Document wDXrJq9MO56BrGV6KjMd9KGB6

r//fj&/ifcoMPAA/yr Technical Center P.O. Box 122 Moore & Walker Rds. Avon Lake, Ohio 44012 216-933-0100 Fax: 216-933-0563 September 17, 1993 Mr. Arnls Andersons U. S. Department of Labor Occupational Safety and Health Administration Km. 734, Federal Office Bldg. 234 N. Summit Street Toledo, OH 43604 Dear Mr. Andersons: On September 10, 1993 the B.F.Goodrich Company received your letter regarding complaint No. 73817702L. The buildings of concern are presently owned by the Geon Company. This change in ownership was discussed with Ms. Marrie Henderson of your office on September 16, 1993. Below please find our response to the alleged hazards. 1. Employees are overexposed to plastic chemicals at the mixers in buildings 441, 438 and 452. Ventilation is inadequate (chemicals not known). Reference 1910.1000 standard. Exposure monitoring has been conducted per attached policy, SA25, Industrial Hygiene Program. Please note that per the "Monitoring Schedule" section, chemicals and physical agents are monitored upon: employee request; governmental regulation? process additions and modifications; job exposure analysis; incidents of potential exposure and task analysis. Current results regarding exposures in the mixer areas have been below the PEL. We will maintain our ongoing monitoring program and address any results of significance. All mixers have stationary ventilation systems that are either in continuous operation or automatically activated when the station is in use. The ventilation has been designed specifically for the equipment in question. These systems are periodically tested for proper flow. As a result of your letter, ventilation tests were conducted on September 14, 1993. Flow rates were found to be in good condition, ranging from 350 to 1100 feet per minute. 2. Lock-out tag-out procedures are not followed when cleaning machines in 441, 438 and 452. Reference 1910.147 standard. NGC 14100 2- - Please find attached copies of our safety policy SA-02 "Lock-Out Procedure", equipment isolation lock-out test and audit/inspection procedures. You will find that SA-02 is in full compliance with 1910.147. Additionally, lock-out training is conducted annually with all employees in buildings 441, 438 and 452. Audits are also conducted annually for employees in these buildings. The lock-out policy is communicated, maintained and enforced. 3. Employees have not been trained as to the chemical hazards they work with. Reference 1910.1200 standard. All employees have received training on hazardous chemicals in their work area, both upon initial assignment and annually thereafter. Please find attached copies of our Hazard Communication Policy SA-24, Hazard Communication lesson plan and associated employee tests and documentation. Additional policies are in place regarding personal protection i.e. respiratory protection, eye, hand and head protection. We have also attached a copy of our recipe sheet titled "The Geon Company Campaign Pick List". This is published to the appropriate employees prior to each production run. Please note that PPE designation is part of this list. Based on a review of 1910.1200, we do however feel that a modification to our training program is needed. Section (h) (2) (ii) addresses physical and health hazards of the chemicals in the work place. Our current training program addresses these issues in a more generic format. Beginning September 28, 1993, we will implement specific training in reference to physical and health hazards. Documentation of training will then be sent to your attention. Dear Mr. Andersons, we have answered your letter to the best of our ability. If there are any other issues or concerns, please let us know. Your letter of September 1, 1993 has been posted to our employees. Our response will also be posted on or before September 21, 1993. Sincerely, The Geon Company /J Calvin C. Lee Geon Site Director CCL:mab Enclosures NGC 14101 B.F.GOODRICH COMPANY Avon Lake SUBJECT: INDUSTRIAL HYGIENE PROGRAM General Notice: SA-25 Issued: 10-10-92 Page 1 of 3 PURPOSE To provide all BFGoodrich employees with a safe and healthful work environment and comply with all applicable government regulations. STAFF AND ORGANIZATION The Avon Lake Industrial Hygiene Program is coordinated by the Site Health and Safety Department. Their responsibilities include: personal monitoring, select area monitoring, analysis of monitoring data, medical surveillance, periodic exposure surveys, selection of personal protective equipment, training programs where applicable, record keeping and reporting. MONITORING SCHEDULE The following chemicals & physical agents are monitored periodically. The frequency is based on individual toxicity and exposure potential. VCM Noise THF Butadiene Welding Fumes Ionizing Radiation Vinyl Cyclohexene Formaldehyde Lead Ethyl Acrylate MDI Acrylonitrile Ammonia Benzene Styrene Organotins Total & Respirable Dust 1. Additional chemicals & physical agents are monitored as indicated by the following: a. Employee request b. Compliance with governmental regulations c. Process additions and modifications d. Job exposures analysis e. incidents of potential exposure f. Task analysis 2. The monitoring schedule is reviewed quarterly by the Manager of Health & Safety. MONITORING STRATEGY Once the chemical or physical agent has been selected, the following steps are taken: 1. A process survey is conducted by the Industrial Hygiene technician. 2.. Select the sample size, i.e., number of personal or area samples. The sample size is based on the quantity and hazard severity of the chemical or physical agent, existing engineering controls and the potential employee population. NGC 14102 General Notice: SA-25 Issued: 10-10-92 Page 2 of 3 3. Determine the sampling technique based on established procedures. (OSHA, BFG, certified analytical lab instruction) 4. Sampling equipment is calibrated and recorded for accuracy prior to and at the conclusion of monitoring. A sample blank is included. 5. The sampling equipment is then transferred to the monitoring site. Sample location is established at the time of the process survey. Check points include: source emission points, ventilation flows, operators work area and potential high exposure tasks. 6. The participating employee completes a chemical monitor form. (See attachment #1) 7. The IH technician completes a laboratory request sheet. (See attachment #2) 8. Once the sampling is complete, the medium is packaged and sent to the appropriate analytical laboratory. If storage is required, the medium is isolated via desiccator or refrigerator to prevent contamination. All outside labs are AIHA certified. BFG analytical laboratories will be utilized where appropriate. PERSONAL PROTECTIVE EQUIPMENT See SAF/SA policies: 3100 Eye Protection; 3200 Hearing Protection; 3600 Safe Wearing Apparel; 3700 Hand Protection; 3800 Respiratory Protection; SA-41 Respiratory Protection; SA-43 Personal Protection; SA-44 Head Protection; SA-45 Hand Protection and the Site Chemical Hygiene Plan. RECORD KEEPING AND REPORTING All personnel monitoring data is entered into corporate medical surveillance. An environmental exposure monitoring card is completed by the site Industrial Hygiene technician. A complete file, including personal and area monitoring results, equipment calibration and technical observations, is maintained by the Safety & Health Department. This information is accessible to all employees. This Information is retained indefinitely. A report is generated quarterly summarizing monitoring results and corrective actions where appropriate. This report is distributed to all affected departments. NGC 14103 General Notice: SA-25 Issued: 10-10-92 Page 3 of 3 ENGINEERING CONTROLS Appropriate engineering controls are established by design engineering for all new processes and significant process modifications. The Manager of Health and Safety is responsible for approval. Maintenance of engineering controls is the responsibility of the equipment owner. Where applicable, preventative maintenance programs must be established. NOTE: All ventilation systems that are designed specifically for exposure control must be included in a preventative maintenance inspection program not to exceed a one-year frequency. FOLLOW-UP PROCEDURES All monitoring results above the Permissible Exposure Limit (PEL) require a follow-up. The Health and Safety Department includes a corrective action sheet with the monitor card when a result is greater than established limits. (See Attachment #3) It is the area supervisor's responsibility to complete this follow-up.sheet. In addition,, all results above the PEL without the appropriate personal protective equipment require a board of review and narrative report. (See SAF-1300 and SA-38 - "Board of Review") NGC 14104 B.F.GOODRICH COMPANY AVON LAKE GENERAL CHEMICAL PLANT GENERAL PROCEDURE GENERAL NOTICE: SA-24 Issued: 11-23-92 Page 1 of 4 SUBJECT: HAZARD COMMUNICATION PURPOSE: To provide a written Hazard Communication Program to all employees. COORDINATOR The Manager of Health & Safety shall be the facility Hazard Communication Coordinator. CONTENTS The Hazard Communication Program listed on the following pages shall contain the following topics: 1. Labeling 2. Material Safety Data Sheets 3. Employee Training 4. Chemical Inventory 5. Contractor Training NGC 14105 GENERAL PROCEDURE GENERAL NOTICE: SA-24 Issued: n-23-92 Page 2 of 4 LABELING Container labeling is an important part of our hazard communication program. With proper container identification and labeling and availability of MSDS and operating procedures, each employee can determine the chemical contents of the container and the chemical health hazard. The basic BFG labeling requirement is that all chemical containers must be labeled, tagged or identified with the chemical name and/or BFG code number and the health/physica! hazard of the chemical. Also, the labeling must be legible, in English and prominently displayed. The specific method of labeling used in the plant will differ depending on the type of container in question as discussed below. Bulk Storage Tanks: Identified with chemical name and/or the raw material code number. Labeled with the National Fire Protection Agency (NFPA) diamond. Raw Material Containers: The plant will rely on our suppliers to label raw material containers with their warning label(s) and stenciling on the BFG code number for that chemical. We will not re-label raw material containers unless the supplier's label has been destroyed and/or rendered unreadable. Multiple Chemical Use Containers: These containers are identified by equipment name or code number. Equipment not marked can be identified by referencing a plot plan displayed near the building entrance which has the equipment identified by number. The equipment contents and health hazard can be determined by reference to the department's operating procedures or production schedule and product recipe for the chemical contents and the MSDS for the chemical health hazard. Intermediate-Use Containers: Identified, marked or tagged with the chemical name and/or BFG code number. This requirement applies to small-sized containers (i.e., 5-gallon buckets, pails, etc.) used to transfer materials for small volume applications. Transfer containers, such as beakers, do not need to be labeled as long as the person using the container is present. If more than one person is to use the container, it must be labeled. Finished Product Containers: All finished products shipped in drums or bags will be labeled with labels prepared by the Manager of Product Safety Compliance. Individuals can contact the Safety Department to obtain labels for common chemicals used in laboratories and process. 2 NOC 14106 GENERAL PROCEDURE GENERAL NOTICE: SA-24 Issued: 11-23-92 Page 3 of 4 B. MATERIAL SAFETY DATA SHEETS Responsibility It is the responsibility of the department using a particular chemical to obtain the most current materia! safety data sheet (MSDS). Specifically, the person needing the chemical or the person ordering the chemical must obtain an MSDS. Location MSDS's for chemicals used in an area will be located in each area. A master file of MSDS's will be maintained in the Technical Center Raw Material Control Department. In addition, the Dispensary will keep a current file of process chemicals. New hazardous chemicals received into the plant cannot be used until an MSDS is available for review. If an MSDS is not available, any of the following, groups can be asked to obtain an MSDS: 1. User Department 2. Safety Department 3. Purchasing Group 4. ALTC Raw Materia! Group C. EMPLOYEE TRAINING Each employee of the Avon Lake Site has received training as required. The initial trail ling for new employees will review: 1. The OSHA Hazard Communication Standard. 2. How to read and understand an MSDS. 3. The Avon Lake Site Hazard Communication Program. 4. An overview of occupational health. This training will be coordinated by the Safety Department. Each employee's ability to understand the information given during the training session will be documented via a written test. The initial training will allow employees to recognize and deal with the specific hazards of the chemicals with which they work. Each new employee will be oriented as to the chemicals and their hazards that will be encountered in their area of assignment. If an employee is transferred to another job area, they will be informed of the hazardous chemicals in their new work area. 3 NGC 14107 GENERAL PROCEDURE GENERAL NOTICE: SA-24 Issued: 11-23-92 Page 4 of 4 For production personnel, informing employees of the hazards from non-routine tasks and non-labeled pipes varies depending on whether the employee is a maintenance craftsman or production/facility operator. A maintenance craftsman is informed of hazards via a completed maintenance work order that will include a statement of the hazard, the protective clothing required and any safety procedure/permit required to do the job safely. Plant operators assigned non-routine tasks are given verbal instructions by their foremen at the beginning of the shift. Additionally, they are told that, if they suspect anything abnormal with their equipment, they are to immediately get their foreman. Note that for purposes of this policy, non-routine tasks are those jobs that are done by a job class at a frequency of less than once per month. Continual employee education will focus on chemical review. Departments will be required to periodically review a chemical MSDS, plus anytime there is a change regarding process, chemical inventory, equipment, etc. D. CHEMICAL INVENTORY In the Technical Center a list of all chemicals used, handled or produced is available via the ChemStore computer system. The ChemStore computer system maintains a current inventory of chemicals, including their location and quantity. In the General Chemical Plant a list of all chemicals used, handled or produced is available from the Safety Department. The Safety Department periodically updates this list. Each department will maintain its own inventory list. E. CONTRACTOR TRAINING Each contractor performing work in the Avon Lake Facility will be informed of the Hazard Communication Program. All contractors will attend a safety orientation training session prior to starting work at the site. In addition, contractors will be given information on protective measures, release deflection and emergency response. It is the responsibility of the contractor's BFG contact to obtain new chemical approval on any chemical the contractor brings into the plant. 4 NGC 14108 LOCKOUT - CARDINAL RULE LESSON PLAN VIDEO-CHEMICAL DIVISION ' LOCKOUT PROCEDURE OVERHEADS - SA-2 ALGC LOCKOUT PROCEDURE REVIEW PROCEDURE QUESTION - ANSWER TEST- NEW GENERAL NOTICE: SA-2/ Rev. 2 Issued: 8-12-91 Page 1 of 8 BFGOODRICH COMPANY AVON LAKE GENERAL CHEMICAL PLANT CARDINAL RULE SUBJECT: SAFETY LOCK-OUT PROCEDURE PURPOSE: The purpose of this procedure is to provide maximum protection to all people and equipment while working on or about equipment powered by an energizing source such as electricity, water, air or steam. DEFINITION: The term lock-out shall mean tagging and locking or disconnecting equipment in such a way that it cannot be energized without the lock being removed. 1- Electrical Lock-out will mean the breaking of the circuit breaker, disconnect the switch, or receptacle plug-in type disconnect on electrical supply line. If it is not possible to lock out a circuit, disconnecting, taping and danger tagging the main lead wires at the breaker by a qualified electrician will be considered a lock-out. Individuals must "Danger Tag" the breaker. 2. A non-electrical lock-out will be made on equipment that is powered by energizing sources such as water, air, steam, etc., by chaining off the source valve and placing a lock and tag on it and bleeding off any pressure before working on it. 3. Safety Locks A safety lock is a Wilson-Bohannan lock. Each lock will be supplied with only one key. 4. Lock-out Box is a box designated to hold Safety lock-out keys from specific designated equipment locked out by an operator and/or operators for the purpose of multiple lock-out with a check sheet. NGC 14110 GENERAL NOTICE: Issued: Page SA--2/ Rev. 2 8-12-91 2 Of 8 NEW 5- Lockable Valves: All valves used for lockout purposes are capable of being locked. Through the use of devices such as chains/ brackets/ adaptors/ covers or boxes/ any valve is capable of being rendered inoperable by a locking device. 6. Portable"Electrical Equipment A lockout is not required if equipment is unplugged from the energy source and the plug is under exclusive control of the employee performing the servicing or maintenance. RESPONSIBILITIES: Individual Each individual who works on or about equipment that can be energized by any means/ and has exposed parts that can be activated/ will lockout and tag the appropriate equipment/ verify the lockout and maintain the key in their possession. In no case will the lock-out by one individual suffice or be considered a lock-out for another person. One person -- 1 lock and tag? 2 persons - 2 locks and tags/ etc. Management The lockout procedure must be thoroughly reviewed with each new employee by his supervisor before he starts to work. The supervisor will demonstrate the procedure to the employee. The employee will then demonstrate to the supervisor how to perform the lockout. Periodically/ (at least every 6 months) the supervisor will review with their employees the lockout procedure. Supervisor shall document these training sessions. Documentation includes names and dates of each person trained/retrained. Supervisor shall conduct an annual inspection of the lockout procedure. This will include a review/ between the supervisor and each authorized employee/ of the employee's responsibilities under the lockout procedure being inspected. ngc 14111 GENERAL NOTICE: SA-2/Rev. 2 Issued: 8-12-91 Page 3 of 8 NEW The supervisor shall certify that the annual inspections have been performed. The certification shall identify the equipment on which the lockout procedure was being utilized/ the date of the inspection/ and the person performing the inspection. See Appendix I. SAFETY DEPARTMENT Will provide guidance when questions or unusual conditions arise. Monitor forcible lock and tag removal. Audit training and annual inspections. Provide required safety training for all contractors. PROJECT SUPERVISOR Assure that contractors' employees receive required Safety Training/ and comply with plant Safety Procedures. PRODUCTION: 1.) When Maintenance or servicing work is to be performed on specific equipment/ the operations personnel shall lock and tag all energizing sources and release all stored energy. 2.) The operation responsible shall provide to the personnel working on the equipment a written description of how the equipment has been locked out. This may be done on the Maintenance Work Order or Job Authorization Check Sheet. 3.) At the job site/ the operation personnel responsible shall review with assigned personnel the location of all lockouts and shall sign the MWO or Job Authorization Check Sheet. MAINTENANCE: Prior to performing any maintenance or servicing work/ each person shall install his personal lock and tag on all lockouts listed on the MWO or Job Authorization Check Sheet. The only exception is if a "Lockout Box" is used. All assigned maintenance personnel shall sign the MWO# verifying lockout and tagging has been done. NGC 14112 GENERAL NOTICE: SA-2, Rev. 2 Issued: 7-15-91 Page 4 of 8 Each person shall remove their lock and identification tag at the completion of their work. They shall also sign the MWO stating this has been done. PROCEDURE FOR LOCK-OUT: 1. Identify Equipment - Carefully check to assure the energizing source/ electrical breaker or disconnect switch to be locked out will de-energize the equipment to be worked on. To assist in' this identification/ each start-stop switch and the breaker or disconnect in the circuit must have correlating identification numbers attached. 2. De-Energize - Isolate the equipment to be worked on under Definitions 1 & 2. 3. Locking Out Equipment - Each person who will work on the equipment must place his own lock and tag on each energizing source. Multiple locking adapters are available when the number of locks needed for proper lock-out exceeds the amount that the breaker or disconnect switch can accomodate. Several pieces of equipment in the plant require as many as four or five disconnects to de-energize the equipment. All sources must be locked out; additional locks are available from the supervisor. The individual who attached the lock must have the only key on his person. The key is not to be passed to another individual. (Exception - See Page 5, #5) 4. Test For Proper Lock-Out - Locking out the breaker or disconnect switch will not be considered adequate assurance that equipment is isolated. After the lock/s and tag/s have been attached/ each person must check for proper lock-out by attempting to start the equipment. All persons involved in locking out the equipment will be informed when the attempt is made to start the equipment. This will be accomplished by depressing the start button. When assured the equipment is properly de-energized and locked/ the stop button is to be depressed. Pushing the stop button is important in order to place the circuit in the "OFF" mode/ so when the breaker or disconnect is re-energized/ the equipment will not start automatically. NGC 14113 General Notice: SA--2/ Rev.2 Issued: 8-12-91 Page 5 of 8 PROCEPCTRE FOR SHIFT CHANGE PERSONAL LOCK-OUT TRANSFER: There will be occasions when a person's work shift ends prior to completion of work on equipment he has locked out. If someone else is expected to finish the work during the interim period before the person's next scheduled work shift/ then he will be responsible for a lock-rout transfer. The lock-out transfer will be accomplished in the following manner. 1. Contact the supervisor having jurisdiction in the area where the equipment is located and request a lock-out transfer, 2. The supervisor will accompany the person who has the equipment locked out to the site of the lock-out and place his own lock-out lock and danger tag on the equipment requiring lock out. 3. After and only after the supervisor's lock and tag are in place/ the person who requested the lock-out transfer may remove his lock and tag. 4. The supervisor will maintain his lock and tag on the breaker or disconnect switch until the person who will complete the work has placed his lock and tag and completes the remainder of the requirements of the lock-out procedure. 5. Ths subsequent shift supervisor has accepted the lock-out transfer by receiving the key for the lock-out from the supervisor he is relieving. The receiving shift supervisor must verify proper lock-out and sign the danger tag as soon as possible after the key transfer. PROCEDURE FOR REMOVAL OF LOCK-OUT: When an individual has completed his work and is prepared to remove his lock/ he should again depress the stop button. This will assure the circuit is still in the "OFF" mode and will not start up when the breaker or disconnect is re-energized. The lock and tag should then be removed. NO individual shall remove NGC 14114 GENERAL NOTICE: SA-2, Rev. 2 Issued: 8-12-91 Page 6 of 8 ANOTHER*S LOCK AND TAG. The only exception foe lock and tag removal is noted below. FORCIBLE REMOVAL OF LOCK: There may be occasions when a person who has locked out equipment has left the plant. In the event the lock must be removed, the following will be required: 1- Every effort shall be made to contact him to obtain his permission to remove the lock. 2. If he cannot be located, the area supervisor shall be responsible for taking whatever action is necessary to assure that personnel will not be endangered or equipment damaged, before the lock is removed. He will, in any case, thoroughly inspect the equipment - 3- The supervisor will consult a member of the Safety Department before any safety lock is forcibly removed. Security will maintain a log for lock removal. 4. The supervisor must be present when the lock is removed. If a multiple locking adapter is used, cut the portion of the adapter containing the lock. 5. The lock will be given to the person's foreman and returned to the employee upon his return. ROTATING EQQIPHENT NOT RESTRICTED BY LOCK-OPT: There will be occasions when locked out equipment will not be sufficient to eliminate the hazard from moving parts. Especially hazardous are blowers having blades with large surface areas. Any air movement, such as a back draft, may cause the blades to rotate causing a severe pinch point hazard. Thus an additional lock-out point is needed to control the blades from movement. A chain with a lock shall be attached to the blade (if possible) to control movement. If not, the hazard can be reduced by blocking the rotor or the drive sheave with a 2" X 4", or with some other construction grade timber. NGC 14115 GENERAL NOTICE: SA-2, Rev. 2 Issued: 8-12-91 Page 7 Of 8 MAINTENANCE CHECK OF EQUIPMENT: There will be special cases where maintenance personnel must energize unguarded equipment in order to check shaft or gear alignment/ timing/ etc. In these special cases/ the maintenance persons involved shall have a standby while he checks the energized equipment. He shall also put a danger tag on the breaker and any other remote starting station before energizing the equipment. The standby and maintenance persons will also be responsible for keeping other people clear of the equipment until it has been properly guarded or locked-out. WORKING ON ELECTRICAL ENERGIZED EQUIPMENT: There will be special cases where Electrician/ Electrical Engineer and Instrument personnel must work on the equipment "HOT", (not locked out). Only these people are authorized to do so. Reference requirements - OSHA STD. CFR 1910.331 - 335 "Electrical Safety Related Work Practices. (EW EQUIPMENT ELECTRICAL ENCLOSURES No one shall open a locked out electrical enclosure for any reason without approval from every individual having the equipment/systera locked out. Any deviation from this procedure will be noted in a separate department procedure and approved by the Safety Department. REMINDER: ANY UNAUTHORIZED PERSON WHO REMOVES A SAFETY LOCK AND/OR DANGER TAG FROM A PIECE OF EQUIPMENT OR PIPING AND OPERATES OR ATTEMPTS TO OPERATE IS SUBJECT TO DISCIPLINARY ACTION. NOC 14116 GENERAL NOTICE: SA-2/ Rev.2 Issued: 8-12-91 Page 8 of 8 ABSOLUTE COMPLIANCE TO THIS PROCEDURE IS A MUST- FAILURE TO COMPLY COULD RESULT IN SEVERE INJURY TO SOMEONE OR TO EQUIPMENT OR EVEN A PLANT DISASTER. APPROVED BY OPERATIONS COUNCIL PLANT MANAGER GK/bp NGC 14117 APPENDIX I AVOW LAKE LOCKOUT PROCEDURE AUDIT/INSPECTION EMPLOYEE AUDITED/1NSPECTED ______________________________________ DATE .____________ _____________________________________________________ TASK/EQUIPMENT DESCRIPTION _________________________________________ (ATTACH ISOLATION FORM IF AVAILABLE) DEPARTMENT __________ _______________________________ PROCEDURE FOLLOWED? YES , NO COMMENTS ________ ______ ___ AUDITED/INSPECTED BY EMPLOYEE, (SIGNATURE ) NGC 14118 REDACTED AVON LAKE LOCKOUT PROCEDURE AUDIT/INSPECTION EMPLOYEE ADDITED/INSPECTED _ DATE_________ M U /Jj /? 7-^______________________ TASK/EQUIPMENT DESCRIPTION AaClM G> O / /J r Ll #Jj_______________________________________ Buss (ATTACH ISOLATION FORM IF AVAILABLE) DEPARTMENT _ JZ93_____________ PROCEDURE FOLLOWED? YES . NO COMMENTS ______________________________________________ AUDITED/INSPECTED BY EMPLOYEE, (SIGNATURE ) ^GC 14U9 NAME: DATE: AVON LAKE GENERAL CHEMICAL PLANT EQUIPMENT ISOLATION - LOCKOUT TRUE/FALSE 1) An isolation device prevents the flow of energy and mater ials from one side of the device to the other side. 2) All valves are capable of being locked in a closed position. 3) Before maintenance work can begin, a written description of how the equipment has been isolated must be pre pared . 4) If someone has left their lock on a valve and has gone home for the night# the equipment night supervisor can cut the lock off without checking with anyofte- 5) Personal Protective Equipment (face shield# rubber gloves# boots and rubber suit) can be worn in lieu of taking time to isolate equipment.________ * 6) Lockout procedures apply only to electrically powered equipment. 7) A contractor can always follow his own lockout procedure when working on our equipment. 8) When two men are working as a "team''# only one has to lock out a piece of equipment before they both can work on it. 9) At the end of a shift# the keys to a lock can be given to the shift relief in order to save time. 10) It is necessary to lock out any piece of equipment whenever one of its safety guards is removed. GJK/bp 1-3-92 NGC 14120 NAME: IS, D&PS(f 'i_j DATE /-- /y~ ^ > \ AVON LAKE GENERAL CHEMICAL PLANT EQUIPMENT ISOLATION - LOCKOUT TRUE/FALSE 1) An isolation device prevents the flow of energy and mater ials from one side of the device to the other side. T 2) All valves are'capable of being locked in a closed Tposition. 3) Before maintenance work can begin/ a written description of how the equipment has been isolated must be pre pared. _J___ 4) If someone has left their lock on a valve and has gone home for the night/ the equipment night supervisor can cut the lock off without checking with anyone - p- 5) Personal Protective Equipment (face shield/ rubber gloves/ boots and rubber suit) cj>n be worn in lieu of taking time to isolate equipment. r 6) Lockout procedures apply only to electrically powered equipment. 7) A contractor can always follow his own lockout procedure when working on our equipment. 8) When two men are working as a "team"/ only one has to lock out a piece of equipment before they both can work on it. P' 9) At the end of a shift/ the keys to a lock can^be given to the shift relief in order to save time. H' 10) it is necessary to lock out any piece of equipment whenever one of its safety guards is removed. 7 GJK/bp 1-3-92 NGC 14121 BFGOODRICH COMPANY AVON LAKE GENERAL CHEMICAL PLANT HAZARD COMMUNICATION TRAINING LESSON PLAN 1. Introduction: Why are we providing training? 2. Overheads & Discussion (Appendix A) A. Hazard Communication Standard B. Avon Lake General Chemical Plant Written Program C. Labeling Requirements D. Dept. Labeling for Single ChemicalContainers. E. Dept. Labeling for Multiple-Chemical Containers. 3. Film: What You Don't Know Can Hurt You A. Questions/Answers 4. Film: The MSD5 - Cornerstone of Chemical Safety 5. Quiz NGC 14122 HAZARDOUS MATERIALS / MSDS 1993 TEST 1. WHAT DOES MSDS STAND FOR?____________________________ 2. AN MSDS INDICATES THE MANUFACTURE AND THE TRADE NAME OF THE MATERIAL. TRUEFALSE______ 3. ALL HAZARDS ARE LISTED ON THE PACKAGE LABEL. TRUE FALSE 4. DOES AN MSDS INDICATE PROTECTIVE EQUIPMENT REQUIRED FOR HANDLING? YES NO 5. AN MSDS INDICATES STORAGE PRECAUTIONS TO BE TAKEN. TRUE FALSE_____________ 6. WE KEEP MSDS BOOKS ONLY IN THE DISPENSARY AND FIRE BRIGADE OFFICE. TRUE FALSE 7. WHAT SHOULD YOU DO IF THE MATERIAL YOU ARE USING DOES NOT LOOK NORMAL? A. FLUSH IT TO THE SEWER WITH LOTS OF WATER. B. CALL THE SITE ENVIRONMENTAL MANAGER FOR RECOMMENDATIONS. C. SET THE MATERIAL ASIDE AND NOTIFY THE FOREMAN. D. USE THE MATERIAL AS NORMAL. 8. NEW CHEMICALS MAY BE ORDERED BY AN ENGINEER AS LONG AS THE SUPPLIER SENDS AN MSDS. TRUEFALSE 9. RESPIRATOR'S ARE REQUIRED WHEN WEIGHING UP LEAD. TRUE______ FALSE 10. WHAT ARE THE TWO TYPES OF PHYSICAL HEALTH HAZARDS? SIGNATURE DATE NGC 14123 HAZARDOUS MATERIALS / MSDS redacted 1993 TEST 1. WHAT DOES MSDS STAND FORifcctktASJi J 2. AN MSDS INDICATES THE MANUFACTURE AND THE TRADE NAME OF THE MATERIAL. TRUE FALSE __ 3. ALL HAZARDS ARE LISTED ON THE PACKAGE LABEL. TRUE. FALSE 4. DOES A*N MSDDS INDICATE PROTECTIVE EQUIPMENT REQUIRED FOR HANDLING? YES NO 5. AN MSDS INDICATES STORAGE PRECAUTIONS TO BE TAKEN. TRUE. FALSE 6. WE KEEP MSDS BOOKS ONLY IN THE DISPENSARY AND FIRE BRIGADE OFFICE. TRUEFALSE 7. WHAT SHOULD YOU DO IF THE MATERIAL YOU ARE USING DOES NOT LOOK NORMAL' A. FLUSH IT TO THE SEWER WITH LOTS OF WATER. B. CALL THE SITE ENVIRONMENTAL MANAGER FOR RECOMMENDATIONS. (C) SET THE MATERIAL ASIDE AND NOTIFY THE FOREMAN. D. USE THE MATERIAL AS NORMAL. 8. NEW CHEMICALS MAY BE ORDERED BY AN ENGINEER AS LONG AS THE SUPPLIER SENDS AN MSDS. TRUE FALSE 9. RESPIRATOR'S ARE REQUIRED WHEN WEIGHING UP LEAD. TRUE FALSE 10. WHAT.ARE THE TWO TYPES OF PHYSICAL HEALTH HAZARDS? ___uccMl___________________________________ ________ SIGNATURE DATE ?-/Y'P 1 NGC 14124 HAZARD COMMUNICATIONTRAINING FOR NEW_EMPLOYEES 1. A clue that a chemical has changed might be a: A. B. C. </&) Change in color or odor Separation into layers Formation of crystals All of the above 2. To make sure you have the correct chemical: A. (gp C. D. Note the size and type of container Read the label Note the appearance and odor Try some of it to see what happens 3. In most labeling systems, red is associated with: Toxics Reactivity Flammability Corrosives If there is no label placard or process sheet to tell you what the chemical is: A. Sniff it to see if you can recognize it B. If you think you know what it is, use it anyway C. Pour it down the drain None of the above 5. If you have to mix acid and water: A. Add the water slowly to the acid B. Be careful not to stir the solution Add the acid slowly to the water Both B and C 6'. Vapor density tells you: A. How rapidly evaporation will occur B. Whether the gas or vapor is lighter or heavier than air How thick or strong the gas is likely to be Both A and B 7. About how much 02 is there in the air you breath? A.- 10-20% (S) 19.5 - 21% C. 25 - 50% D. 50 - 100% NGC 14125 32 .izard Communication Training for New Employees 8. The type of eye protection available for your use is: A. Glasses with side shields B. Goggles C. Face Shields (HX) All of the above / ^ The three pieces of information on a chemical label are: A. B. (XT) D. Chemical Name, Hazard Warning, Name of Supplier Chemicaf Name, Hazard Warning, Transportation Requirements Chemical Name, Exposure Limits, Physical Data Reactivity, Employee Protection, Health Information 10. Chemicals likely to cause the greatest immediate harm to the outside of the body are: A. Solvents B. Toxic Metals C. Hydrocarbons Corrosives 11. You should not always rely on your nose as a gas detector because: A. It cannot tell you how concentrated the substance is B. Your sense of smell can deaden C. AH toxic gases have no odor D. All of the above Both A and B 12. The fastest and most common route by which chemicals enter the body is: A. CJ3P C. D. Absorption Inhalation Ingestion Osmosis 13. Poisoning by swallowing can be controlled through: A. Good Hygiene B. Wearing respirators & Not eating in the work area All of the above E. Both A and B NGC 14126 3 zard Communication Training for New Employees 14. The key to protecting yourself is: Making sure your skin is covered Wearing rubber gloves and safety glasses Matching the protection to the hazard Wearing a cartridge respirator in an oxygen deficient environment 15. Bubbles are a sign that: Heat is being generated a A gas is being given off C. The process is ready to explode D. The vapor pressure is rising 16. The reason that hazardous low-lying or confined areas should be checked before entering is: A. They could contain toxic gases B. There could be inadequate oxygen available for breathing C. They could be full of flammable vapors ~D. ) All of the above 17. Respirator users must be trained and tested. False 18. An eye wash or safety shower should only be used if you feel a burning sensation. True C False '1j$. Gasoline vapors are heavier than air. True (^False^) 20. All toxic gases can be detected at low odor levels. True f False/ 21. Chemical protective gloves differ depending on the material of construction. True J False 22. A Boiling Point is the temperature at which a chemical releases enough vapors for combustior True False ^__ NGC 14127 .ge 4 .Hazard Communication Training for New Employees REDACTED 23$ The Permissible Exposure Limit or the Threshold Limit Value is the maximum allowable exposure to air-borne concentrations over a work day. True f False 24. LD50 is a single dose of a material which1 on the basis of laboratory tests, is expected to kill 50 percent of a group of test animals. ^True^y' False 25. Where at ALTC can you obtain a Material Safety Data Sheet? / / Name SEW:drf HazaComm.sew Date NGC 14128 HAZARD COMMUNICATIONTRAINING FOR NEW EMPLOYEES 1. A clue that a chemical has changed might be a: A. Change in color or odor B. Separation into layers C. Formation of crystals D. All of the above 2. To make sure you have the correct chemical: A. ' Note the size and type of container B. Read the label C. Note the appearance and odor D. Try some of it to see what happens 3. In most labeling systems, red is associated with; A. Toxics B. Reactivity C. Flammability D. Corrosives 4. If there is no label placard or process sheet to tell you what the chemical is: A. Sniff it to see if you can recognize it B. If you think you know what it is, use it anyway C. Pour it down the drain D. None of the above 5. If you have to mix acid and water: A. Add the water slowly to the acid B. Be careful not to stirthe solution C. Add the acid slowly to the water D. Both B and C 6. Vapor density tells you: A. How rapidly evaporation will occur B. Whether the gas or vapor is lighter or heavier than air C. How thick or strong the gas is likely to be D. Both A and B 7. About how much Q, is there in the air you breath? A. 10 - 20% B. 19.5 - 21% C. 25 - 50% D. 50 - 100% NGC 14129 Page 2 Hazard Communication Training for New Employees 8. The type of eye protection available for your use is: A. Glasses with side shields B. Goggles C. Face Shields D. All of the above 9. The three pieces of information on a chemical label are: A. Chemical Name, Hazard Warning, Name of Supplier B. Chemical Name, Hazard Warning, Transportation Requirements C. Chemical Name, Exposure Limits, Physical Data D. Reactivity, Employee Protection, Health Information 10. Chemicals likely to cause the greatest immediate harm to the outside of the body are: A. Solvents B. Toxic Metals C. Hydrocarbons D. Corrosives 11. You should not always rely on your nose as a gas detector because: A. It cannot tell you how concentrated the substance is B. Your sense of smell can deaden C. All toxic gases have no odor D. All of the above E. Both A and B 12. The fastest and most common route by which chemicals enter the body is: A. Absorption B. Inhalation C. Ingestion D. Osmosis 13. Poisoning by swallowing can be controlled through: A. Good Hygiene B. Wearing respirators C. Not eating in the work area D. All of the above E_ Both A and B me 14130 Page 3 Hazard Communication Training for New Employees 14. The key to protecting yourself is: A. Making sure your skin is covered B. Wearing rubber gloves and safety glasses C. Matching the protection to the hazard D. Wearing a cartridge respirator in an oxygen deficient environment 15. Bubbles are a sign that: A. Heat is being generated B. A gas is being given off C. The process is ready to explode D. The vapor pressure is rising 16. The reason that hazardous low-lying or confined areas should be checked before entering is: A. They could contain toxic gases B. There could be inadequate oxygen available for breathing C. They could be full of flammable vapors D. All of the above 17. Respirator users must be trained and tested. True False 18. An eye wash or safety shower should only be used if you feel a burning sensation. True False 19. Gasoline vapors are heavier than air. True False 20. All toxic gases can be detected at low odor levels. True False 21. Chemical protective gloves differ depending on the materia! of construction. True False 22. A Boiling Point is the temperature at which a chemical releases enough vapors for combustion True False NGC 14131 Page 4 Hazard Communication Training for New Employees 23. The Permissible Exposure Limit or the Threshold Limit Value is the maximum allowable exposure to air-borne concentrations over a work day. True False 24. LD50 is a single dose of a material which, on the basis of laboratory tests, is expected to kill 50 percent of a group of test animals. True False 25. Where at ALTC can you obtain a Material Safety Data Sheet? Name SEW:drf HazaComm.sew Date 14122 DATE: 09-09-93 12:53 THE GEON COMPANY CAMPAIGN PICK LIST PAGE: ] LOCATION: 12 CAMPAIGN: A309Z10 PROCESS COPE: Z0005 REWORK EXISTS: N OWNER: ITEM: B44 1 872410000264 QUANTITY TO PRODUCE: ADJUSTED QUANTITY: QTY REWORK AVAIL: 24, 700 24, 700 A EXP DATE BLDG INV LOCATION LOT NUMBER CONT GRADE QTY ON-HAND QTY AVAIL COMPONENT ITEM : - B455 - TRAC TRAC - TRAC - TRAC - TRAC 001104770000 110X477 SILO ALS ILOS B1 7 31 U 1 23307 N33U014 N3 3U 0 1 6 A64875 N38W054 B10 61 N35U025 B 10 6 1 N35W026 99 90 90 90 90 90 COMPONENT ITEM: 873330002102 87333-000-2102 - B441 M/B BOX AREA A304X08 60 COMPONENT ITEM: 9 1 200S086 9-27-95 B441 LIQUIDS jS-07-95 B441 LIQUIDS MARK 1900 16407E 16522E TO TO COMPONENT ITEM: 92100B211 YELLOW Y-933- LD 0 4*30-95 B441 N.SPEED RACK M0T78-3 B3 COMPONENT ITEM: 92J. 00B22S ORANGE 650 04-30-95 B441 N.SPEED RACK 2JNQF FD COMPONENT ITEM : 924709566 04-30-95 B441 NORTH WHSE TI-PURE R-9G0 LP 26337 B3 COMPONENT ITEM: 925710356 08-27-95 B441 EAST WHSE ULTRAPFLEX H A-3-219-16 B3 COMPONENT ITEM: 941710699 09-03-95 B441 NORTH DOCK 2301 X 50 815 B3 COMPONENT 08-04-95 09-07-95 . 9 - 0 7-95 ITEM: B441 B 44 1 B44 1 942710859 EAST WHSE EAST WHSE EAST WHSE BLENDEX BB1289 BB1427 BB1440 338 B6 66 BC 0 00 Q 00 o o0 0 00 05 > 05 QTY 150,903 53,744 78.000 5 5 112,082 REQD: 0 00 467 QTY REQD: o 00 13,165 0 00 . 28,800 QTY REQD: 0 00 58 QTY REQD: 0 00 31 QTY REQD: 0 00 17,960 QTY REQD: o 00 8,137 QTY REQD: 0 00 3,600 QTY REQD: o 00 0 00 o 0\' QTY 9,400 18,000 iS , 000 REQD : 150, b3 , 78. 112, 19,009. 12 . 13, 28, 380. 20. 12 . 17 . 380. 8, 950 . 3,i 570. 9, 16 , 18. 2,281. NGC 14133 DATE: 09-09-93 12:53 THE GEON COMPANY CAMPAIGN PICK LIST PAGE LOCATION: 12 CAMPAIGN: A 3 0 9 Z 1 0 PROCESS CODE: Z0005 REWORK EXISTS*. N OWNER: ITEM: B441 872410000264 QUANTITY TO PRODUCE ADJUSTED QUANTITY: GTY REWORK AVAIL: 24,700 24,700 EXP DATE BLDG INV LOCATION LOT NUMBER CONT GRADE QTY ON-HAND QTY AVAIL COMPONENT ITEM: 94300L0I6 0 4 - 3 0 - 9 5 B44 1 L I1U IDS MINERAL OIL USP BULK TO 0 00 8,0 *'. i QTY REQD: COMPONENT ITEM : 94300L027 POLYETHYLENE AC629A 07-20-95 B441 3.SPEED RACK 366296 B2 0 00 1,595 QTY REQD : COMPONENT ITEM: 94300L034 08-24-95 B441 EAST WHSE 08-24-95 B441 EAST WHSE CA STEAR ATE-FUSED 0S093 B3 08163 B3 0 00 0 00 8,647 16,000 QTY REQD: COMPONENT ITEM : 94300L040 7-16-95 B441 EAST WHSE 09-08-9 5 B441 EAST WHSE PARAFFIN W2505 W2549 165 F M.P. PWD. B5 0 00 B5 0 00 . QTY 46 5,400 REQD: 8, 570. 1, 19. 81 16 475. 5 19 NGC 14134 DATE: 09-09-93 12:53 CAMPAIGN : A309Z10 PRODUCT : S72410000264 THE GEON COMPANY PROTECTIVE EQUIPMENT PAGE: COMPONENT DESCRIPTION 92100B211 YELLOW Y-933-LD BODY PART/EQUIPMENT Hand Eye(s > Respiratory / CHEMICAL PROTECTIVE GLOVES SAFETY GLASSES / HALF MASK AIR PURIFYING RESPIRATCL COMPONENT DESCRIPTION 92100B228 ORANGE 650 BODY FART/EQUIPMENT Hand Eye(s) Respir ator y / CHEMICAL PROTECTIVE GLOVES / SAFETY GLASSES / HALF MASK -AIR PURIFYING RESPIRATG COMPONENT DESCRIPTION 924709566 TI-PURE R-960 LP BODY PART/EQUIPMENT Eye < s) Respiratory / SAFETY GLASSES / HALF MASK AIR PURIFYING RESPIRATG: COMPONENT DESCRIPTION 925710356 ULTRAFELEX H BODY PART/EQUIPMENT Hand Eye(s) Respiratory / CHEMICAL PROTECTIVE GLOVES / SAFETY GLASSES / HALF MASK AIR PURIFYING RESPIRATOR COMPONENT DESCRIPTION 9417*10699 2301 X 50 BODY PART/EQUIPMENT Eye < s ) Rp^niratorv NGC 14135 / SAFETY GLASSES / DISPOSABLE DUST MASH DATE: 09-09-93 12:53 UPPER EXTREMITIES THE GEON COMPANY PROTECTIVE EQUIPMENT PAGE: / CHEMICAL PROTECTIVE SLEEVES COMPONENT DESCR IPT ION 942710B59 BLENDEX 338 BODY PART/EQU IPMENT Eye(s) Respireto r y / SAFETY GLASSES / DISF 03 ARLE DU 3 T MAS K COMPONENT DESCR IPT ION 94300L016 MINERAL OIL 'USF BODY PART/EQUIPMENT Eye < s) / SAFETY GLASSES COMPONENT DESCRIPT ION 94300L027 POLYETHYLENE A C 6 2 9 A BODY PART/EQUIPMENT Respiratory Eye(s) / HALF MASK AIR PURIFYING RESPIRATO / VAPOR TIGHT GOGGLES COMPONENT DESCR IPT ION 94300L034 CA STEARATE-FUSED BODY PART/EQUIPMENT Respiratory Eye(s) / HALF MASK AIR PURIFYING RESPIRATO / SAFETY GLASSES NGC 14136