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Risk Management Plans and General Duty Clause - Download as DOC

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					9.0      Safety (Process Safety)

      This section covers safer chemistry for the processes and support
processes. This section does not cover the chemical or material inherent hazard
characteristic for safety (corrosive, flammable or explosive). That information is
covered in section x.x.

9.1      Goal

         Safer chemical processes.
            – Company and Facility Safety Record
                  • Number of process safety incidents
                  • OSHA recordable and lost workday incidence rates-
                     employees and contractors
                  • Fatalities for employees and contractors
                  • Number of DOT reportable distribution incidents
            – Training/education
                  • Safety Committees
                  • Training
                  • Safety policies
            – Continuous improvement

         Categories and Definitions

–       Employee Safety and Health
–       Facility Safety Record including:
           – Number of process safety incidents
           – OSHA recordable and lost workday incidence rates- employees
                and contractors
           – Fatalities for employees and contractors
           – Number of DOT reportable distribution incidents
    – Training/education
                   • Safety Committees
                   • Training
                   • Safety policies
–       Continuous improvement (Narrative addressing going beyond regulations
for storage/inventory)
–       Extremely hazardous substances management (inventory/storage)
•       Explosions, fire, releases
•       Report storage, risk management plan in place
–       Extreme chemical process conditions
•       Relating to GC principles; ambient conditions (temperature/pressure)


      EXISTING SAFETY PROGRAMS
      • ACC Responsible Care: http://www.responsiblecare.org
   •    AIChE’s Center for Chemical Process Safety
        http://www.aiche.org/CCPS/index.aspx
    • SOCMA Chemstewards
http://www.socma.com/ChemStewards/
    • Global Reporting Network: www.globalreporting.org
    • NSF 140
    • OSHA Process Safety Management
            – 29 CFR 1910.119. (www.osha.gov).
    • Clean Air Act’s 112(r) General Duty Clause and Risk Management Plans :
        http://www.epa.gov/oecaerth/monitoring/programs/caa/112r.html
    • ASTM Process Hazard Evaluation
    • Reference: Insurance Checklist requirements- These may include storage
        requirements.

DEFINITIONS
  • Environmental Management System (EMS): a tool used by a company to
     identify and control the environmental impact of its activities, products or
     services, and to improve its environmental performance continually, and to
     implement a systematic approach to setting environmental objectives and
     targets, to achieving these and to demonstrating that they have been
     achieved. Example: International Organization for Standardization (ISO)
     14001: 2004, Environmental management systems –Requirements with
     guidance for use. (www.iso.org ).
  • Quality Management Standard: a set of policies, processes and
     procedures required for planning and execution (production / development
     / service) in the core business area of an organization. Example:
     International Organization for Standardization (ISO) 9001: 2000, Quality
     management systems –Requirements (www.iso.org)
  • Process safety incidences (PSI): an incident is reported as a process
     safety incident if it meets all four of the following criteria: 1) Chemical or
     chemical process involvement 2) Above minimum reporting threshold 3)
     Location; and 4) Acute release. Note: ACC to adopt Center for Chemical
     Process Safety (CCPS) version of process safety reporting. Mandatory
     reporting to the ACC using the CCPS version will begin in 2010. (ACC
     Responsible Care)
  • Recordable Injury Rate: Defined by OSHA as the number of recordable
     incidents for each 100 full-time employees per year, based on 2,000 hours
     worked per employee per year.(ACC responsible care)

   •   Days Away from Work Incident Rate: Defined by OSHA as the number
       lost workday incidents for each 100 full-time employees per year, based
       on 2,000 hours worked per employee per year.(ACC responsible care)
   •   Fatalities: Number of fatalities included on OSHA 300 log for employees
       and for contractors that occurred on the facility premises. (ACC
       responsible care)
   •   Distribution Incidents: Those that meet the criteria of DOT regulatory
       requirements and fall under the members’ ACC dues base. Form 5800
       incidents are attributable to the ACC member if the member is listed as
       either the shipper or carrier on the DOT 5800 Form. (acc responsible care)
   •   Safety committee: a formal joint management-worker health and safety
       committees that helps monitor and advise on occupational health and
       safety programs (Global reporting network)
   •   Continuous improvement: Benchmark safety endpoints against past years
       to show marked improvements. (Global Reporting Network)




RECOMMENDATIONS
Company and Facility Safety Record
    Your company tracks the number of process safety incidents as defined
       by CCPS or equivalent
    Your company tracks reportable spills/incidents
    Your company tracks OSHA recordable and lost workday incidence rates-
       employees and contractors
    Your company tracks fatalities for employees and contractors
    Your company tracks number of DOT reportable distribution incidents
    Your company has an Environmental Management System
    Your company has a publically available EMS
Training/Education
    Your company has safety committees
    Your company maintains safety policies
    Your company meets and goes beyond OSHA workplace safety training
       requirements
    Your company meets and goes beyond DOT transit safety training
       requirements
Continuous improvement
    Your company maintains safety records in the categories listed above and
       sets goals for continuous improvement.


   •   Do you have an extremely hazardous substance per 302?
          – If so, report management system used for this chemical storage
          – Report above and beyond the regulations related to this chemical
             storage
          – Report accidents/incidents per man hour

				
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