Document QgYxz0BXG0RqR7YzmBnG83q76

QUESTIONS FOR OSHA AUDIT References: OSHA Regulation 1910.1017 Vinyl Chloride OSHA Regulation 1910.134 Personal Protective Equipment -Respiratory BFG Eng. Std. ST-404.6 Revision #11-8-75 Breathing Air Supply 1. COMPLIANCE STAFFING 1. Person in charge now -- long term - ^ 2. Reports to whom 2^3. Uescrib^ojgai^z^t^on a^d^ovej-ag^ 4. How much back-up is given by: Plant Nurse, Safety, Personnel, Production Departments REGULATED AREA gl. Define area 2. Where are precaution.signs posted j{3. How do you control access ' 4. How are daily rosters filed 5. lil2as~for deregulation ^" 6. Should roof area be regulated - 7. When do you plan to deregulate stairwells* -- other areas. ^ <% )W* 3. PERSONAL MONITORING 1. What is purpose of 6-hr. monitoring, pf 15-srinute. & 2. Show historical record of exposure, also current level. What hazard ous operation monitoring frequency is used. Show your personal monitoring cards -- signed time -- card summary file. 5HOW how filed -- retention NGC37868 Questions for OSHA Audit 2- c<. Are lab chromatograms filed. >^5. How frequently is the G.C. calibrated -- what gas. How are the air pumps maintained -- who is responsible -- what is your experience with pumps. /^7. What air flow rate is used for long term (6-hr.) monitoring; what break-thru is allowed on the back-up tube. /yS. What is air flow rate for short term monitoring. 9. How many employees are being monitored now. Ao. For what job tasks do you require respiratory protection. What job task monitoring has been done for 5 ppm ceiling. What test accuracy and pump accuracy data do you have to demonstrate monitoring accuracy requirements'are being complied with. jO, "fL l *2- ' Hi 4. RESPIRATORY PROTECTION c>---- 1 C^l. What is covered in your written Respiratory Protection procedure. How often are what employees instructed in responsibilities and need for wearing respirators. What cleaning facilities are available. / <05. Are respirators assigned to individual users. Where are they stored between uses. How often are they checked for deterioration and by whom. 6- Any observance of employee stress in wearing this protective gear. >f7. How many breathing air stations on each floor -- what is greatest dis V tance between -- what is length of hose supplied. s/ O8* How would you handle a maintenance team of several men at one station. >r^ &10. Is breathing air G.C. analyzed -- when will it be -- what is done if ( 0.5 ppm AVCM is recorded. Where is 5-minute reserve supply reservoir located. >jll. How is breathing air conditioned before supplying user. <v NGC37869 Questions for OSHA Audit -3 ^?12. Is activated carbon used anywhere in breathingS air psystem. '*13. What is your mask day experience. - ^ A$&4. ;vT ^"15. What are the continuous VCM monitoring alarm levels now -- future. Is the breathing air mask coupling used elsewhere in the plant. 0^16. How many Scott air pacs are provided -- have they been converted to pressure demand type. cy!7. What are plans for use of cannisters if worker mobility is necessary. ifh What .data-da-you have on AVCM aeosttgeaenfe insiderrcajjigntQi:, r f 5. HAZARDOUS OPERATIONS- f \ ^1. List your hazardous operations. ... f \ dL'&vf**- <r6 c\2ty What is your procedure f^protective equipment usage in hazardous oper* Ai ations -- hard charge -- liquid VCM leak -- dirty poly entry -- other ^ maintenance job. 6. METHODS OF COMPLIANCE 1. I fy 2. <c ^.03. See attachment A for detailed .questions. List of projects to reduce level to less than 1 ppm -- completion dates. Dates for updating written plans on 6-month frequency. 7. CONTRACTORS AND VISITORS A < l.^What is plant policy involving contractors in regulated area -- how train contractor employees -- respiratory supply -- record keeping. Visitor policy for other than authorized personnel. Questions for OSHA Audit -4 - 8. EMERGENCY SITUATIONS vr- (VI. Written emergen^^pi^ocedurg^fo^regjlated area _r* i f 2. Relate to written Evacuation Procedure --- evacuation alarm -- head >5^ count -- assembly area. j 3. What if assembly area is in path of VCM emission. ^~4- What signal Is used for each type of alarm. 'jfjM-eh'l ~ fa- 9. TRAINING ^1. Records of required annual training, quarterly training. '-n- 2. New and transferred employee indoctrination and training -- materials and records. <^3. Included in annual training -- carcinogenic hazard -- protective steps - respiratory equipment -- fire and toxicity -- monitoring need -- medical surveillance -- emergency procedures -- recognition of VCM release -- OSHA standard review. 10. MEDICAL SURVEILLANCE N 1. Annual exams, 6-month exams, upon removal from regulated area. ^2. Is employee^ provided ^L^feTcopy of suit^>^^ty^or^ex^osuxe to VCM upon completion of examination -- within weeks. p<z % ^ '7- l-'vf ^ 3. Policy if employee declines medical exam or is otherwise non-cooperative. 11. SIGNS AND LABELS ^"l. Hazardous operation sign.* /^2. PVC waste labeled. JlaJUbJL Product labeling. NGC37871 Questions for OSHA Audit -5- 12. RECORDS AND REPORTS iff*- Sfl. Personal monitoring records -- employee notification notices. 2. Medical records. . 3. Authorized personnel rosters. 4. Notification of changes in regulated areas. 5. File of massive release reports. NGC37872