Document pv2eMNNdeZGd92wByK1o5mND

conoco h r* Conoco Chemicals Company Conoco Inc. P. O. Box 91, New Highway 25 Aberdeen, Mississippi 39730 (601) 369-8111 PVC PLANT SAFETY AND HEALTH MANUAL ABERDEEN, MS SUBJECT: EFFECTIVE DATE: WRITTEN BY: APPROVED BY: TITLE: Work Environment Hazard Control Program Manager I. INTRODUCTION Operation of the Aberdeen PVC Plant involves the presence of the work environment hazards described below. Each hazard may be damaging to the human body if controls are inadequate. This program establishes the minimum controls required for that purpose. A. Chemicals A wide range of chemicals are required for plant operation. Many of them are toxic or otherwise hazardous. In those cases, harm r* to people may occur via inhalation, ingestion, or direct skin/eye contact, depending upon the specific chemical and conditions present. B. Noise Inherently noisy equipment exists throughout the plant. Excessive v exposure to the resulting noise may produce temporary or permanent hearing loss. C. Low Light Levels Safe plant operation requires adequate work area lighting. Loss of this light, regardless of cause, greatly increases the risk of per sonal injury and other non-productive accidents. VAB.0001226871 PVC PLANT SAFETY AND HEALTH MANUAL Page 2 I. INTRODUCTION (Continued) D. Biological Hazards Plant breakrooms, restrooms, and trash containers represent locations where biological hazards may develop. The presence of vermin attracted to these areas increases the risk of incurring illnesses. II. HAZARD IDENTIFICATION AND CONTROL Any employee who discovers what he believes to be a new work environment hazard is expected to eliminate the hazard if it is within his authority and ability to do so. If this is not possible, he should take preventive action to insure that the risk of personal injury due to the hazard is kept at a minimum until further corrective action can be taken. The preventive action necessary may range from something as simple as closing a valve to shutting down an entire process. IH. HAZARD EVALUATION A. New Chemicals Any new chemical will not be used in the plant until; a. All hazards associated with the intended use of the material have been identified by the using department and the Safety Department, b. Protective measures, including the acquisition of personal protective equipment, have been taken to cope with the hazards. 2. Material Safety Data Sheets Any person who causes a new chemical material to be introduced into the plant must also insure that a material safety data sheet is obtained from the vendor prior to the use of the chemical. A copy of the sheet is to be given to the Safety Supervisor, who is responsible for maintaining an up-to-date file of ven dor safety data sheets for all chemical materials used in the plant. Should the attempt to obtain a vendor data sheet before use of the chemical fail, the Safety Supervisor should be contacted. He is to determine the hazards and other information pertinent to the chemical by whatever means are appropriate. This will include a direct contact with the material vendor. It may also VAB.0001226872 * I, PVC PLANT SAFETY AND HEALTH MANUAL Page 3 III. HAZARD EVALUATION (Continued) A. New Chemicals (Continued) 2. Material Safety Data Sheets (Continued) involve communication with Conoco industrial hygienists toxicologists, or other person(s) who can supply information regarding potential exposure problems as well as necessary controls for the safe use of the material. to B. Routine Dosimetry The Safety Department will conduct effective, on-going dosimetry programs for the following hazards. Each program will comply with the requirements of regulation pertinent to each hazard: 1. VCM Worker TWA VCM exposures will be routinely determined, using REAL "Minimonitors". Sample analysis will be done twice each week by the laboratory, using a Perkin-Elmer UF42" head-space analyzer, or other equivalent analytical instru ment . As soon as the results of analysis are available, the Safety Supervisor will investigate and determine the causes of any overexposures found. Whenever possible, the causes (and possible solutions) will be discussed by him and the over exposed employee. In the absence of the Safety Supervisor, the Safety Director will conduct such investigations. 2. Lead and Antimony Worker TWA lead and antimony exposures will be routinely determined, using Bendix Mod. BDX--44 pumps, operated at 1.5 liters per minute, and either Gelman //4337 filters or Millipore MAWP037AM filters. Analysis will be done by Research Services, using atomic absorption analysis. As with VCM, the Safety Supervisor will donduct follow-up investigations of all overexposures. VAB.0001226873 PVC PLANT SAFETY AND HEALTH MANUAL Page 4 III. HAZARD EVALUATION (Continued) B. Routine Dosimetry (Continued) 3. Total Dust Worker TWA total dust exposures will be routinely determined, using Bendix Mod. BDX-44 pumps, operated at 1.5 liters per minute, and Millipore MAWP037AM matched-weight, dual filters. Analysis will be done by Research Services, using a 5-place analytical balance. Follow-up investigations of any overexposures will be con ducted by the Safety Supervisor. 4. Noise Worker noise exposure will be routinely determined, using audio dosimeters which comply with the requirements of OSHA noise regulation. C. VCM Area Monitoring The Honeywell continous monitoring system will be used to reduce the risk of VCM overexposures in areas where high concentrations may occur. The system will be maintained and used under the direction of Process Engineering. D. Special Studies 1- VCM f The Safety Department will conduct VCM exposure studies of high-exposure-risk jobs, as they become evident. This may involve area sampling, dosimetry, or a combination of both, as needed to define exposure levels and corrective action required for their control. High Volume Use Control As with VCM, the Safety Department will conduct exposure studies involving other high-volume-use chemicals as needs arise. This includes occasional rechecks of exposure levels and studies of unique conditions that may develop. VAB.0001226874 PVC PLANT SAFETY AND HEALTH MANUAL III. HAZARD EVALUATION (Continued) D. Special Studies (Continued) 3. Noise The Safety Department will conduct an on-going program of area noise level measurement. This work will be aimed at determin ing noise reduction and hearing protection needs, as required by OSHA 1910.93. They will be assisted by the Medical Depart ment, as required. 4. Lighting Work area lighting deficiencies will be determined at night by department heads and the Safety Director during the annual safety audits of each operating area. Particular emphasis will be given walking surfaces where slips/trips could result in severe injury. A light meter will be used, as needed. 5. Restrooms, Breakrooms, and Washrooms The Plant Nurse will conduct quarterly inspections of all plant breakrooms, washrooms, and restrooms to insure adequate clean liness standards are being maintained. E. Reports 1. General The timely reporting of work environment hazards is essential to their effective control. Any such hazard suspected of representing a serious danger must be reported Immediately via the chain of command. Additionally, interim measures must be taken to control the hazard until further action can be taken. This is a responsibility borne by each employee. The reporting of hazards to non-plant personnel will be confined to that established by local manager policy. 2. Routine Reports The following reports will be routinely made; a. Weekly Results of Chemical Dosimetry The Plant Nurse will issue weekly reports of the results of routine chemical dosimetry. This includes VCM, lead, anti mony, and total dust. VAB.0001226875 PVC PLANT SAFETY AND HEATLH MANUAL III. HAZARD EVALUATION (Continued) E. Reports (Continued) 2. Routine Reports (Continued) b. Weekly Results of Noise Dosimetry The Plant Nurse will issue weekly reports of the results of noise dosimetry during the times when noise dosimetry is being done. c. Overexposure Notices The Plant Nurse will issue reports to employees found to have been overexposed during routine chemical and noise dosimetry, notifying them of their overexposures. In the absence of the Plant Nurse, the reporting will be done by the Safety Supervisor. * Monthly Chemical Dosimetry Results Summary The Safety Supervisor will issue monthly summaries of the results of all routine chemical dosimetry results, including the details pertinent to overexposures. e. Monthly Continuous Monitoring Summary Process Engineering will issue a monthly summary of the results of Honeywell VCM continuous monitoring. f. Quarterly Summary of Exposure Monitoring The Safety Supervisor will issue a quarterly summary of the results of non-routine chemical exposure monitoring. + g. Annual Summary of Dosimetry Results The Safety Supervisor will issue an annual summary of the results of routine chemical dosimetry. This will include recommendations for changes in sampling frequencies, where appropriate. A # VAB.0001226876 PVC PLANT SAFETY AND HEALTH MANUAL Page 7 IV. MPLOYEE COMMUNICATIONS AND TRAINING A. Hazardous Material Control Prior to the use or handling of new, hazardous materials, each employee involved will be advised of the associated hazards and trained in the steps to be taken to control them. Additional information and training will be provided when required by ' regulation pertinent to each hazard. B. Noise Work areas having hazardous noise levels will be posted with warning signs that require the use of hearing protection. Employees are required to use such protection while in posted C. New Employees 1. Initial Orientation The Safety Department will provide general orientation train ing on VCM, lead, and similarly regulated materials to new employees. 2. On-the-Job Further training on the use and handling of hazardous n will be provided to new employees by the employee's immediate supervisor. All training of this nature will be documented by a training meeting report at the time of occurrence and the reports distributed to the Manager, Plant Superintendent, the Operations Superintendent, Safety Director, and Plant Nurse. D. Annual Health Training The Safety Department will conduct an annual health training session for all employees. The session will include a review of plant work environment hazards and their control. Special emphasis will be given to OSHA-regulated materials, including VCM, lead, and noise. VAB.0001226877  PVC PLANT SAFETY AND HEALTH MANUAL MPLOYEE COMMUNICATIONS AND TRAINING E. Respirator Training 1. New employees The Safety Department will conduct basic respirator training for each new employee as a part of the orientation in C.l, above. The instruction will include explanation of the func- tioning of each respirator, a demonstration of its correct use, and employee practice. 2. Refresher Training The Safety Department, in conjunction with Operating and Maintenance Departments, will conduct annual respirator re fresher training for all employees whose job duties require the use of respirators. The training will be done by using 1st line supervisors as assistant instructors and will in clude negative face piece fit seal checks, using a test en vironment . V. ENGINEERING CONTROLS Whenever possible or practical, engineering controls will be used to control environmental hazards. When hazards are present and adequate engineering controls have not been implemented, interim measures of other types must be used to protect employees from the hazard. VI. VENTILATION A. General Ventilation systems in use must be maintained and .used as designed and intended. Should system failure occur, employees normally pro tected by ventilation must be removed from the area(s) of the hazard unless other equally effective protective measures are provided. B. Building Ventilation System The Compound Department is responsible for daily monitoring of the compound ventilation system and the issuance of work orders or other measures needed to correct system deficiencies. VAB.0001226878 * PVC PLANT SAFETY AND HEALTH MANUAL VI. -V--E---N--T---I-L--A--T---I-O---N-- (Continued) B. Building Ventilation System (Continued) t * The Safety Department will conduct quarterly measurements of venti lation system airflow and immediately alert the Compound Department of any serious deficiencies found. VII. HOUSEKEEPING AND SANITATION A. General To the degree possible, employees are expected to maintain their areas of responsibility in a state of order and free of trash, litter, and other materials which might produce biological hazards. B. Breakroom and Restroom Cleaning The Mechanical Department is responsible for insuring the timely cleaning and maintenance of breakroom and restroom facilities throughout the plant. C. Vending Machine Cleanliness The Administrative Services and Safety Departments will be respon sible for liason with food vendors for the purpose of correcting any vending machine health hazards. D. Breakroom/Restroom Inspection The Plant Nurse will conduct quarterly inspections of all plant restrooms, washrooms, and breakrooms to Insure adequate sanitary conditions are being maintained. E. Personal Hygiene All employees are expected to exercise care to minimize unnecessary or prolonged hand, face, and skin contamination with chemicals of any type. It is especially important that employees thoroughly clean their hands and face prior to eating, drinking, or smoking following the handling of chemical materials. VAB.0001226879 PVC PLANT SAFETY AND HEALTH MANUAL Page 10 VIII. PERSONAL PROTECTIVE EQUIPMENT Employees exposed to environmental hazards that require the use of personal protective equipment must be provided and required to use such devices. The equipment must be effective and it must have Safety Department approval. When doubt arises about what hazards are present or what personal protective equipment is needed, the Safety Department should be con tacted. IX. CHEMICAL DISPOSAL Process Engineering will conduct an on-going program for the safe: disposal of hazardous materials. Appropriate State and Federal regu lations must be complied with. X. MEDICAL SURVEILLANCE PROGRAM An employee medical surveillance program, performed under the guidance of the Medical Division, will be maintained and all employees encouraged to participate. VAB.0001226880 PVC PLANT SAFETY AND HEALTH MANUAL Page 11 WORK ENVIRONMENT SPECIAL STUDIES WORK CALENDAR ITEM TIMING A. VCM Exposure Studies 1. VCM Filter Pack Changes 2. Reactor Condensor Cleaning 3. VCM Railcar Loading/Unloading 4. Fluid Bed Dryer Area 5. V-ll Roof Area 6. Other -- As Needs Are Found 7. Contractor Hazardous Jobs B. High Volume Use Chemical Exposure Checks 1. CTA 2. Plasticizer 3. Phthalic Anhydride 4. Chlorine 5. AMS C. Building Ventilation Performance Monitoring D. Sampling Equipment Checks/Calibrations 1. Test Bendix Box 44 Pumps 2. Calibrate Gilmont Flowtube E. Update Material Safety Data Sheet Files F. Policies and Procedures Reviews 1. Respiratory Protection Program Evaluation. 2. Work Environment Hazard Control Plan May/June May/July June/Aug. June/Aug. June/Aug. May/Dec. As Needed July/Sept. July/Sept. July/Sept. July/Sept. July/Sept. Mar/June/Sept./Dec. Mar/June/Sept./Dec. Jan./Apr/Aug./Oct. May/Sept. Oct. Feb. * VAB.0001226881