EPA
                                                FACT  SHEET
                         MARCH  1993
                                                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 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  and.
Community Right-to-Know Act --' Title. Ill  of  the
Superfund Amendments and Reauthorization 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  objectives of the-  CAP'
program are 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  learn about,. 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
    '
feder'al    agencies,
                               industry   flroups,
as .wel  as  environmental  groups .and academia.
ThesetSfoinf e^foptspat&Sse^seot&term'm 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 arena.

PROGRAM GOALS           '

The CSA program  is  part  of this broad  initiative
and has been designed to accomplish  the following
chemical accident prevention goals:
 •  Visit facilities  handling hazardous substances
    to gather  information on and learn about safety
 ,   practices  and technologies;

 •  Heighten awareness of the need  for, and promote,
    chemical  safety   among  facilities   handling
    hazardous  substances, as well as in communities
    where chemicals are located;

 •  Build .cooperation among facilities,  EPA, and
    other authorized  parties by coordinating Joint
    audits;  and                    -   .   •

 •  Establish  a  database  for  the  assembly and
    distribution   of   chemical   process   safety
    management  information  obtained  from  the
    facility audits.

 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 104(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 under  the  CSA program,
 all facilities  that  will  .receivedan  audit should
 have  experienced   a  reieas^^pf,a,  hazardous
 substance,  pollutant,  or  contaminant,  of  there
 should be  reason  to believe-that there exists a
.threat of such a release.  The audits'are intended
 to be honconfrontational  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
 (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.

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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:
   Awareness  of  chemical  and process  hazards;
   Process  characteristics;
   Emergency  planning and preparedness;
   Hazard  evaluation   and   release   detection
   techniques;
   Operations and emergency response  training;
   Facility/corporate management structure;
   Preventive maintenance and inspection programs;
   and
•  Corrtnunity     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
recorasended  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
hive 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     enrollees.    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).

 FACILITY SELECTION

At present, there are no established procedures for
 selecting a facility  for  an audit.  Each EPA region
 has  flexibility  in identifying facilities. Options
 to consider, in selecting a facility include:

    Previous history of the  facility;
    SERC  and/or LEPC  referral;
    Proximity to sensitive population(s);     -
    Public  sensitivity;
    Regional accident  prevention initiatives;
    Opportunity for sharing  new technology;
    Population density; and
                               »n in*.
REPORT DISTRIBUTION

Standard distribution by  EPA regional offices  of
the audit report will be at a^minimum to:

•  SERC and LEPC in which the facility is  located;
•  Facility owner/operator and 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.

ACCOMPLISHMENTS                        -

During the first four years of the CSA program,  the
regions   have  conducted   audits   at  over   150
facilities in 46 states and Puerto  Rico.   EPA  has
analyzed the conclusions and recommendations listed
in the audit reports to identify trends within and
across  industries,  processes,  and  chemicals  to
assist  in the further development of  the CSA  .and
CAP   programs,   particularly  in   light   of   the
accidental release provisions of section 112 of
the  Clean Air Act.   At  the  same  time,  follow-up
activities  performed by  several  of  the  regional
offices   indicate    that   the  majority   of   the
recommendations to improve chemical process safety
practices,suggested  by the  audit teams  have been
implemented  or  are scheduled to be implemented at
audited  facilities.

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  SafetyAudit
 program,    contact   the    Chemical    Emergency
 Preparedness  Program  (CEPP)  office  in  your  EPA
 regional office.

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