Document ppzE2eyarKQ2bbp0oOgdpyVXj

EMPLOYEE CHEMICAL EXPOSURE LAKE CHARLES CHEMICAL PIANT Parpose: To establish and foraalize a consistent program of evaluation and control directed toward the elimination of hazardous employee exposure to dangerous materials and conditions. In addition, the program will also institute and define the necessary responsibilities of individuals so as to achieve a smooth on-going program adaptable to normal as well as unique situations. I. MANAGEMENT & ADMINISTRATION A. Function - To develop, guide, and continually evaluate the overall industrial hygiene program. B. Responsibility - The primary responsibility to admister the program will rest with the Safety Director. C. Program Evaluation - On at least a semi-annual basis, a review of the total program will be made. All Department Heads, will participate, as necessary in this review. The purpose of the review will be to evaluate the program's effectiveness, develop improve ments and to serve as a frequent stimulus to the over all effort. II. SIGNIFICANT PROGRAM FEATURES A. Hazard Monitoring - Includes the determination of what is monitored evaluation of monitoring data, and the appropriate recording of data. B. Determination of corrective measures to be taken including both protective equipment and engineering changes. C. Effects of various government requirements on plant program and compliance with such regulations. An advance plan for the following 12 months will be maintained and updated at the beginning of each calendar quarter. MCI) 000011972 III. EMPLOYEE EXPOSURE MONITORING A. Determination - The need for monitoring will be determined by regulations governing chemical exposure in the work place, as well as, our own judgment in evaluation of plant environment. Both in-plant and out-of-plant advisory sources will be used in selecting what monitoring will be done, the method used, and the frequency. B. Routine Monitoring 1. Schedule - A schedule of exposure monitoring will be developed by the Safety Director. This will include all dosimeter sampling, as well as, monitoring planned for long-term evaluation of a specific chemical or area. Responsibility for maintaining this schedule will rest with the Safety Director. 2. Sample Collection - Safety Department will be responsible for the actual collection of various samples. Pumps for area samples and dosimeters will be maintained and calibrated by the Safety Department. The Laboratory will furnish the various collection devices such as charcoal tubes and impinger solutions. 3. Monitoring Analysis - The Laboratory will be responsible for the actual chemical analysis of all samples. This includes the analytical data expressed in terms of exposure. 4. Records - Results of routine monitoring will be recorded in an acceptable manner by the Safety Department. These records will be maintained as necessary to comply with regulations requiring them. At least quarterly, a summary of monitoring results will be written to guide the updating of the overall exposure control program. C. Special Monitoring - From time to time, special monitor ing or sampling will be required in connection with complaint response or special job exposure control. This may involve personnel dosimeters, long term area samples, "grab" samples or other methods necessary to furnish exposure data. oooon^ WCt) -2- 1 Complaint Response - Response to possible in-plant emission complaints will be the responsibility of the Safety Department. Where necessary and in the interest of rapid action, the Laboratory Shift Supervisor will be called upon for assistance. 2. Dual Samples - In all cases of plant monitoring dealing with employee chemical exposure and pre formed by governmental or other regulatory agencies, dual samples will be taken. In these situations, the Safety Department along with the Laboratory will take the action necessary to assure that the monitor ing achieves its purpose. Analysis of the results will be made available on a "first priority" basis. 3. Special Jobs - When special jobs requiring frequent monitoring occur, the Safety Department will have the responsibility to assure that sufficient data is gathered to properly protect employees. In these cases, the Safety Department will notify the Laboratory of the monitoring requirements as far in advance as possible. Sample collection will be done by the Safety Department. Analysis of the samples will be done by the Laboratory with the Safety Department acting to help with the analysis where possible. D. Record Keeping - In addition to the records required under routine monitoring, all other results of monitor ing will be recorded. 1. Uniform Data - Data detailing the particular sample conditions, data, location, and equipment used will be reported along with results in a uniform way. 2. Employee Notification - The records of an employee1s monitoring will be available for inspection by that employee. In addition, specific notification will be furnished to any employee when dosimeter results indicate an exposure above the existing threshold exposure level. The Safety Department will be responsible for the notification. Copies of the notice will be sent to the Department Head and a record log will be kept by the Safety Department CHEMICAL EXPOSURE REDUCTION The results of monitoring and the existing as well as future requirements of regulator agencies will be the primary basis for correcting potential over exposure to hazardous material. In addition, results of health testing that may be undertaken will also be considered in determining where corrective action is required. mcD 0000U974 -3- A. Basic Reduction Fhilosphy 1. Long Term Solution - Where cases oi` potential over exposure exist on a more or less continuous or frequent basis, the fundamental corrective action will be to reduce the cause of exposure by engineer ing change or addition. 2. Short Term Controls - As interim measures to control short term exposure, employee protective equipment or administrative controls will be used. B. Engineering Changes - All engineering changes for the correction of potential employee exposure situations will be designed by the Process Engineering Department after a thorough consideration of all available input from other departments. Final designs will be approved by the Tfected departments, Safety and the Manager. The design is to specifically include expected exposure level after installation, projected operating costs and an estimated time required to make the changes. At the time of final approval, a completion data for the project will be set. No changes will be made in this date except where specifically approved by the Manager. C. Personal Protective Equipment - All equipment used for the protection of employees, contractors, or other personnel while working in the plant will be approved for the antici pated exposures by the Safety Director. Any changes made will be confirmed in writing by the Safety Director. Where applicable, the various equipment will carry recognized regulatory agency or American National Standards Institute approval. D. Reduction or Control Measures - The quarterly update of our exposure control plan will contain a status summary of all reduction measures. V. TRAINING The primary responsibility for training of all employess in procedures required to reduce or eliminate exposure to hazardous materials will rest with the Safety Department. All training programs will be reviewed by Departments prior to general plant presentation. VI. MEDICAL SURVEILLANCE A. Requirements - The requirements for comprehensive medical or health surveillance may come either from regulatory standards or be developed internally using guidelines and recorancndations from corporate groups. MCD -4- B. Surveillance Measures - To the extent possible, various health screening tests will be combined to eliminate confusion C. Surveillance Records - Records of all medical health testing w .11 be maintained as part of the plant's First Aid records. Each employee may have his individual records made available to a private physician by written request. D. Voluntary Testing - Unless specifically required by statute, all employee medical testing for hazardous material exposure will be voluntary. This does not include pre-employment physical exams or termination exams if required. HCD 0000119^6 -5-