Document e7oxeBB5JQ7X99KjBz276eLMm

1996 CONSOLIDATED AUDIT HAZARDOUS MATERIALS TRANSPORTATION REVIEW TEAM LEADER - HELEN CAUSEY FUNCTIONAL LEADERS - DEAN SMITH DO A 043051 CONFIDENTIAL Hazardous Materials Transportation Review HMTR Questionnaires Review Date 9/10/96 Location/Division: LAD Plant/Facilitv: Chlorine Plant Address: Superintendent: (Process leader) Major Author: J.J. Hiemenz Helen Causev Review Team Members: Dean Smith. Helen Causev. Wallv Cutrer. Todd Boken Chemicals Reviewed: Chlorine Sulfuric Acid DRI: This document has been developed solely for use within The Dow Chemical Company, and is thus marked as "Dow Restricted". Sharing of this document with persons not employed by or affiliated with The Dow Chemical Company must be cleared through the North America Safety, Loss Prevention, and Security Department. April 1995 Dow Restricted DO A 04305? CONFTDFNTIAL DO A 043053 conftdfnttai HMTR Questionnaires Introduction Purpose This collection of questionnaires is a part ofthe Review Package for the Hazardous Materials Transportation Review (HMTR) which will be discussed in the Formal Review during die Consolidated Audit. Complete only the questionnaires that apply to your plant. To provide a basis for discussion, at the Formal Review, of the plant's awareness and understanding of its distribution responsibilities. Responsibility Deciding which questionnaires to complete The plant superintendent/process leader is ultimately responsible for completing the questionnaires and distributing them when completed. The superintendent/process leader may designate a knowledgeable person to complete and distribute the questionnaires. Use this table to decide which questionnaires you must complete. If you... Are preparing for a HMTR Then Till in the... Emergency Response Questionnaire and Equipment Construction Questionnaire AND... If you... Then fill in the... Ship bulk materials Outbound Bulk Questionnaire Receive purchased materials Inbound Bulk Questionnaire Ship or receive materials by marine vessel Marine Questionnaire Ship bulk waste materials Waste Questionnaire What to do with the completed questionnaire Distribute to the appropriate Review Committee members, at least three weeks prior to the Consolidated Audit. Note: Contact your HMTR focal point for the names and numbers of copies to distribute. April 1995 Dow Confidential DO A 043054 CONFIDENTIAL Hazardous Materials Transportation Review HMTR Questionnaires Name of Material A *= based on government regulations, corporate minimum requirements, and area/division safety standards. B = based on established good practices, internal and external guidelines, and to stimulate discussion or training. C = based on identifying hazards and hazard mitigation. EMERGENCY RESPONSE QUESTIONNAIRE Resource - Operations, Distribution Emergency Response, Site Emergency Services Responsible Care Distribution Code compliance for Element 5.1 B 1. Who are the Dow "Knowledgeable Plant Contacts" (KPCs) for an en route emergency? Name Wally Cutrer Name Glenn Wisdom Name 24 Hr Phone 504-353-8443 24 Hr Phone 504-353-8443 24 Hr Phone Name 24 Hr Phone Responsible Care Distribution Code compliance for Element 5.1 B 2. How do you document that these contacts are trained and familiar with their role in a distribution emergency response? Dow training records Responsible Care Distribution Code compliance for Element 5.1 B 3. Are E/R responders with HAZMAT Technician or NFPA Level A training available to respond to transportation emergencies with your material? Yes [ x ] No [ ] Not Apply [] Responsible Care Distribution Code compliance for Element 5.1 B 4. For purchased materials, who are "knowledgeable" contacts for an en route emergency? Supplier Name : Sulfuric Acid/Cytec / Joan Adair 24 Hr Phone: 1-800-537-2649 Supplier Name________________________ 24 Hr Phone B 5. Are ALL inbound raw materials F.O.B. Dow? (i.e, Dow accepts ownership when it arrives at Dow's gate.) Yes [ x ] No [ ] Not Apply [] Responsible Care Distribution Code compliance for Element 5.2 B 6. Do the plant's KPCs have a Distribution Emergency Response (E/R) information packet, notebook, or briefcase for the materials both shipped and received by the plant? Yes [ x ] No [ ] If" No", why not?_______________ _________ ______ ___ April 1995 Dow Confidential 00 A 043055 CONFIDENT!AL 1 Hazardous Materials Transportation Review HMTR Questionnaires Name of Material____________________________________________ ,_______________________________ A = based on government regulations, corporate minimum requirements, and area/division safety standards. B = based on established good practices, internal and external guidelines, and to stimulate discussion or training. C - based on identifying hazards and hazard mitigation. EMERGENCY RESPONSE QUESTIONNAIRE Responsible Care Distribution Code compliance for Element 5.2 C 7. What special properties of your material should be made known? ___ DOT Corrosive, Poison Responsible Care Distribution Code compliance for Element 5.2 C 8. What "specialized" equipment and/or resources would be necessary in a transportation incident? Consider: Drager or GasTec sample pump and tubes, explosimeters, absorbent materials, neutralizers, materials of construction, and clean-up and disposal information. C-Kit. Drager Tubes, neutralization techniques Responsible Care Distribution Code compliance for Element 5.1 A 9. What system do you have to verily that the driver or conductor has the required papers and emergency response information? Ref: 49 CFR 172.600 - 604 Provided bv railroad on shipping paperwork D0 A 043056 CONFIDENT! AL- 2 Dow Confidential April 1995 Hazardous Materials Transportation Review HMTR Questionnaires Name of Material___________________________________ A = based on government regulations, corporate minimum requirements, and area/division safety standards. B = based on established good practices, internal and external guidelines, and to stimulate discussion or training. C = based on identifying hazards and hazard mitigation. EQUIPMENT CONSTRUCTION QUESTIONNAIRE Resource - Distribution Emergency Response, Distribution Regulatory Affairs, Tech Centers t Care Distribution Code compliance for Element 4.1 the acceptable Dow or Department of Transportation (DOT) equipment specifications? PTR 172 & 173, Global Hazardous Materials Distribution Guidelines, Distribution ; Standards Not Known [ ] Drum (like UN 1A1): ________________________ Not Apply [ ] Cylinder (like DOT 3A): _____________________ Not Apply [ ] Tank Truck (like MC 307); ___________________ Not Apply [ ] IMO Bulk Tank (like IM 101): ________________ Not Apply [ ] Rail Car (like DOT 111A100): _DOT 1005500W. Not Apply [ ] Other: ______ ______________________________ Not Apply [ ] Responsible Care Distribution Code compliance for Element 4.1 A 2. Can this material be transported without requiring special local, state, or federal permits or approvals (like: DOT Exemptions or special approvals)? Ref: 49 CFR 107 Subpart B Yes [ x ] No [ ] If" No", please attach copies of the exemptions or approvals. Responsible Care Distribution Code compliance for Element 4.1 A 3. How is the container material of construction verified for compatibility before loading? Ref: 49 CFR 173.22 Dedicated fleets under direction of North American rail fleet organization Responsible Care Distribution Code compliance for Element 4.1 C 4. How is the gasket material verified for compatibility before loading? Plant Procedures/specifications April 1995 Dow Confidential OONFA rO04F3NoTl^ 3 Hazardous Materials Transportation Review HMTR Questionnaires Name of Material_______________________ _____________________________________________ A = based on government regulations, corporate minimum requirements, and area/division safety standards. B = based on established good practices, internal and external guidelines, and to stimulate discussion or training. C = based on identifying hazards and hazard mitigation. OUTBOUND BULK QUESTIONNAIRE Resource - Manufacturing, Distribution/Traffic, Distribution Regulations, Industrial Hygiene, Product Tech Center, Distribution Emergency Response C 1 Jh\st any special concerns for this material while in transit? Like: Anhydrous HC1 - Extended time will result in excessive pressure. Responsible Care Distribution Code compliance for Element 4.1 A 2. Do you have a process to verify? 49 CFR 171-174 Correct unit number Yes [x] No [ J Not Apply [ ] Correct DOT vehicle specification Yes [x] No [ ] Not Apply [ ] Container integrity Yes [X] No [ ) Not Apply [ ] Analysis of heels Yes [] No [x ] Not Apply [ ] Note: analysis not done, but process in place to investigate large heels Final securement Yes [x] No [ ] Not Apply [ ] Carrier has appropriate personal protective equipment Yes [] No [ ] Not Apply [x ] Responsible Care Distribution Code compliance for Element 3.1 B 3. Are you satisfied with the safety, service, and emergency preparedness of the companies transporting your materials? Yes [ x ] Yes [ ] No [ ] No[ ] Not Apply [ ] for Rail Not Apply [ x] for Truck Responsible Care Distribution Code compliance for Element 3.2 B 4. Do you have a system to provide input to those evaluating carrier performance? Yes [ x] Yes[ ] No[ 1 No[ ] Not Apply [ ] for Rail Not Apply [x ] for Truck Responsible Care Distribution Code compliance for Element 2.3 B 5. For truck transportation, is product specific driver training provided by Dow personnel? Yes [ ] No [ ] Not Apply [ x] A 6. Has personal protective equipment required for loading this product been tested or approved by the Industrial Hygiene Department? Ref: 29 CFR 1910.133-134 Yes [ x ] No [ ] 4 Dow Confidential April 1995 DO A 040058 CONFIDENTIAL Hazardous Materials Transportation Review HMTR Questionnaires Responsible Care Distribution Code compliance for Element 4.2 A 7. Do you have a written procedure to prevent incompatible materials from being loaded on the same vehicle or in adjacent compartments? Ref: 49 CFR 173.24(e)4 and Global Hazardous Materials Distribution Guidelines Yes [ ]No[ ] Not Apply [x ] for Rail Yes [ ]No[ ] Not Apply [x] for Truck A 8. List the methods used to assure that the container is not overloaded: Ref: 49 CFR 173.24, 173.314 For Rail Scale with automatic cutoff] For Truck ________________________________________________________ ________ Not Apply [ x ] Responsible Care Distribution Code compliance for Element 4.2 B 9. Is the vapor space prevented from passing through the flammable range during loading? Yes [ ] No [ ] Not Apply [ x ] for Rail Yes [ ] No [ ] Not Apply [ x ] for Truck C 10. Are only Dow personnel involved in loading this product? Yes [ ] No [ x ] Not Apply [ ] for Rail Yes [ ]No[ ] NotApply[x] for Truck Responsible Care Distribution Code compliance for Element 2.3 B 11. Have non-Dow personnel been trained in the proper handling of this material? Yes [ x ] No [ ] Not Apply [ ] Responsible Care Distribution Code compliance for Element 2.3 A 12. How do you assure the non-Dow loader uses the proper protective equipment during the loading operation? Ref: 29 CFR 1910.133 - 134 ______Enforcement of operating procedures_______________________________ Not Apply [ ] April 1995 Dow Confidential 00 A 0430S9 CONFIDENTIAL. 5 Hazardous Materials Transportation Review HMTR Questionnaires Responsible Care Distribution Code compliance for Element 2.3 C 13. How are special Dow procedures and requirements for specific products communicated to carriers? (For example: we require dry disconnects for Epichlorohydrin.) Responsible Care Distribution Code compliance for Element 2.4 B 14. Is there a documented process in place for determining and recording carrier compliance with special procedures and requirements? Yes [ ]No[ ] Not Apply [x] for Rail Yes f ]No[ ] Not Apply [x] for Truck Responsible Care Distribution Code compliance for Element 3.1 C 15. Do you decide which carriers will be used for your shipments? Yes [ ] No [ ] Not Apply [ x ] for Rail Yes [ ] No [ ] Not Apply [ x ] for Truck If yes, how?__ If no, what is the process of identifying carriers for your shipments? Responsible Care Distribution Code compliance for Element 4.4 C 16. Where are instructions for proper cleaning of distribution containers documented? MSDS [ ] TEDER [ ] Product Handbook [ ] Other_________ DO A 04306,0 CONFIDENTIAL 6 Dow Confidential April 1995 Hazardous Materials Transportation Review HMTR Questionnaires Name of Material A - based on government regulations, corporate minimum requirements, and area/division safety standards. B = based on established good practices, internal and external guidelines, and to stimulate discussion or training. C = based on identifying hazards and hazard mitigation. INBOUND BULK QUESTIONNAIRE Responsible Care Distribution Code compliance for Element 4.3 - Whole section Resource - Product Prime Buyer (through division Purchasing), Distribution Regulations, Distribution Emergency Response, Industrial Hygiene B 1. Do you have a "system" to report supplier defects to the purchasing department? Yes [ x ] No [ ] C 2. List any concerns you have for this material while in transit? Like: Anhydrous HC1 - Extended time will result in excessive pressure. A3. Has personal protective equipment required for unloading this product been tested or approved by the Industrial Hygiene Department? Ref; 29 CFR 1910.133-134 Yes [ x ] No [ ] C 4. Are only Dow personnel involved in unloading this product in your plant? Yes [ x ] No [ ] A 5. Has the non-Dow unloader been trained in proper unloading procedures in your plant? Ref: 49 CFR 174.67 and 177.834 Yes [ ] No [ ] Not Apply [ x ) A 6. Who documents the training? _____ A 7. How do you assure the non-Dow unloader uses the proper protective equipment during the unloading operation? (Like: cooling tower chemicals, compressed gases, and other raw materials.) Ref: 29 CFR 1910.133 -134 _______ _______ ___________ ____________________________________________ Not Apply [ x ] B 8. Is the material analyzed for positive identification before unloading begins? Yes [x ] No [ ] B 9. Is the vapor space prevented from passing through the flammable range during unloading? Yes [ x ] No [ ] Not Apply [ ] April 1995 Dow Confidential 00 A 043061 CONFTDENTTAl 7 Hazardous Materials Transportation Review HMTR Questionnaires t Name of Material A *= based on government regulations, corporate minimum requirements, and area/division safety standards. B based on established good practices, internal and external guidelines, and to stimulate discussion or training. C * based on identifying hazards and hazard mitigation. MARINE QUESTIONNAIRE -- Does Resource - Marine Technology Center (Freeport, TX), Marine Chartering (Houston, TX), YoucJ&al Marine Dept. C 1. Are Dow personnel the only ones directly involved with the marine transfer (loading/unloading) operations for the material being shipped into or out of your facility? Yes [ ]No [ ] A 2. If" No", how is training and/or licensing verified for the other people involved with the marine transfer? Ref: 46 CFR, Parts 10 and 12 A3. Is the training documented? Ref: 46 CFR, Parts 10 and 12 Yes [ ]No [ ] Not Apply [] B 4. Have the facilities of the department performing the transfer been audited via the Marine Tech Center or the Terminal Tech Center? Yes [ ]No [ ] Date of last Review C 5. If "YES", attach a copy of the recommendations and response/action plans from the last Marine Tech Center or Terminal Tech Center audit. Not Apply [ ] A 6. Does your facility Emergency Response Plan include contingency plans for marine emergencies which comply with the Dow Marine E/R Guidelines. Ref: 33 CFR, Parts 150 and 154 Yes [ ]No [ ] If "NO", what are your plans to achieve compliance? A 7. Is your Marine E/R plan periodically tested? Ref: 33 CFR, Parts 150 and 154 Yes [ ] No [ ] Not Apply [ ] A 8. Is the testing of your Marine E/R plan documented? Ref: 33 CFR, Parts 150 and 154 Yes [ ]No[ ] Not Apply [ ] 8 Dow Confidential April 1995 DO 0430" CONFIDENTIAL Hazardous Materials Transportation Review HMTR Questionnaires Name of Material_____________________________________ __ _____________________________ A = based on government regulations, corporate minimum requirements, and area/division safety standards. B = based on established good practices, internal and external guidelines, and to stimulate discussion or training. C " based on identifying hazards and hazard mitigation. MARINE QUESTIONNAIRE B 9. Does the department responsible for loading check for the cleanliness and compi ship/barge tank prior to loading? the Yes [ ]No [ ] C 10. Are compartments analyzed for "last contents," if you load on product heels. Yes [ ]Nof ] Responsible Care Distribution Code compliance for Element 4.2 All. Do you have a written procedure to prevent incompatible materials from being loaded on the same vessel in adjacent tanks? Ref. 46 CFR Part 150, Table 1 Yes [ ] No [ ] A 12. List the methods used to assure that the vessel tank/container is not overloaded: Ref. 46 CFR 151.45-6,46 CFR 150.500 B 13. Is the vapor space prevented from passing through the flammable range during loading/unloading? Yes [ ]No[ ] Not Apply [ ] A 14. Are all personnel within the cargo area or involved in the cargo transfer (including sampling or measuring) required to use specified protective equipment and clothing? Ref: 46 CFR 150.455 Yes [ ) No [ ] B 15. Has personal protective equipment, utilized by personnel working on behalf of Dow, been tested or approved by the Industrial Hygiene Department? (NOTE: Ships crew are not considered working on behalf of Dow.) Yes [ 3 No [ ] A 16. How are carrier personnel informed of the hazards of the material being transported? Ref: 46 CFR 150.500 April 1995 Oow Confidential DO A 0430A3 CONFIDENTIAL Hazardous Materials Transportation Review HMTR Questionnaires Name of Material A = based on government regulations, corporate minimum requirements, and area/division safety standards. B *= based on established good practices, internal and external guidelines, and to stimulate discussion or training. C *= based on identifying hazards and hazard mitigation. WASTE QUESTIONNAIRE Resource - Environmental Services, Environmental Operations B 1. Has Environmental Services reviewed your materials within the last 3 years? Yes [ ]No [ ] When? B 2. What modes of transport are used to ship this material? Package truck [ ] Bulk truck [ ] Vacuum truck [ ] Rail [ ] Other [ ] C 3. Are only Dow personnel involved in loading/unloading this material? Yes [ ] No [ ] Not Apply [ ] B 4. Have non-Dow personnel been trained in the proper handling of this material? Yes [ ]No [ ] Not Apply [ ] A 5. How do you assure the non-Dow unloader uses the proper protective equipment during the unloading operations? Ref: 29CFR 1910.133 - 134 ______ Not Apply [ ] A 6. Do you have a process to verify? Ref: 49 CFR 171-174 Correct unit number Yes [] No [ ] Not Apply [ 1 Correct DOT vehicle/container specification Yes [] No [ ] Not Apply [ 1 Container integrity Yes ] No [ ] Not Apply [ ] Analysis of heels Yes [] No [ ] Not Apply [ 1 Proper Blocking and Bracing Yes [] No [ ] Not Apply [ ] Final securement Yes [] No ] Not Apply t ] Marking, labeling, and placarding Yes [] No [ ] Not Apply [ ] B 7. Is the vapor space prevented from passing through the flammable range? Yes [ ]No [ ] Not Apply [ ] A 8. What process do you have to assure that container is not overloaded? Ref: 49 CFR 173.24 and 173.314 10 Dow Confidential April 1995 rnLr 04364 CONFlD^NTrAI.