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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