CalARP Formal Evaluation Review Presented By: Beronia Beniamine, Stanislaus County, Senior Hazardous Material Specialist & Greg Taylor, Foster Farms, Corp.

CalARP FormalEvaluation Review

Presented By:

Beronia Beniamine, Stanislaus County, Senior Hazardous

Material Specialist

&

Greg Taylor, Foster Farms, Corp. PSM Specialist

GENERAL CalARP REGUIREMENTS

Process Applicability Management System Registration Information Qualified Person Certification Recordkeeping Hazard Assessment Emergency Response Program2/3 Requirements Updates

Management System

Does the facility have a CalARP/RMP management system?

Has a qualified person/position been assigned the responsibility for CalARP/RMP compliance?

Can the facility demonstrate that there is not a conflict of interest in their management program (e.g. is the person responsible for the programs also responsible for minimizing costs)?

Registration Information

Are items a-u in section 2740.1 of the CCR identified? Please refer to the Formal Evaluation Checklist, it includes all the June 24, 2004 changes.

We have handouts with the Formal Evaluation Checklist that you can pick up at the end of our presentation.

HAZARD ASSESSMENT

Offsite Consequence Analysis Parameters Worst-Case Release Scenario Analysis Alternative Release Scenario Analysis Defining Offsite Impacts to the Population Defining Offsite Impacts to the Environment Offsite Consequence Analysis Review and Update Offsite Consequence Analysis Documentation

Five-Year Accident History

Offsite Consequence Analysis

Was the analysis performed by qualified people? Are the technical assumptions credible? Was the source of the population estimate data

identified? Was the model used valid for the type of material? Was the initiating event for the scenario derived from a

valid resource? (e.g. PHA/HR, accident history, industry evidence, etc.)

Does the analysis describe the impacts on local population and the environment?

Will any safeguards claimed withstand the event and still function?

Offsite Consequence Analysis

Do the system operators know what will happen if a worst case scenario takes place?

Is the worst case scenario up to date (within 5 years or within 6 months of a major change)?

Do the system operators know what will happen if an alternative case scenario takes place?

Is the alternative case scenario up to date (within 5 years or within 6 months of a major change)?

While CalARP and EPA regulations require estimating the population within a circle having a radius equal to the distance to toxic endpoint, the actual area affected by the scenarios as predicted by most models is less than 6% of the area of the circle.

Typically the population that will likely be affected is significantly less than what is reported in a facilities CalARP Worst-Case and Alternative Release Scenarios!

Note: 2004 ERG NH3 Worst-Case downwind evacuation is 1.4 miles!

Wind

Variables & Modifying ConditionsVariables & Modifying ConditionsRelated to Downwind DistancesRelated to Downwind Distances

Location– (inside building vs. open field vs. downtown)

Weather– (wind, temperature, rain)

Size of problem– (5 gallon vs. 5,000 gallon)

Stage of incident– (short vs. long duration release)

Nature of materials– Semi Bad Stuff, Bad Stuff, or Really Bad Stuff

Type, condition & behavior of container/vessel

Responders & equipment

Availability & amount of control agents

Anhydrous Ammonia @ 20,000 ppm can be in the form of a visible cloud and is fatal now!

Anhydrous Ammonia @ 20,000 ppm can be in the form of a visible cloud and is fatal now!

Note what happens when anhydrous ammonia is released as an aerosol! An aerosol is heavier than air and in its vapor form its lighter that air!

UpwindUpwind

The result of a state-wide drill was that the ammonia lifted over the firefighters and dropped down on the spectators.

Emergency Response

Emergency Response Applicability– Emergency Action Plan

• Owner or operator whose employees will not respond to accidental releases of regulated substances need to meet the following:

– Coordinate with community plan

– Coordinate with fire agencies for flammables.– Procedures for notifying emergency responders.

Emergency Response Program

Emergency response program shall include the following:– Emergency Response/Action Plan;

• Procedures for informing/interfacing w/agencies/public;

• Documentation of first aid/medical monitoring treatment;

• Post incident response procedures;

– Procedures for equipment use, inspection, testing, maintenance.

– Training in Incident Command System.

– Procedures in place to review and update plan

– Coordination w/community emergency response plan.

Emergency Response Program

If employees are involved in emergency response does the plan address the following?– Emergency recognition

– Safe distances and places of refuge

– Site security and control

– Are event specific plans (e.g. IAP and SSP) developed prior to entry into IDLH environments per CCR Title 8, Section 5192 requirements.

– Etc…

IN C ID E N T O B JE C T IV E S

1 . IN C ID E N T N A M E

A m m onia R elease ? Y E S __ N O __ 2 . D A TE PR E PA R E D

____ /____ /_____

3 . T IM E PR E PA R E D

__________________________

4 . O P E R A T IO N A L P E R IO D (D A T E /T IM E ) ____ /____ /____ _____ H ours (T yp ically 2 to 8 H ours)

5 . G E N E R A L C O N T R O L O B JE C T IV E S FO R T H E IN C ID E N T (IN C L U D E A L T E R N A T IV E S) T he safe ty o f a ll personnel on site m ust be our first consideration . P ro tect life , environm ent & p roperty (rem em ber L ife is 1 st, E nvironm ent is 2 nd , & P roperty is last!

P rio rity C on tro l O b jective IC S A ssignm ent: E stab lish in itia l iso la tion perim eters per E R G guidelines and contro l access to a ll areas o f th is incident. R em ain up w ind , upgrade and upstream o f any re lease . A ssigned to : E n ter N am e(s)

S afety: T he sa fe ty o f a ll personnel o n site m ust be our firs t consideration .

Iso la te & D eny E ntry: T his m eans an evacuation o f the im m ediate area and contro l o f a ll entry po ints to p ro tect o ther personne l in surround ing areas. R em ain up w ind , up grade and upstrea m o f any release . In itia l Iso lation D istance ________ feet.

N o tifica tio ns: (P lant, M anagem ent, 9 -1 -1 (F ire , H azM at & P o lice), N at’l R esponse C ente r, S ta te O E S , & C o unty A A , and o thers as necessary e .g . L ocal W ater T reatm en t, R egional W a ter Q ua lity, F ish & G am e, e tc .) C ircle those that have been o r are being no tified .

C o m m and: IC S positions are docum ented on the S ite Sa fety P lan.

Identifica tion & H azard A ssessm ent: H azards are docum ented on the S ite Sa fety P lan "Sections III & IV "

A ction P lanning: E xam ple: re scue, reconna issance, conta inm en t, contro l, o r no action until adequate resources arrive . C irc le those tha t are being considered .

S am p le In cid ent A ction P lan (IA P )S am p le In cid ent A ction P lan (IA P )

Protective Equipment: Protective equipment being used to take safe defensive actions: ____________________________________

Containment & Control: Defensive Steps being considered and or taken: _______________________________________________

Protective Actions: Notify appropriate agencies (e.g. Police, Fire, County, etc.) that measures need to be taken to protect persons beyond our property lines. This might include evacuation or shelter in place. Agencies have been notified? Yes ___ or No ___

Decontamination: Initially setup for 2 - stage emergency decon to protect life.

D isposal: Follow all applicable laws and regulations if any HazW aste is generated.

Documentation: Including but not limited to IAP, Site Safety Plan, IC Emergency Incident Log, Incident Investigation, and Critique.

6 . W E ATHE R FO R E C AS T FO R O P E R ATIO NAL P E R IO D: Te m p : Ho t, Mild o r C o ld S ky: C le a r o r C lo u d y Hu m id ity: Dry, F o g g y, R a in Win d : No n e , Lig h t, Me d ium , He a vy (C irc le a ll th a t a p p ly) Lo g a c tu a l c o n ditio ns in c lu d in g : Te m p _ _ _ _ _ _ _ , W ind S p e e d _ _ _ _ _ _ _ , W in d Dire c tio n _ _ _ _ _ _ _ .

7 . G E NE R AL/S AFE TY ME S S AG E Th e s a fe ty o f a ll p e rs o n n e l o n s ite m us t b e o u r firs t c o ns id e ra tio n . S a fe ty o f th e re s p o n s e p e rs o n n e l is o f th e h ig h e s t p rio rity. All wo rk is to b e c o n d uc te d in a s a fe m a n n e r a n d if a n y u ns a fe c o n d itio n is e n c o u n te re d it s h ou ld b e im m e d ia te ly re p o rte d to th e S a fe ty O ffic e r. Th e e n try te a m is to im m e d ia te ly le a ve th e Ho t Zo n e if a n y u ns a fe co n d itio n is e nc o u n te re d .

8. ATTACHM ENTS (? IF ATTACHED) ORGANIZATION LIST (ICS 203) M EDICAL PLAN (ICS 206) HAZ M AT SITE SAFETY PLAN

DIVISION ASSIG NM ENT LISTS (ICS 204) INCIDENT M AP ___________________________

COM M UNICATIONS PLAN (ICS 205) TRAFFIC PLAN ___________________________

202 CSTI 9. PREPARED BY:

_________________________________________

10. APPROVED BY INCIDENT COM M ANDER

_______________________________________________________

Sample Site Safety Plan (SSP) Sample Site Safety Plan (SSP)

SITE SAFETY AND CONTROL PLAN

1. Incident Name:

Ammonia Release? YES ___ NO ___

2. Date Prepared: ___/___/_____

Time: ____________________

3. Operational Period: ___________

(Typically 2 to 8 Hours)

Section I. Site Information

4. Incident Location: (e.g. Engine Room)

Section II. Organization

5. Incident Commander: Enter Name

6. Operations Section Chief:

(Typically None)

7. Information Officer: _______________________

(Typically Legal Council or Risk Management)

8. Safety Officer: Enter Name

(May be same as IC)

9. Entry Team Leader: Enter Name 10. Site Access Control Leader (Typically None)

Communications/Security: Enter Name

11. Field Monitoring: Enter Name

12. Decontamination Leader: Enter Name 13. Safe Refuge Area Mgr: Enter Name

(Typically someone from production)

14. Medical Monitoring: Enter Name

15. Training: Is everyone's training current? YES___ NO___

16. Head Count: Is all personal accounted for? YES___ NO___

17. Entry Team (Buddy System)

Name: Level

18. Decontamination Element

Name: Level

Entry 1 Enter Name A Decon 1 Enter Name (May be Decon Leader) B

Entry 2 Enter Name A Decon 2 (Required for formal Decon) ________________ B

Entry 3 Enter Name A Decon 3

Entry 4 Enter Name (May be Entry Team Leader) A Decon 4

Section III. Hazard/Risk Analysis

19. Material Container type /

Source of Leak

Qty. Phys.

State

pH IDLH F.P. I.T. V.P. V.D. S.G. LEL UEL

Anhydrous Ammonia (UN# 1005) ______________? ____? ____? 11.6 300 ppm NA 1204 F 8.5 atm 0.6 0.6+ 15% 28%

Comment: Anhydrous Ammonia - Primary toxicity risks include inhalation and dermal hazards secondary risk is fire/explosion hazard. The PEL for Anhydrous Ammonia is 25 PPM. (You may have to conduct recon to determine Source of Leak, Quantity, and Physical State.)

Section IV . H azard M onitoring

20. L E L Instrum ent(s): C on fi n ed Sp ace L E L M eter

21. O 2 I nstrum ent(s): C on fi n ed Sp ace O 2 M eter

22. T oxicity/PPM Instrum ent(s): A m m o n ia T o xici ty M eter

23. R adiological I nstrum ent(s): N /A

C om m ent: T h e E x c lu s io n Z o n e s h a l l b e m o n i to r e d f o r p r im a r y / s e c o n d a r y h a z a r d s b y u s in g O 2 , L E L , a n d P P M m o n i to r in g d e v ic e s .

Im m e d ia t e e v a c u a t io n o f e n t ry t e a m fro m th e H o t Z o n e i f O 2 le v e l d r o p s b e lo w 1 6 % o r L E L a p p r o a c h e s 1 0 % o f th e L E L

P e r im e te r a n d Z o n e m o n i to r in g w i l l b e p e r f o r m e d u s in g to x ic i ty in s t ru m e n t( s ) a n d p e r im e te r / z o n e s w i l l b e a d ju s te d a s r e q u i r e d .

Section V . D econtamination P rocedures

24. Standard D econtam ination Procedures: Y ES: _ _ _ _ _ N O : _ _ _ _ _ C om m ent:

In i t i a l ly s e tu p fo r 2 - s ta g e e m e r g e n c y d e c o n to p r o te c t l i f e . T r a n s i t io n to f o r m a l 2 - s t a g e d e c o n to p ro te c t e n v i r o n m e n t a n d o r p ro p e r ty .

Section V I . Site C ommunications

25. C om m and Frequency _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 26. T actical Frequency: N o n e 27. Entry Frequency: H an d sign als an d h o rn .

Section V I I . M edical A ssistance

28. M edical M onitoring Y ES: _ _ _ N O : _ _ _ 29. M edical T reatm ent and T ransport I n -place Y ES: _ _ _ _ _ N O : _ _ _ _ _

C om m ent:

C o n d u c t p r e - e n t ry a n d p o s t - e n t ry m e d ic a l m o n ito r in g o f e n t r y t e a m , b a c k u p t e a m a n d d e c o n t e a m p r io r t o e n te r in g H o t Z o n e . T ru c k o r o th e r v e h ic le i s a v a i la b le f o r t r a n s p o r t a t io n . Y E S _ _ _ N O _ _ _ A 9 1 1 c a l l h a s b e e n m a d e to r e q u e s t b a c k u p m e d ic a l a n d t r a n s p o r ta t io n s u p p o r t ? Y E S _ _ _ N O _ _ _

Section VIII. Site Map

30. Site Map: SEE ATTACHED MAP/SITE PLAN (Be sure to indicate Wind Direction, Command Post Location, Zones [Hot, Warm, Decon, Cold, Assembly Area, and Entry & Escape Route(s)] here or on attached Map/Site Plan.)

N

Weat her

Com m and Post

Zones

Escape Rout es

Assem bl y Areas

Ot her

If this information has been included on your attached Map/Site Plan then place an X in each box to confirm.

Wind Direction

Zoning within the perimeter (ICS System):– Support Zone or Cold Zone or Green Zone.– Contamination Reduction Zone or Warm Zone or Yellow Zone.– Contamination Reduction Corridor (DeCon Area)– Exclusion Zone or Hot Zone or Red Zone.

Zoning within the perimeter (ICS System):Zoning within the perimeter (ICS System):–– Support Zone or Cold Zone or Support Zone or Cold Zone or Green ZoneGreen Zone..–– Contamination Reduction Zone or Warm Zone or Contamination Reduction Zone or Warm Zone or Yellow ZoneYellow Zone..–– Contamination Reduction Corridor (Contamination Reduction Corridor (DeCon AreaDeCon Area))–– Exclusion Zone or Hot Zone or Exclusion Zone or Hot Zone or Red ZoneRed Zone..

REMEMBER Only trained

responders are allowed in

control zones!

Perimeter may need to be over 1 mile downwind!

ICP

SafeRefugeArea

StagingArea

Section IX. Entry Objectives 31. Entry Objectives: Perform recon for trapped or injured persons and rescue same if safe do to so. Perform recon to determine source of leak and isolate same if safe to do so. Remember ONLY IF “GAINS” OUTWEIGH “RISKS” SHOULD THE ACTION BE TAKEN!

Prior to entering the Exclusion Zone or performing Decon personal shall be wearing proper protective equipment.

The safety of all personnel on site must be our first consideration. Safety of the response personnel is of the high est priority. All work is to be conducted in a safe manner and if any unsafe condition is encountered it should be immediately reported to the Safety Officer. Remember to respond safely, slowly, methodically, and watch for slip, trip, and fall hazards. The entry team is to immediately leave the Hot Zone if any unsafe condition is encountered.

Section X. SOP’S and Safe Work Practices 32. Modifications to Documented SOP’s or Work Practices YES: _______ NO: _______

Comment: (If you are not going to follow your SOPs and or Isolation Steps indicate what you intend to do here or referred to an attachment.)

Section XI. Emergency Procedures

33. Emergency Procedures:

Two long horn blasts from the Entry Team Leader means that the entry team is to immediately leave the Hot Zone. If the entry team requires immediate rescue they are to signal by continuous short blasts from their horn. Hand signals will be reviewed prior to entry into Hot Zone and used for routine communication. If the entry team cannot exit the way they entered the Hot Zone they are to immediately use the escape route identified on the Map/Site Plan.

Section XII. Safety Briefing

34. Safety Officer Signature: (M ay be same as IC) Safety Briefing Completed (Time): ________________________

Safety Briefing M UST be completed prior to entering H ot Zone

_________________________________________________

35. HM Group Supervisor/Entry Leader Signature:

_________________________________________________

36. Incident Commander Signature: (M ay be same as SO)

_____________________________________________________

SOP’s Refer to Example On Next Slide!SOP’s Refer to Example On Next Slide!

Typical Air Handler / Evaporator

(with valves on roof)Isolation Steps

1. Close Liquid Valve

2. Open Liquid SOV

3. Close Hot Gas Valve

4. Open Hot Gas SOV

5. Close Suction Valve

6. Close By-Pass Valve

7. Follow Pump Out SOP

2

1

3

6

5

4

Defensive Action = Mitigating a release utilizingskills normally used in operating facility systemsThis is a example of what facilities can develop to

their assist emergency response teams.

PROGRAM 3 REQUIREMENTS Executive Summary Process Safety Information Process Hazard Analysis Operating Procedures Training Mechanical Integrity Management of Change Pre-Startup Review

PROGRAM 3 REQUIREMENTS

Compliance Audits Incident Investigation Employee Participation Hot Work Permit Contractors

What Process Safety Information Is Required?

Block flow diagram or simplified process flow diagram,

Process chemistry (e.g. M.S.D.S.), Maximum intended inventory, Safe upper / lower limits - temp, pressures,

flows, compositions, etc., Evaluation of the consequences of deviation

(from the safe upper / lower limits)?

What Process Safety Information Is Required? (Cont.) Information on equipment used in the process:

– Materials of construction (e.g. ASME certified vessels) documented,

– Piping and instrument diagrams (P&ID’s current & accurate?),

– Electrical classification documented, – Relief system design and design basis documented, – Ventilation system design documented,– Design codes and standards employed to construct the

process must be documented, – Safety systems (e.g. detection) documented?– Documented Safe upper / lower limits such as temp,

pressures, flows, compositions, etc.

Documentation showing equipment complies with recognized engineering practices?

Or documentation showing existing equipment is designed, maintained, inspected, tested and operated in safe manner?

What Process Safety Information Is Required? (Cont.)

Should a Process Hazard Analysis or Hazard Review be accepted if the Process Safety

Information was unavailable or inaccurate?

What Should the Process Hazard Analysis Address? Hazards of process, Previous incidents (not just reportable releases) with

the potential for accidents including near misses, Engineering and administrative controls, Consequences of failure of engineering and

administrative controls including safe operating limits,

Stationary source sitting, Human factors, Qualitative evaluation of health and safety effects of

failure of controls,

What Should the Process Hazard Analysis Address? (Cont.) External events?

– Were external events such as fires, floods, earthquakes, transportation accidents, extreme wind or tornadoes, fog, and extreme temperatures discussed?

– Were external events such as site security related to sabotage, terrorism, and theft discussed?

– Were external events such as site security related to the potential for adjacent facilities or systems to impact the process discussed?

Did the PHA and or Re-validation address procedural steps where appropriate (e.g. hot gas defrost cycle on an ammonia evaporator)?

Was PHA performed by a knowledgeable team?

What Follow Up Is Required for Process Hazard Analysis Recommendations? Is a system established to promptly address findings

and recommendations? Is there a written schedule of when these actions are

to be completed? Have the recommendations been resolved in a

timely manner? Are the resolutions documented? Have actions been completed as soon as possible? Has PHA or Hazard Review been done for major

changes or additions to the process? Has PHA been re-validated at least every 5-years?

Process Hazard Analysis Recommendation Withdrawal

Employer can justifiably decline to adopt a recommendation where the employer can document, in writing and based upon adequate evidence, that one or more of the following conditions are true; analysis contains material factual errors; recommendation is not necessary to protect health &

safety of employees of owner and/or contractors; an alternative measure would provide sufficient level

of protection; or recommendation is infeasible.

Operating Procedures

Initial startup, Normal conditions, Temporary operations, Emergency shutdown, Emergency operations, Normal shutdown, Startup following a turnaround or after

emergency shutdown?

Which SOPs reasonably apply to most processes?

Written operating procedures which address: – Deviation from Normal Operating limits:

• Consequences of deviation, • Steps required to correct or avoid deviation?

Regular review/annual certification of operating procedures?

Is a periodic review of written prevention programs such as EAP/ERP, MOC, PM Program, Incident Investigation, Contractor Safety Programs, done?

What Other Operating Procedures Must a Facility Have?

What Safe Work Practices Should The Facility Have In Place? Hot Work Permit Program, Lockout/Tagout program, Opening Process Equipment Program (i.e. Line Break

Permit), Confined Space Permit and Rescue Programs, Medical Surveillance Program (respiratory protection

program), and HazCom Program. Written evaluations and training records. Proper maintenance of emergency response equipment.

What Training Is Required?

Is refresher training provided at least every three years, and more often if necessary?– Are employees consulted with concerning the

frequency and need for refresher training?– Documented training on SOPs, maintenance

procedures, operating limits, safety systems & hazards, emergency procedures, safe work practices, etc.

– Is the same level of training provided to an employee prior to a new job assignment?

– Is training provided to contractors who maintain or operate the system or process?

What Training Documentation Is Required?

Does training documentation include:– Documentation that employee received and

understood training,

– Identity of employee,

– Date training occurred,

– Means used to verify employee training (e.g. testing, observation, demonstration, etc.) comprehension?

What Should Be Included In A Mechanical Integrity Program? Written procedures to maintain the on-going

integrity of ALL process equipment, Planned (preventive, predictive, and proactive but

not reactive) and corrective maintenance procedures,

Training for process maintenance activities, Inspection and testing of process equipment, Prompt correction of equipment deficiencies, Quality assurance (e.g. appropriate checks and

inspections performed according to manufacturer’s recommendations, & suitable spare parts available).

Is the program documented?– Including the date of each inspection or test,

– The name of the person who performed the inspection or test,

– The serial number or other identifier of the equipment on which the inspection or test was performed,

– A description of the inspection or test performed,

– The results of the inspection or test, and

– Actions taken to correct deficiencies.

What Documentation Should Be Included In The Mechanical Integrity Program?

Mechanical Integrity Program

Do the written testing and inspection procedures follow recognized and generally accepted good engineering practices including but not limited to?– Appropriate frequencies for testing and inspection of

process equipment (e.g. API, IIAR, NFPA, ANSI, ASME, etc… guidelines or manufacture's recommendations),

– Criteria for acceptable test results,

– Methods to analyze inspection and testing results to assure that equipment deficiencies are corrected when outside acceptable limits.

Mechanical Integrity Program (Cont.)

Is data collected and documented during normal daily walk around including but not limited to?– Liquid levels in all vessels,

– Inspections of equipment and tasks to be performed such as defrosting evaporators,

– Instrument readings such and operating conditions (e.g., temperature, pressure, flow, level, etc.), and

– System upsets including operating outside normal operating limits and what corrective actions were taken.

Mechanical Integrity Program (Cont.)

Are Equipment Deficiencies discovered during routine maintenance and daily walk around corrected?– The employer shall correct deficiencies in

equipment which are outside acceptable limits defined by the process safety information or manufacturers recommendations before further use, or in a safe and timely manner provided means are taken to assure safe operations.

Management of Change and What Is Considered Change? Change - Any modification which affects the capability of a

process to maintain control of the physical and chemical transformations taking place, including all modifications to equipment, procedures, raw materials, and processing conditions other than replacement-in-kind.

For example (this list is not to be considered all inclusive):– Substitution of a material of construction with a different material.

For example, a process vessel and/or section of piping is designed with black carbon steel. Replacement of a section of the equipment with stainless steel would constitute a change.

– Replacement of a vessel with one of a different pressure rating.

– Replacing a gasket with one of a different material.

Is the technical basis for ALL proposed changes, such as but not necessarily limited to, the reasons for performing the work, desired results, technical design, and appropriate implementation instructions documented including but not limited to?– Changes in process safety information being updated prior to

any change?

– Changes in operating procedures or practices being updated prior to change being put into service?

– Training completed prior to startup of the changed process?

– Maintenance routines developed prior to change being put in to service?

Management of Change and What Should Be Documented?

Are compliance audits conducted at least every 3-years?

Are audits conducted by at least one qualified person knowledgeable in the process?

Is a system established to promptly address findings and recommendations?

Is there a written schedule of when these actions are to be completed?

Have the recommendations been resolved in a timely manner?

Compliance Audits and What Should Be Documented?

Are the two most recent audits and audit responses available for review?

Did the audit adequately address previous Compliance Audit, PHA, and Independent Audit recommendations that have not been corrected or resolved?

Have actions been completed as soon as possible?

Are actions to be taken and their status communicated to employees?

Compliance Audits and What Should Be Documented? (Cont.)

Is each incident which resulted in, or could reasonably have resulted in a catastrophic release of a highly hazardous chemical (including near-misses and minor releases) investigated?– Are near-misses such as excursion of process operating

parameters, damaged piping, and corrosion investigated?– Are incident report findings and recommendations

promptly addressed, and resolved?– Did a contractor employee if the incident involved work

of a contractor participate in the investigation?– Was a system established to prevent a reoccurrence? – Are incidents reports retained for at least five years?

Incident Investigations and What Should Be Documented?

Does the program include all contractors who work on or adjacent to covered process(s)?

Have contract employers’ safety performance and programs been evaluated and documented?

Is the entrance, presence, and exit of contractors and contract employees controlled?

Have contract employees been periodically audited?– Been properly trained in and utilizing safe work practices– Know potential fire, explosion, or toxic release hazards

and applicable provisions of the plants emergency action/response plan

Contractor Safety Program and What Should Be Documented?

Contractor notified of fire, explosion, and release hazards at facility?

Contractor performance periodically evaluated? Contractor provided training for their employees? Contractor informs their employees of the hazards and

emergency response plan at the facility? Contractor advised facility of hazards presented by contract

work? Contractor advised facility of any hazards found? Contractor assured facility that employees followed its

safety rules?

Contractor Safety Program and What Should Be Documented?

CalARP/RMP Program Updates Within five years of its initial submission or most recent

update whichever is later. No later than three years after a newly regulated substance is

first listed by USEPA or OES. No later than the date on which a new regulated substance is

first present in an already covered process. No later than the date on which a regulated substance is first

present above a threshold quantity in a new process. Within 30 days of change in emergency contact information. Within 6 months of a reportable release.

CalARP/RMP Program Updates (Cont.)

Within 6 months of a change that requires a revised PHA or hazard review

Within 6 months of a change that requires a revised offsite consequence analysis.

Within 6 months of a change that alters the Program level that applies to any covered process.

Within 6 months of a change that alters the Program level that applies to any covered process.

What are some examples of changes that would require a revised Process Hazard Analysis or

Offsite Consequence Analysis?