vvEPA
FACT SHEET JANUARY 1991
CHEMICAL SAFETY AUDIT PROGRAM
BACKGROUND
The Chemical Safety Audit (CSA) program has evolved
from the efforts of the U.S. Environmental
Protection Agency (EPA) under the the Chemical
Accident Prevention (CAP) program. The CAP program
emerged from concerns raised by the release of
methyl isocyanate at Bhopal, India, and of aldicarb
oxime at Institute, West Virginia. Awareness of
the critical threat to public safety posed by
similar incidents led to an emphasis on
preparedness and planning for response to chemical
accidents. Simultaneous with the development of
preparedness activities by EPA was the passage and
implementation of the Emergency Planning end
Community Right-to-Know Act -- Title III of the
Superfund Amendments and Reauthoriration Act (SARA)
by Congress in 1986. Because prevention is the
most effective form of preparedness, the CAP
program promotes an effort to enhance prevention
activities. The primary obejctives of the CAP
program is to identify the causes of accidental
releases of hazardous substances and the means to
prevent them from occurring, to promote industry
initiatives in these areas, and to share activities
with the community, industry, and other groups.
Many of the key concerns of the CAP program arise
from the SARA Title III section 305(b> study
entitled Review of Emergency Systems. As part of
the information gathering efforts to prepare this
study, EPA personnel conducted a number of facility
site visits to evaluate chemical process safety
management practices. The study covers
technologies, techniques, and practices for
preventing, detecting, and monitoring releases of
extremely hazardous substances, and for alerting
the public to such releases. One of the key
recommendations resulting from the study was the
continuation and expansion of the audit program.
As a follow-up to this national prevention study,
EPA has undertaken cooperative initiatives with
Federal agencies. States, industry groups,
professional organizations, and trade associations,
as well as environmental groups and academia.
These joint efforts will serve to determine and
implement a means to share information on release
prevention technology and practices, and to enhance
the state of practice in the chemical, process
safety erena.
PROGRAM GOALS
The CSA program is part of this broad initiative
and has been designed to accomplish the following
chemical accident prevention goals:
• Heighten awareness of the need for chemical
safety among chemical producers,
distributors, and users, as well as in
communities where chemicals are located;
• Visit facilities handling hazardous
substances to learn and understand
problematic and successful practices and
technologies for preventing and mitigating
releases;
• Build cooperation among authorized parties
by coordinating joint accidental release
investigations where appropriate; and
• Establish a national database for the
assembly and distribution of chemical
safety information obtained from facility
investigations and from other sources.
PROGRAM AUTHORITY
The Comprehensive, Environmental Response,
Compensation and Liability Act (CERCLA or
Superfund) was enacted December 11, 1980, and
amended by SARA on October 17, 1986. CERCLA
authorizes the federal government to respond where
there is a release or a substantial threat of a
release into the environment of any hazardous
substance, pollutant, or contaminant that may
present danger to the public health or welfare or
to the environment.
CERCLA Sections 104(b) and 1Q4(e), as amended by
SARA in '1986, provide authorities for entering a
facility and accessing information to conduct a
chemical safety audit by EPA. While CERCLA
provides authority for States to use statutory
authorities for entry and information gathering,
such authorities may only be accessed pursuant to a
contract or cooperative agreement with the federal
government. Since there is no such arrangement,
States, as well as local governments, must use
their own authorities for audit participation.
As a matter of EPA policy, if entering pursuant to
CERCLA, all facilities that will receive an audit
must have experienced a release of a hazardous
substance, pollutant, or contaminant, or there must
be "reason to believe" that there exists a threat
of such a release. The audits are intended to be
nonconfrontational and positive, such that
information on safety practices, techniques, and
technologies can be identified and shared between
EPA and the facility. Involvement in the CSA
program by Local Emergency Planning Committees
(LEPCs) and State Emergency Response Commissions
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(SERCs) formed under SARA Title III is encouraged
to enhance the.goals of both of these programs.
However, as stated above. State and local
government participation in the audit, itself, must
be performed under State and local authorities.
AUDIT SCOPE
The audit consists of interviews with facility
personnel, and on-site review of various aspects of
facility operations related to the prevention of
accidental chemical releases. Specific topics
addressed include:
• Process characteristics;
• Hazard evaluation and release detection
techniques;
• Training of operators and emergency
response personnel;
• Management structure (corporate and local);
• Preventive maintenance and' inspection
programs; and
• Community notification mechanisms and
techniques.
Observations and conclusions from audits are
detailed in a report prepared by the' audit team.
The report identifies and characterizes the
strengths of specific Chemical Accident Prevention
program areas to allow the elements of particularly
effective programs to be recognized. Copies of the
report are provided to the facility so that weak
and strong program areas may be recognized. The
audit is conducted following the Guidance Manual
for EPA Chemical Safety Audit Team Members, issued
by EPA Headquarters. This guidance contains
recommended actions, as well as mandatory
procedures that must be followed to ensure the
health and safety of program auditors and program
integrity. Each member of the audit team should
• have a copy of the manual, and a copy of the manual
is transmitted to the audited facility.
AUDIT TEAM COMPOSITION
An EPA audit team primarily consists of EPA
employees, and other designated representatives
including contractors 'and the American Association
of Retired Persons (AARP) enrol lees. Other
Federal, State, and local government personnel may
also be team members.
The audit team can vary in size, depending upon the
level of detail of the audit (e.g., number of
chemicals and/or processes under investigation;
national significance). At a minimum, however,
there must be two technical experts on a team.
FACILITY SELECTION
At present, there are no established procedures for
selecting • facility for an audit. Each EPA Region
has flexibility in identifying facilities. A
variety of options to use in selecting a facility
can be considered:
Previous history of the facility; •
SERC and/or LEPC referral. '.
Proximity to sensitive population(s);
Public sensitivity;
Opportunity for sharing new technology;
Population density; and
Concentration of industry in |the area.
Information sources to be used in determining some
of these options include Federal, State, and local
release notification reports and follow-up reports,
On-Scene Coordinator (OSC) reports, Regional
Response Centers, Accidental Release Information
Program (ARIP), Emergency Response Notification
System (ERNS), and other sources.
REPORT DISTRIBUTION
Standard distribution by Regional EPA offices of
the audit report will be at a minimum to:
• SERC and LEPC in which the facility is
located;
• Facility owner/operator;
« Facility CEO;
• EPA Headquarters; and
• Any other Federal, State, and local
agencies or departments that assisted in
conducting the audit.
Distribution is available to other EPA offices,
other Federal, State, and local agencies or
departments, and other private and public sector
organizations.
CSA PROGRAM BENEFITS
• Identification of effective, field-proven
chemical accident prevention technologies
and practices.
• Better understanding of the causes of
chemical releases.
• Greater awareness by facilities of chemical
safety and understanding of available
techniques, and specific suggestions for
improved programs. ;
• Identification of problem areas in industry
where more attention is needed.
• Cooperation and coordination of chemical
safety programs with other Federal and
State agencies through joint audits and
training.
For more information on the Chemical Safety Audit
program, contact the Chemical Emergency
Preparedness Program (CEPP) office in your Regional
EPA office.
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