Management Practices is designed to prevent fires, explosions and accidental chemical releases. The practices are based on the principle that facilities will be safe if they are designed according to sound engineering practices, built, operated and maintained properly and periodically reviewed for conformance. Process safety is an interdisciplinary effort. Consequently, the Code is divided into the following four sections: management leadership, technology, facilities and personnel. Individually, each Practice describes an activity or approach important to preventing fires, explosions and accidental chemical releases. Collectively, the Practices encompass process safety from the design stage through operation, maintenance and training. The scope of this Code includes manufacturing, processing, handling and on-site storage of chemicals. This Code must be implemented with full recognition of the community's interest, expectations and participation in achieving safe operations. The process safety management program in each facility is complemented by workplace health and safety programs, as well as waste and release reduction programs which address and minimize releases and waste generation. These three programs, and others, will help assure that our facilities are operated in a manner that protects the environment and the health and safety of employees and the public. RELATIONSHIP TO GUIDING PRINCIPLES The Code helps achieve several of the Responsible Care Guiding Principles: o To recognize and respond to community concerns about chemicals and our operations, o To make health, safety and environmental considerations a priority in our planning for all existing and new plants and processes. o To operate our plants and processes in a manner that protects the environment and the health and safety of our employees and the public. vvv 000011-092 DRAFT - t>. 2 MANAGEMENT PRACTICES Each member company shall have an ongoing process safety program which includes: A. MANAGEMENT LEADERSHIP 1. Leadership by senior management through policy, participation, communications and resource commitments in achieving continuous improvement of safety performance. 2. Clear accountability for performance against specific goals for continuous safety improvement. 3. Measurement of safety performance, audits of compliance and implementation of corrective actions. 4. Investigation, reporting, appropriate corrective action and followup of each incident which results or could have resulted in a fire, explosion or accidental chemical release. 5. Sharing of relevant safety knowledge and lessons learned from such incidents with industry, government and the community. 6. Use of the CAER process to assure public comments and concerns are considered in design and implementation of the facility's process safety systems. B. TECHNOLOGY 1. Current, complete documentation of process design and operating parameters and procedures. 2. Current, complete documentation of process safety information relating to the hazards of materials and process technology. 3. Periodic assessment and documentation of process hazards, and implementation of actions to minimize risks associated with chemical operations, including the possibility of human error. 4. Management of changes to chemical operations to maintain or enhance the safety originally designed into the facility. VVV 000011093 DRAFT - p.3 C. FACILITIES 1. Consideration and mitigation of the potential effects of expansions, modifications and new sites on the community and environment. 2. Facility design, construction and maintenance using sound engineering practices consistent with recognized codes and standards. 3. Safety reviews on all new and modified facilities during design and prior to start-up. 4. Sufficient layers of protection through technology, facilities and personnel to prevent escalation from a single failure to a catastrophic event. 5. Provision for control of processes and equipment during emergencies resulting from natural events, utility disruptions and other external conditions. D. PERSONNEL 1. Identification of the skills and knowledge necessary to perform each job. 2. Establishment of safe work practices for operating and maintenance activities. 3. Training for all personnel to reach and maintain proficiency in safe work practices and the skills and knowledge necessary to perform their job. 4. Demonstrations and documentation of skill proficiency prior to assignment to independent work, and periodically thereafter. 5. Programs designed to assure that personnel in safety critical jobs are fit for duty and are not compromised by external influences, including alcohol and drug abuse. VVV 000011094 EXHIBIT A CHEMICAL MANUFACTURERS ASSOCIATION MEMBER SELF-EVALUATION FORM PROCESS SAFETY CODE OF MANAGEMENT PRACTICES Member Company: Name: _____________________________ Responsible Care Coordinator: Name: _____________________________ Address: Telephone: Number of facilities subject to Code: ** ******** Instructions: 1. This form is to be submitted annually to CMA by each member company. CMA will announce dates for each Code. 2. Indicate on the cover page the number of member company facilities subject to the Code. All facilities subject to the Code must be included in this report. 3. For each Management Practice on the following pages, indicate the number of facilities that have attained each stage. The total number of facilities for each Management Practice should equal the total number of facilities subject to the Code. 4. Only subject facilities owned or operated as of the reporting date should be included. oou095 5. The stages of implementation are: Stage I - No action; Stage II - Evaluating company practices against Code practice; Stage III - Developing action plan to implement Code practice; Stage IV - Implementing action plan; Stage V - Code management practice in place; Stage VI - Implementation reviewed and reaffirmed this year. MANAGEMENT LEADERSHIP 1. Leadership by senior management through policy, participation, com munications and resource commitments in achieving continuous improvement of safety performance. 2. Clear accountability for performance against specific goals for continuous safety improvement. 3. Measurement of safety performance, audits of compliance and implemen tation of corrective actions. 4. Investigation, reporting, appropriate corrective action and follow-up of each incident which results or could have resulted in a fire, explosion, or accidental chemical release. 5. Sharing of relevant safety knowledge and lessons learned from such incidents with industry, government, and the community. STAGES II III IV V VI vvv 000011096 6. Use of the CAER process to assure public comments and concerns are considered in design and implementation of the facility's process safety system. TECHNOLOGY 1. Current, complete docu mentation of process design and operating parameters and procedures. 2. Current, complete docu mentation of process safety information relating to the hazards of materials and process technology. 3. Periodic assessment and documentation of process hazards, and implemen tation of actions to minimize risks associated with chemical operations, including the possibility of human error. 4. Management of changes to chemical operations to maintain or enhance the safety originally de signed into the facility. FACILITIES 1. Consideration and miti gation of the potential effects of expansions, modifications and new sites on the community and environment. 2. Facility design, con struction, and maintenance using sound engineering practices consistent with recognized codes and standards. I II III IV V VI 3. Safety reviews on all new and modified facilities during design and prior to start-up. 4. Sufficient layers of pro tection through technology, facilities and personnel to prevent escalation from a single failure to a catastrophic event. 5. Provision for control of processes and equipment during emergencies resulting from natural events, utility disrup tions and other external conditions. PERSONNEL 1. Identification of the skills and knowledge necessary to perform each job. 2. Establishment of safe work practices for oper ating and maintenance activities. 3. Training for all personnel to reach and maintain pro ficiency in safe work practices and the skills and knowledge necessary to perform their jobs. 4. Demonstrations and docu mentation of skill proficiency prior to assignment to independent work, and periodically thereafter. ^ oo00l J0 9Q Programs designed to assure that personnel in safety critical jobs are fit for duty and are not compromised by external influences, including alcohol and drug abuse. I II III IV V VI VVV 000011099 PROCESS SAFETY CODE OF MANAGEMENT PRACTICES RESPONSE FORM 1. Both in the purpose section and at A.6. of the Management Leadership section, the Code emphasizes incorporation of public input into the safety management of our facilities. Do you agree that this element is reasonable and necessary? Explain. 2. The Code's scope includes the "manufacturing, processing, handling and on-site storage of chemicals." Does this properly define the operations that should be addressed under the Code? Explain. 3. Do you fully understand the references to "sound engineering practices"? Is greater specificity needed? Explain.________ 4. Do you feel parts of the Code are redundant? If so, which parts? 5. Do you feel the member evaluation form will be useful to monitor and evaluate your progress in implementing the Code? 6. Will the practices outlined in this draft satisfy the goals of the Code as outlined in the purpose section? Explain. WV 000011100 7. What kinds of resources will you find helpful in implementing the practices of this Code?__________________________________________ 8. ________ I have no specific comments or questions about the Code. Please return by March 5, 1990 to: Kyle B. Olson Director, Safety and Plant Operations Chemical Manufacturers Association 2501 M Street, NW Washington, DC 20037 VVV 000011101 SAFE PLANT OPERATIONS TASK GROUP Ray Olsen Chairman Exxon Chemical Co. P.0. Box 400 Baytown, TX 77522 (713)425-2593 fax: (713)425-1017 Percy Kavasmaneck EOC Liaison Union Carbide Corp. P.0. Box 6361, Bldg. 2000 South Charleston, WV 25303 (304)747-5561 fax: (304)747-5448 Philip Rasch Hoechst Celanese Corp. 26 Main Street Chatham, NJ 07928 (201)635-6917 fax: (201)231-4122 Mike McCready Union Carbide Corp. P.0. Box 8004 South Charleston, WV (304)747-2775 fax: (304)747-3084 25303 Hermann Ortega Air Products & Chemicals, Sr. Plant Manager P.0. Box 538 Admin 5 Allentown, PA 18195 (215)481-7386 Inc. Greg Scott ARCO Chemical Co. 3801 West Chester Pike Newtown Square, PA 19073 (215)359-3142 fax: (215)359-2722 Landon Kenny Tennessee Eastman Co. P.0. Box 511 Kingsport, TN 37662 (615)229-4968 fax: (615)229-3966 Leon Schaller E.I. du Pont de Nemours & Co. Nemours 11498 1007 Market Street Wilmington, DE 19898 (302)774-6194 fax: (302)774-7321 John Oldner Dow Chemical Co. 2020 Willard H. Dow Center Midland, MI 48674 (517)636-2121 fax: (517)636-0729 Vin Boyen Monsanto Co. A2NB 800 N. Lindbergh Blvd. St. Louis, MO 63167 (314)694-6007 fax: (314)694-4105 Joe Caporossi American Cyanaroid 1 Cyanamid Plaza Wayne, NJ 07470 (201)831-3452 fax: (201)831-3400 Ted Henken Chevron Chemical Co. 6001 Bollinger Canyon Rd. T-4318 San Ramon, CA 94583 (415)842-0043 fax: (415)842-5775 0001U02 Jud DeLany Proctor and Gamble Winton Hill Technical Center 6110 Center Hill Road Cincinnati, OH 45224 (513)634-7833 fax:(513)634-5481 Brynn Aurelius Shell Chemical Co. 1 Shell Plaza Houston, TX 77001 (713)241-4565 fax: (713)241-1170 William Jordan First Mississippi Corp. 700 North Street Jackson, MI 39205 (601)949-0238 fax: (601)949-0228 Adrian Sepeda Manager - Manufacturing Support Occidental Chemical Corporation P.0. Box 809050 Dallas, TX 75380 (214)404-3273 fax: (214)404-3275 Loren Wassell Monsanto Company 800 N. Lindbergh Blvd. G2WF St. Louis, MO 63167 (314)694-7002 Kerian Fitzpatrick ARCO Chemical Frankfort Road Monaca, PA 15061 (412)773-230i Win Person Henkel Corp. 2200 Renaissance Blvd. Gulph Mills, PA 19406 (215)270-8201 fax: (215)270-8103 Harry Calsing BF Goodrich 6100 Oak Tree Blvd. Indpendence, OH 44131 (216)447-7823 fax: (216)447-6245 L.V. "Larry" Csengery Shell Oil Company 777 Walker, Two Shell Plaza P.0. Box 2099 Houston, TX 77252-2099 (713)241-1314 fax: (713)241-7195 John Master ARCO Chemical Company 3801 West Chester Pike Newtown Square, PA 19073 (215)359-2200 fax: (215)359-2928 WV 00001110 3 PROCESS SAFETY CODE OF MANAGEMENT PRACTICES OPEN FORUM REGISTRATION FORM Please register the following person(s) for the Responsible Care Process Safety Code of Management Practices Open Forum to be held March 1, 1990, at the Marriott Marquis, Atlanta, GA. (The Open Forum will start at 9:00 a.m.) A check in the amount of $ ($100 per person) is enclosed. The registration fee covers continental breakfast, lunch, conference room charges, break and meeting materials. Mail registration form and a check or money order, payable to the Chemical Manufacturers Association, to: Stephanie V. Kopetz, CMA, 2501 M Street, NW, Washington, DC 20037. Refunds will be made if cancellations are received by CMA before close of business February 23, 1990. NAME_________ NAME_________ NAME_________ COMPANY_____ ADDRESS____ CITY_________ STATE_______ lPHONED_____ ZIP psreg Wv 00iU04 DATE: TIME: PLACE: ** 8:30 8:35 9:00 9:30 10:00 10:30 11:00 11:45 1:00 1:30 2:00 2:30 3:00 3:30 4:00 4:30 CHEMICAL MANUFACTURERS ASSOCIATION PROCESS SAFETY CODE OF MANAGEMENT PRACTICES OPEN FORUM March 1, 1990 8:30 am - 4:30 pm Marriott Marquis Hotel Atlanta, Georgia ************* TENTATIVE AGENDA Introduction - K.B. Olson, CMA Code Development Background - P. Kavasmaneck, Union Carbide Vice-Chairman, Engineering and Operations Committee Code Overview - R. Olsen, Exxon Chairman, Safe Plant Operations Task Group Discussion Break Presentation of Management Leadership Elements - V. Boyen, Monsanto Discussion Lunch Presentation of Technology Elements - L. Csengery, Shell Discussion Presentation of Facility Elements - H. Calsing, BFGoodrich Discussion Break Presentation of Personnel Elements - G. Scott, ARCO Discussion Closing Comments - P. Kavasmaneck, Union Carbide Adj ourn pscdof