Document OrRpNmqKJ2bRB7BJqn6Z07jK

.4-79) Shell Oil Company Shell Chemical Company Interoffice Memorandum APRIL 1, 1987 FROM: SENIOR ENGINEER - PROCESS ENGINEERING ENVIRONMENTAL/UTILITES DEER PARK MANUFACTURING COMPLEX TO: ALL MANAGERS AND SUPERVISORS DEER PARK MANUFACTURING COMPLEX SUBJECT: MANDATORY HEALTH & SAFETY TRAINING REQUIREMENTS Attached is some information on all mandatory Health & Safety training requirements that apply to DPMC. Although in general we have an excellent H&S training program, it is essential all the minimum OSHA and Shell requirements are met. There are three attachments. Attachment I is a simple listing of all topics which must be covered, grouped by "Basic/Initial Training" and "Annual Refresher Training." Attachment II describes how the training is accomplished (e.g. which.groups receive which types of training, at what times, who provides it, and what resources "are available). Attachment III is a reference document which lists information on each training subject. I recommend that each Department review the list to ensure that all training and documentation for which they are responsible is being carried out. As part of our DPMC Compliance Audit Program, all training records will be audited in the fourth quarter of this year. If you have any questions on the requirements, please contact me at X-7781. C. M. Hutchi CMH:mh Attachments cc: Deer Park "i". E. Gillespie All Safety Personnel Safety Satellite Head Office K. C. Crawford BCBD8709101 LAN1021909 FILE COPY ti/RDn SPIT ELITE FILE H/fiDR l EH ABS-005537 Attachment I HEALTH & SAFETY TRAINING REQUIREMENTS BASIC/INITIAL TRAINING EMERGENCY ACTION PLAN/EMERGENCY RESPONSE PLAN FIRE PREVENTION PLAN V PORTABLE FIRE EXTINGUISHERS WARNING SIGNS EMBRYO/FETUS COUNSELING V V ALL NEW OPERATIONS/FIELD EMPLOYEES EMERGENCY ACTION PLAN/EMERGENCY RESPONSE PLAN FIRE PREVENTION PLAN PORTABLE FIRE EXTINGUISHERS WARNING SIGNS EMBRYO/FETUS COUNSELING HAZARD COMMUNICATION HEARING CONSERVATION TRAINING (AUDIOMETRIC TESTING) RESPIRATORY PROTECTION TRAINING SMOKEHOUSE (FIT TEST) {ASBESTOS TRAINING AREA/JOB/CRAFT/SKILL SPECIFIC TRAINING HAZARD COMMUNICATION - LOCAL INFO EMERGENCY ACTION PLAN/EMERGENCY RESPONSE PLAN - LOCAL INFO FIRE PREVENTION PLAN - LOCAL INFO RESPIRATORY PROTECTION - LOCAL INFO EMBRYO/FETUS COUNSELING HAZARDOUS WASTE SITE OPERATIONS LPG STORAGE/HANDLING FACILITIES STORAGE TANKS EMERGENCY RESPONSE TEAMS ASBESTOS (FIT TEST) VCM LEAD FIRE BRIGADE AERIAL LIFT EQUIPMENT POWERED INDUSTRIAL TRUCKS (FORKLIFTS) CRANES SLINGS LAM 021910 MECHANICAL POWER PRESSES WELDING EQUIPMENT ABS-005538 ANNUAL REFRESHER TRAINING PORTABLE FIRE EXTINGUISHERS ALL OPERATIONS/MAINTENANCE EMPLOYEES PORTABLE FIRE EXTINGUISHERS HEARING CONSERVATION TRAINING (AUDIOMETRIC TESTING) RESPIRATORY PROTECTION ANNUAL TRAINING BIANNUAL SMOKEHOUSE TRAINING (BIANNUAL FIT TEST) ASBESTOS TRAINING AREA/JOB/SKILL SPECIFIC TRAINING VCM LEAD HAZARDOUS WASTE SITE OPERATIONS EMERGENCY RESPONSE TEAMS (SEMI-ANNUAL ASBESTOS FIT TEST) NOTES: (1) ANNUAL ASBESTOS TRAINING GENERALLY APPLIES TO ALL O&M EMPLOYEES, WHILE SEMI-ANNUAL FIT TESTING IS ' ONLY GIVEN TO A SELECT GROUP, PRIMARILY INSULATORS (2) ITEMS IN PARENTHESES (AUDIOMETRIC, FIT TESTING) ARE TESTING REQUIREMENTS AND INCLUDED AS REMINDERS, SINCE THEY ARE SOMETIMES HANDLED ALONG WITH TRAINING lam 021911 ABs ~05539 Attachment II IMPLEMENTATION OF HEALTH & SAFETY MANDATORY TRAINING REQUIREMENTS BASTC/TNTTTAT, TRATNTNO All new employees receive formal H&S training as part of the New Employee Orientation conducted by the Training x Department. Employees aire grouped for Orientation either as Support Staff, Professional Staff, or Operations Employees. When the new employee arrives at his assigned job, or is reassigned to another job, he receives additional H&S training specific to his assignment. Also, training is required for some specialized skills not necessarily related to job assignment. New Support Staff Support Staff receive Phase I training (one day), plus a supplemental day of training, both of which include some H&S training. These elements must be included: ToPiS Fire Prevention Plan Portable Fire Extinguishers Warning Signs Emergency Plans Presented bv Safety Safety Safety Safety Already in The presenters are responsible to be sure the required material is covered. Safety must assure Warning Signs is covered in one of their segments. Each Department Manager is responsible for counseling their new female employees on the Embryo Fetus Protection policy and local potential for exposure. A video tape is being prepared which covers the general aspects of the policy (contact Industrial Hygiene). They are also responsible to be sure the employee is familiar with any local emergency plans, if applicable (e.g. evacuation plan). The Training Department conducts two full days of HS&E training for new professional staff, known as Phase II Training. These elements must be included: LAM 021912 o * -0 Topic. Presented by Already in Program? Hazard Communications Hearing Conservation Emergency Plans Fire Prevention Plan Respiratory Protection Portable Fire Extinguishers Warning Signs Industrial Hygiene Safety Safety Safety Safety Safety Safety Yes Yes Yes Yes Yes Yes Not sure The H&S presenters are responsible to be sure the required material is covered. Safety must assure Warning Signs is covered in one of their segments. All Department Managers are responsible for counseling new female employees on the Embryo Fetus Protection policy and local potential for exposure. A video tape is being prepared which covers the general aspects of the policy (contact Industrial Hygiene). They are also responsible to be sure the employee is familiar with any local emergency plans, if applicable (e.g. evacuation plan). New Operations Employees. General As part of their Phase I training, new Operators get two days of HS&E training essentially the same as new Professional employees. The same requirements apply to this portion of their training, with the addition of Asbestos training. In the past, initial Asbestos training has been the responsibility of each Department: But it is logical to move it to Phase I, since it does apply to all employees who may come in contact with asbestos. The presentation could be included in one of Safety's segments. (The Departments are still responsible for Asbestos refresher training, discussed later.) New operations employees also receive audiometric and respirator fit tests. New/Reassigned Operators/Craftsmen. Area Specific or Job Specific When any new or reassigned operator or craftsman arrives on the new job, his initial H&S training must include: Local Hazard Communication information Local Emergency Plans Local Fire Prevention Plans Local Respiratory Protection procedures LAM 021 Qn *'* All females must be counselled on the Embryo Fetus Protection policy and local potential for exposure. A video ABs~00554i tape is being prepared which covers the general aspects of the policy (contact Industrial Hygiene). If they are reassigned employees, they should already be familiar with the policy and only need to be counselled on local potential for exposure. Depending on the Department or job, some additional H&S training (testing) requirements may apply. These are: LPG Storage/Handling Facilities Storage Tanks VCM Training Lead Training Aerial Lift Equipment Powered Industrial Trucks (Forklifts) Cranes Slings Mechanical Power Presses Welding Equipment Hazardous Waste Operations Emergency Response Teams (Asbestos fit test) If operating or maintaining any of this equipment or handling any of these materials is part of the employees job, then it is the responsibility of the Department to assure the employee is trained and to keep the record. In practice, if these items are part of the job qualification, they are included in the job training program. The documentation can be handled in one of two ways: 1. Document that each individual topic was covered, or 2. Be able to demonstrate each topic is covered in the job training program, and document the program was completed. Skill Specific Training Sometimes an employee needs a new skill that is not part of the job training. For example, fire crew members must be trained; that is not part of the employee's job requirements and is handled on an "as needed" basis. Another example is aerial (personnel) lift equipment. Some craftsmen receive this training as part of their job. But an operating Department may want some operators to have this skill, and it was not part of their job training. In this case, they must be trained, and their training documented. The area of "skill training" could include these topics: Fire Brigade Aerial Lift Equipment Powered Industrial Trucks Cranes (Forklifts) LAM 021914 ABS-005542 * <-V" Slings Mechanical Power Presses Emergency Response Teams PERIODIC REFRESHER TRAINING All Employees All Department Managers must provide portable fire extinguisher training for their employees once/year. They should contact Safety to arrange for hands-on training, or contact Training to use their video tape. All Operations/Maintenance Employees In addition to fire extinguisher training, each Operations/Maintenance employee must receive refresher training (testing) on: Tonic Frequency Responsible Portable Fire Extinguishers Hearing Conservation (Audiometric test) . Respiratory Protection Training Smokehouse training (Fit test) Asbestos Training Annual Annual Annual Annual Biannual Biannual Annual Department Department Medical Department Department Industrial Hygiene Department To conduct Portable Fire Extinguisher Training, contact Safety to arrange for hands-on training, or contact Training for a video tape. Contact Safety to arrange for smokehouse respiratory training. A video tape for asbestos training is available through Training. Area or Job Specific Training Depending on the employee's area or job assignment, the following refresher training is required on an annual basis T2Ei VCM training Lead training Emergency Response Team- Safety personnel Frequency Annual Annual Annual Department Department Safety LAM 021915 ABS-005543 Topic (Con*t) Hazardous Waste Site Operations (Asbestos fit test) Frequency Responsible Annual Department Semi-annual Industrial Hygiene Skill Specific Training Members of Emergency Response Teams must receive refresher training. These teams are: Team Frequency Fire Brigade Haz Mat Team Response Action Team Annual Annual Monthly Rev. 3/31/87 CMH LAM 021916 ABS-005544 M -- a* ns .a M it aj in ai c= C Q) cB ofMlj w -- u. M X \ JuC ak_ a h ai M X ci ^ -- tn u= ot i_ o o a* ajajk.Uk. > >- --< .C aj > e aj > cn aj u ca aj x ui n O > o O Ol c a o > a i a aa u on >. m a>e m e Ma sin a u aj aj W ns J3 O. -- -- "S X *U e a 4J M x on uoi ^in or 1 u m a ai cn mi Ol M ou' oj u aaj c-ans 01 ai a- jz at m- e at X nt aj ns m o.. cn e k. jc l a aj cn a *a ai a a CU in a u u co **o aaj m *j m a Ol 3 aj m aj m umc -- a'< aajj A o c aa -J L O O OJ --. *a --< w| m cn k_ AJ u cn xj=. 2: *a OJ fc- -- aj .0 ui u o c o--* --m AoJ JqZj AJ Z "O A. *0 qj zzz e 0 01 k cn a c c --o ui .a ae Cl U s aAJ k_ -- >. ^3 OJ A- OJ = AOu 4i aj 01 <u c 3 e: u m L at m m in mOJ A U A 3 3 u n in -- .a a m- o t. aj 0i 0 j= k_ m x3 ai in ---- o *s m c a. sa m m ai aj ai m- c > OAA ai O m u in a. -a .a c aj a 3 -o -- fli 0 e c cj m a u HEALTH It SAFETY TRAINING REOUIREHEHTS-DPHC fcMT-mswn* * LAM 021917 ABS-005545 For Maintenance, job training suffices. For Operations, each Dept handling LPB should assure hazards, safe handling procedures are covered in training aanuals or Dept procedures. Per OSHA 1910.110(b)Ili) "Personnel perforeinq installation, reeoval, operation, and eaintenanee work shall be properly trained in such function." regarding LP6 storage/handling. F u lfille d by regular jab training. ll us a C c3Okn- cCn3 w. ui jaez aai. -- o -- aj in c O 3 i. A^ O O O CL O *i -- - a XI Tl mo A O T3 cl O 3k + >> US Ol M. 8 aLt l 41 a> js a o A ^US O--I C C Or* <-* in as e ai oj 3 si n-* 3- m e-l 4J BL--O > -< U Q. I 9 81 81 o O 81 M C 3X in lu 4J M c x: oj ai * e a. x in a a 3 >- o ai - >- -* l. o C *-- k. U 81 M x C <3 O C 9 OIo_, OJ O *-- V OI XI a an I 'Oj cn c Oa T l. Cn 8i w xr n jfc oa > Ai u r ti u cl k. o m um aa ll' 8-= --. uj -k> c o oj a M o. x an > VI 1 u U k. ui ai ui u< u m at 3 *d in -- qi Ai l La.t laiti c 3-* >Q umi vo. a* u at h. aLi O ^8k1. Ol lO. tn me: mm J3tz3 Cau x - in cp qi os oi e > O >. ui -- > a aOi ou qai e. a <E ai ^ -o in oi ai as ai in 4^ u B XI > >* O* A Ai iQ Ol l_l c VA -13 _e A, Ml 3 c w A *- 4i T3 u c o i c. a in O Ai ~ L A > ui u "O CJ oQj. Am at eoti k. 3 E O - >- *o -<* i q jc a aani --a aui X ^ a oi 8k.i L< 3a > ^ -- ai o _ m *^a*o--~s .AA-->ii a>i u^ aoi. *_ aeos -- o. u mvb "cSr. ^ a ? O ann s j: A oi cn b. C5A *13c ai XAi k. Mkl- cT3*l bm M ^XwA3t T! _ C O --* na au o"* -- k. cn a* O. AL.i ^ T3 a_ d.Z e aia c ._ c: -o -- c 3 xda e S>I .Mc U3C eo Ol *9 o -a ui *i La Ca a si -. T ^O Ol Ol o e o 3 u o u --. .** at 8) k- k_ > c 01 O o > u . . ^*0AI O a-J 3 an m AI *0 3 kj LC O C L A <8 Ai CO q. o -- k- A A C M O O L ka- CJ 3 O *"-- 13 *- ^ Ol O an u <8 O U) k_ O " U fll L an l oa tj o. n n > L e in o ^ o _tn_ ui o ii M . i* aj AM m <!). A M Ai V + eg E A ui 3 CJ O 01 c *o m Ai S > c oi X A A k. C S3 A* 01 *3 -A 88 AI C 3 *0 C --- U fit A A O Qi -A fc_ 01 k. A 0i a- CL <c o Field personnel who work around LPG All O/H Depts LP6 STORAGE AND HANDLING FACILITIES *-- CJ 3C CJ = x <C LU _i >. Ocn CL. CJ LU LU 5E x: Lft ajJ LU s CD --. Q LAM 021918 ABS-005546  It CD tl i9 FIRE BRIGADE HIS leaders/*ebers Per OSHA 1910.156 the f i r e brigade Bust be tra in e d . Leaders lore training than eabers. Train also on special hazards. This is handled by the fire chief, uho also aaintains the training records. No changes needed. O' a ccn h* *4- GJ kua.ti us eB1 4- Qj > -* hn in Oi ^ wO. J4L^ .ro IX u Oi acmj ^--e*moaji ai m id Hm. *m e cn u cj _ m oi 4J Oi ka-j Cai > Ou > a *o o c. c. --. U O. > ai in x cn o c= C U <P4 0i ns in > -- *aat -- ~ <= o *-> *n a r Co- *o 3to= m ocl. ez m a a w. > k. Of in in -- e= a oj u in o i. >. Ul CL4C a. a m HI Hi ~ in .o --*o c 3 oj at ai Ul a *C <r oj i. in a: u o in Hi as > n ns O as u --ocj i=on3 <3=r c *o cn a s. a in ns k N k. oi m ai om. Co aG=J C OI n -3 U<u 4cJ 1ai a. iu t- k. Hi uj cn iX x to 0<3X t3aE iX. -- **4 LAM 021919 ABS-005547 c: 9 O TD - 4^ U MO l > U m k. a Si 0*44 * ca e --4 --4 ai C -4-* > JC n ** ai H M k. *^ ai u s i. 3C . Q 44 AI Cl >- 4-> >. a tn -- ai c xi m oi T tc>: _u uai o* ^4 O. tt o ci m 4i a 44 3 <T *44 03 cu Cl >- 4 > O 0.44 ^ ai a -- o o a SC " M * "v Ol \ fl) <f 44 u. i k_ m > acn acn u *1 in ai > -- >. > 4 -- a O' ns c M k. --- e a * *TB *** & U 44 -2\T v Cl Cl TD >. -->4 --a --4 O > .-4 o cx --4 in w tn u u " -9 Cl 4wi Ca 3in xw cn cr c 1a1i1 ^c i *a c c 44 O 4 >. n in 9 D *3 U tl -- eea > k. 4- O k. 4J a M * 44 a 44 <d a Cl 44 4J ci in 4 m ci *-- at 44 i. a t -4 m at LU Cl IX >4 o- a Cl *44 k. 9 (J cn ti k3oa -- - in m -- k. a 44 Cl 40 UJ K . in it 44 <u n C3 JC Ma --. a <--c x.e -'.-/4svr- \ LAM 021920 ABS-005548 1 ABS-005549 17 AERIAL LIFT EQUIP Departient resp lor equipaent All operators (see note below! Per OSHA 1910.67, eiployees ust he 'trained to operate' Training w ill work with Maintenance to l i l tdevelop a prograe to train people in the operation of aerial (personnel) tlote: The teras "operators' and "inspectors' here refers to the equipaent operators and inspectors--!t is not a job classification. CD 5 LAM 021922 no 04 >i 23== OS C_3 ABS-005550 23 MECHANICAL POWER PRESSES Departaent reap for equipment (I) All inspectors Per OSHA 1910.217, the esployer is required to insure We have one eechanical power press, in the coipetence of inspection and naintenance personnel, the boilenakers' shop.