Document qa7pEYpMVzXLJb35Mn2VReQ1K

Operating Discipline 12 Industrial Hygiene Solvents/EDC 1 12.4 Communication and Training 12.4.1 Facility Hazardous Waste Operations and Emergency Response (HAZWOPER) Program Scope This document serves as the facility written Hazardous Waste Operations and Emergency Response (HAZWOPER) Program. Hazardous waste is generated in the plant as a byproduct of the manufacturing process and associated activiti s. These waste can be either source specific or general in nature and are RCRA regulated. HAZWOPER Reference Document This document, containing hazard communication policies and practices specific to this facility, when used in conjunction with the Hazcom reference document, comprises the written Hazcom program for this facility. The current version of the HAZWOPER reference document is available electronically on one of the following File Servers using the paths listed: o Michigan Div. Operating Discipline File Server (via MD0633): MDCV03/OPERDISC/DOS/INDJHYG/IHREFERENCE DOCS/HAZREF MDCV03/OPERDISC/MAC/INDHYG/IHREFERENCE DOCS/HAZREF The current version of the HAZWOPER Facility Template is available electronically on one of the following File Servers using the paths listed: o Michigan Div. Operating Discipline File Server (via MD0633): MDCV03/OPERDISC/DOS/INDJHYG/IHTEMPLATES/HAZCOM MDCV03/OPERDISC/MAC/INDHYG/IHTEMPLATES/HAZCOM List and Description of Hazardous Waste This section describes how the facility maintains and files a description (characterization) of al1 hazardous waste streams generated and disposed of by/at the facility. Reference 29 CFR 1910.120 (Paragraph (P) (2)) Responsibility The following is responsible for overseeing the plant hazardous waste files: Environmental Coordinator If an new waste stream is generated, it is characterized and sent to Environmental Operations lor review. If n eded, required analytical data is attached to the waste characterization. After review and approval, the waste is added to the list and the characterization is filed. The waste may be disposed of at that time. Existing hazardous waste streams are reviewed for correctness on an annual basis. Changes in existing hazardous waste streams will result in the filing of a new waste characterization. Revised: 9/12/97 Printed: 11/06/97 7:31 AM Dow Restricted FONFTDFNTTAI ] C. R. Douglas 00 007695 Operating Discipline 12 Industrial Hygiene Solvents/EDC 1 12.4 Communication and Training Location/Accessibility The list and individual characterization files of hazardous waste are located in Bldg. 1617, in the Environmental Filing System, Section RCRA-190. These are accessible 24 hours a day. List and Description of Hazardous Waste Storage Areas and Tanks This section describes the areas and tanks in the plant that store hazardous waste. There are several areas and tanks in the Plant designated for hazardous waste storage. Areas exist where containers of solid or liquid hazardous waste are stored (< 90 day storage) and tanks in which only liquid hazardous waste is stored (permitted storage, which generally store waste for less than one year). Less Than 90 Day Hazardous Waste Container Storage Areas Less Than 90 Day Hazardous Waste Storage Tanks Permitted Hazardous Waste Storage Tanks 1. North section of Block 17 2. Southeast Block 16 (TTU) 3. Northwest Bldg. 1703 (Process Lab) These areas are inspected on a weekly basis as per RCRA regulation. D-42B (General Plant Waste Feed to TTU) These areas are inspected on a daily basis as per RCRA regulation. D-13 (Per/Tet Plant Waste Feed to TTU) D-15 (Per/Tet Plant Waste Feed to TTU) D-92A (TTU Waste Feed from Per/Tet Distillation) D-700 (TTU Waste Feed from Per/Tet Heavies System) D-710 (TTU Waste Feed from EDC Heavies System) T-749 (Groundwater Recovery) V-201 (Groundwater Recovery) These areas are inspected on a daily basis as per RCRA regulation. Medical Surveillance Program This section describes how the plant complies with Medical Surveillance Requirements of the standard. Reference 29 CFR 1910.120 (Paragraph (P) (3)) Biennial Health Monitoring Biennial Health Monitoring Scheduling Employees are required to wear respiratory protection equipment for more than 30 days per year, and as such, are required to submit to a biennial physical exam surveillance program. In addition, employees are requested to submit to annual physical exams involving blood chemistries and audiograms. Employee Health Monitoring physical exams are scheduled by; the plant Industrial Hygiene Coordinator Revised: 9/12/97 Printed: 11/06/97 7:31 AM Dow Restricted 2 C. R. Douglas CONFTDFNTTAI DO 007696 Operating Discipline 12 Industrial Hygiene Solvents/EDC 1 12.4 Communication and Training Biennial Health Monitoring Records Employee Health Monitoring records are kept and maintained bYthe Dow Medical Department. Decontamination This section describes the plant procedures for decontamination of tools, equipment, Procedures Chemical Protective Clothing and Personal Protective Equipment. Reference Decontamination of Tools Decontamination of Equipment 29 CFR $ 1910.120 (Paragraph (P) (4)) Tools are decontaminated following the steps listed below; 1. Depending on the degree of contamination, the tool may be decontaminated simply by wiping with an absorbent cloth. 2. If wiping with an absorbent cloth is not sufficient, the tool may be decontaminated by washing or scrubbing with; water, water and detergent, or a suitable solvent. If any of the above described liquids are use, the washing must been done in a contained area of the plant or the residue must be contained in a suitable device (i.e., a bucket). 3. If the above methods do not result in a thorough decontamination, the tool is then discarded. 4. All residues (absorbents, liquids, etc.) generated in the decontamination process must be properly disposed of. Equipment is decontaminated following the steps listed below; 1. The equipment is isolated, and then may or may not be red tagged, depending on procedural requirements. 2. Empty equipment contents as best physically able through draining, pumping, purging, etc.. 3. Some equipment requires solvent flushing and/or Requires purging with plant air or plant nitrogen and/or Requires water washing and/or Some equipment requires chemical cleaning and/or TSCA regulated equipment requires special decontamination procedures. Consult those procedures as needed for this type equipment. 4. Any liquid or solid residues are then removed from the equipment. 5. After visual inspection and/or analytical results, the equipment is then decontaminated. Note: Decontaminated equipment leaving the plant must be proven decontaminated (visual inspection or analysis) and must have a Dow Decontamination Tag attached. Revised; 9/12/97 Printed: 11/06/97 7:31 AM Dow Restricted CONFTDFlVr TAI 3 C. R. Douglas DO 007697 Operating Discipline 12 Industrial Hygiene 12.4 Comnmiiication and Training Decontamination of Chemical Protective Clothing and/or Personal Protective Equipment Chemical Protective Clothing (CPC) and Personal Protectiv Equipment (PPE) are decontaminated as per th manufacturers instructions. In lieu of these instructions, there are some simple guidelines; Never use solvents Never use harsh detergents Never use abrasives or abrasive detergents In use CPC or PPE will be stored in designated areas. Contaminated CPC or PPE will not be re-used until it is decontaminated. CPC or PPE that can not be decontaminated will be disposed in containers designated for that purpose. New Technology This section describes the plant procedures for complying with the New Technology requirements of the standard. Reference 29 CFR 1910.120 (Paragraph (P) (5)) New Technology Continuous monitoring of appropriate discipline literature is conducted in order to stay abreast of technological developments. Those developments deemed applicable will be implemented on an as needed basis. A Dow Technology Center that specializes in the incineration of hazardous waste also provides quidance. Hazardous Materials Handling Labeling supplies for this facility can be found ***llst locatlon(s) here The following methods are used to label portable containers: ***Select the option(s) being used and delete the options not being used Option Method Description 1 Use Preprinted Facility personnel obtain appropriate preprinted label from Label facility supply or printer as basis for creating new label. 2 Fill out the Facility personnel complete labels using a label guide. Label using 1) The Dow internal sample labeling guide (the Dow labeling labeling guide standard can be found in Appendix G of the Hazcom Reference Document) in combination with MSDsheets/ T.I.M.E. sheets or 2) The T.I.M.E. "L'report 3 Use Example Facility personnel use an example of a properly completed Label label as basis for creating new label. Revised: 9/12/97 Primed: 11/06/97 7:31 AM Dow Restricted CONFTDFNTT At. 4 C. R. Douglas DO 007698 Operating Discipline 12 Industrial Hygiene 12.4 Communication and Training HAZWOPER Training The plant utilizes a computer software based (File Maker Pro) training system. The system is designed to allow self-paced training for all employees. The training information is distributed to plant personnel for review prior to the actual training period. Many plant specific, safety and environmental related training topics are used to complete HAZWOPER Facility-Specific Hazcom Training Facility-Specific Hazcom Training Responsibility Facility-Specific Hazcom training is a one time (per person) required training conducted prior to assuming job responsibilities (for additional information refer to Hazcom reference document). The following individual is responsible for overseeing FacilitySpecific Hazcom training: "Identify the Individual (by Job title) responsible for overseeing Facility-Specific Hazcom training and delet the others Method(s) of Training IH Contact Compliance Specialist Safety Contact Head Operator Industrial Hygienist Other Facility-Specific Hazcom training is conducted using the following methods: ***Select the option(s) being used and delete the there 1. The facility Safety/Health orientation video is reviewed. 2. One-on-one training is conducted by a knowledgeable person (e.g., compliance specialist, safety contact, industrial hygiene contact, or area industrial hygienist) Facility-Specific Training Documentation 3. Hazcom training information is presented using a Hazcom checklist (found as an attachment at end of this program) 4. Self paced study using a training notebook with an opportunity for question and answers Facility-specific training is documented using the following: Select the option being used and delete the there 1. Documented using DPS course number 8105 New Chemical Hazard Training 2. A hard copy of the training checklist/attendance sheet is maintained at the facility. The documentation is located at C'*list location) 3. Other, briefly describe Training on the hazards associated with a new chemical hazard brought into the facility is conducted for employees who will be potentially exposed prior to beginning work with that chemical (for additional information refer to the Hazcom reference document) Revised: 9/12/97 Printed: 11/06/97 7:31 AM Dow Restricted 5 C. R. Douglas OONFTDFNTTAL. DO 007699 Operating Discipline 12 Industrial Hygiene 12.4 Communication and Training New Chemical Hazard The following individual is responsible for overseeing New Training Responsibility Chemical Hazard training: "Identify the individual (by Job title) responsible for overseeing New Chemical Hazard training and del te the others New Chemical Hazard Training Method IH Contact Compliance Specialist Safety Contact Head Operator Industrial Hygienist Other, please list New Chemical Hazard training is accomplished through the following method(s): Select the option being used and delete th there New Chemical Hazard Training Documentation 1) Safety Meeting (e.g., monthly or pre-job) 2) Management of Change 3) Hazard information is presented using a Hazcom checklist (found as an attachment at end of this program) with an opportunity for Q&A 4) Pre-start-up review 5) Other, briefly describe New chemical hazard training is documented using the following: Select the option being used and delete th others 1. Documented using DPS course number 3186 2. A hard copy of the training checklist/attendance sheet is maintained at the facility. The documentation is located at (***list location) 3. Other, briefly describe Revised: 9/12/97 Primed: 11/06/97 7:31 AM Dow Restricted CONFIDENT! Al g C. R. Douglas DO 007700 Operating Discipline 12 Industrial Hygiene Solvents/EDC 1 12.4 Communication and Training Non-Routine Task Before non-routine tasks are performed, employees are Hazard Communication instructed in the potential hazards of the tasks and are informed of the appropriate work practices to be followed. The hazards of non-routine tasks are communicated to employees through the use of one or more of the following: 1) Permits such as the Safe Work Permit, Line and Equipment Opening Permit, Confined Space Entry Permit, Hot work permits etc 2) Pre-job safety meetings 3) Safety standards which describe in detail the measures which should be followed when conducting non-routine tasks 4) Following a written procedure for this task 5) Management of Change HAZWOPER Emergency Response Training Contractor employees working in this facility are apprised of: 1) How to access MSDS's for chemcials they may be exposed to 2) Precautionary measures that need to be taken to protect employees during normal conditions and in a forseeable emergency 3) How to obtain label information The above information is communicated to contactors through the following methods : `"Select the option(s) being used and delete the others 1) Pre-job safety conference meeting minutes. 2) Work Permits (LEO, Confined Spaces, Safe Work Permit, Hot Work Permit). 3) Reviewing Contractor training checklist with the contract employees. 4) Reviewing facility safety orientation video. 5) Other, briefly describe The following person(s) is/are responsible for overseeing contractor hazard communication: `"Identify the individual (by Job title) responsible for overseeing contractor hazard communication and delete the others IH Contact Compliance Specialist Safety Contact Head Operator Industrial Hygienist Other Revised: 9/12/97 Printed: 11/06/97 7:31 AM Dow Restricted CONFTDFNTTAt 7 C. R. Douglas DO 007701. Operating Discipline 12 Industrial Hygiene Sstegs&MSS-l 12^4Commun|cationandTraini^ Hazcom Standard A copy of the applicable OSHA Hazard Communication standard can be found in Appendix F of the Hazcom reference document. Revised: 9/12/97 Printed: 11/06/97 7:31 AM Dow Restricted CONFTDFNTTAI 8 C. R. Douglas DO 007702