EPA 550-F-99-011
June 1999
Addressing Year 2000 Issues in
Small and Medium-Sized Facilities
that Handle Chemicals
C P
DA
America n
Association
I%P%PJFm The
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NACD
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Addressing Year 2000 Issues in Small and Medium-Sized
Facilities that Handle Chemicals
Several chemical industry trade
associations1 representing
manufacturers, formulators,
distributors and retailers - in
partnership with the U.S. Chemical
Safety and Hazard Investigation
Board (CSB) and the U.S.
Environmental Protection Agency
(EPA) - are issuing this document as
part of an ongoing effort to assess and
address potential Y2K disruptions in
facility operations, particularly safety-
related control systems and
equipment. This document is offered
as a public service, and it is oriented
toward owners and operators of small
and medium-sized entities.
The statements in this document are
intended solely as guidelines. Site-
specific application of these guidelines
may vary depending on process
activities and unique facility
characteristics. Source material used
to develop this document was
produced by the United Kingdom's
Health and Safety Executive, the U.S.
CSB, EPA and SOCMA.
'Participating organizations: the American
Crop Protection Association, the Chemical
Manufacturers Association, the Chemical Producers
and Distributors Association, the Chemical Specialties
Manufacturers Association, the International Sanitary
Supply Association, the National Association of
Chemical Distributors, RISE (Responsible Industry
for a Sound Environment), and the Synthetic Organic
Chemical Manufacturers Association.
Introduction
Many systems and pieces of equipment used
to sustain process safety in chemical facilities
rely on the progression of dates from year to
year (for example, 1998 to 1999) to function
properly. This includes not only mainframe
and personal computers, but also any
equipment that contains a microchip such as
heating, lighting, safety, and
telecommunications systems. Many of these
systems "read" only the last two digits of the
year -1998 becomes "98," 1999
becomes "99." As a result, they may be
vulnerable to problems when the year 2000
(Y2K) begins, because they cannot recognize
that "00" means 2000, not 1900. This can
cause problems at any level of the system -
the clock, the Basic Input/Output System
(BIOS), the operating system, the application
software, or even the data itself.
Y2K failures external to your facility, such as
disruptions in electricity, water and
transportation, also may affect your facility's
operation.
This document describes a five-step process
for protecting the continuity of the process
safety systems in your facility from potential
Y2K problems. Additionally, the appendices
contain information to help you throughout
the process. This document includes the
following:
A checklist of typical in-plant systems
potentially vulnerable to Y2K disruptions
to help you determine where to focus
your efforts (Appendix A);
Guidelines for assessing the effect on
safety and deciding priorities (Appendix
B),
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Sources for obtaining Y2K resource
material (Appendix C);
A list of specific key dates that may
cause disruptions (Appendix D); and
A guide for communicating your
activities to your employees and your
community (Appendix E).
Step 1 - Assessment
The first step in the process is to conduct an
assessment to gather the information you
need to ensure that you can protect safety
systems and equipment. Begin by conducting
a thorough inventory to identify all systems,
computerized equipment, and devices with
embedded computer chips that may be
vulnerable to date-change failure. This
includes systems that import and/or export
data and should take into account systems
with which they exchange data. Appendix A
has a checklist that includes systems that
may have embedded chips or are susceptible
to a Y2K disruption. Also, Appendix B has
a checklist (Figure 2) you can use to help
you determine if a system or device is date-
dependent.
For each item, define the extent of work
necessary for Y2K compliance. In some
cases, this can be accomplished by referring
to user manuals and other documentation
provided with the equipment. In other cases,
it may involve contacting suppliers to obtain
needed information. Determine whether or
not the supplier believes the system, as
supplied, is "year 2000 compliant," - that is,
able to accommodate the transition to Y2K
and correctly continue date-based
calculations. It is important to obtain
satisfactory written assurance of compliance
from the supplier whenever possible. Such
assurance may be sufficient for some
systems that are being used as supplied and
that have a low safety risk.
For systems and equipment that are not Y2K
compliant, manufacturers or suppliers may
be able to provide assistance with making the
required changes. In some cases, however,
you may be unable to obtain this kind of
help. Hardware or software for some systems
and equipment may have been changed or
adapted for use in your facility, and these
changes could affect the ability of the system
to correctly make date changes and date-
based calculations. You may be using
equipment and software that no longer is
supported by a supplier or by the original
manufacturer. The supplier may be unable to
provide immediate assistance because of
current workload; ownership of the business
may have changed hands; or the
manufacturers or suppliers may have gone
out of business entirely. In these
circumstances, your options for dealing with
systems and equipment will depend on the
amount of information available, the other
resources you may have to make required
changes, and the potential difficulty of
replacing the system or piece of equipment in
question.
Once you have identified all safety-related
systems and equipment that may be
vulnerable to date-change failure and defined
the necessary work to make them Y2K
compliant, move on to assessing the effect of
each item on safety in your facility and
setting priorities for making necessary
corrections (see Appendix B).
Step 2 - Correction
The second step in the process is to use the
priorities set during the assessment part of
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the process, decide whether to repair, replace
and retire, or work around the vulnerable
safety-related systems and equipment that
you inventoried. Numerous diagnostic tools
are available to assist you with these
decisions. Many can be accessed on the
Internet. Appendix C contains information
about these and other resources.
In some cases, selecting a remedial approach
will be straightforward. For example,
installing a readily available software patch
might be all that is necessary to solve a
specific problem. These decisions can be
much more difficult, however, if repair or
replacement is expensive and the likelihood
of failure cannot be clearly assessed.
When selecting a remedial option, you may
want to employ an approach similar to that
used in prioritizing your inventory. The
exception would be adding cost of
remediation as an additional consideration.
This includes weighing the following:
The likelihood of failure
The potential impact of failure -
Will failure seriously hinder emergency
response? Will it hinder day-to-day
operations? Are redundant external
resources available for response in the
event of internal resource failure?
The cost of remedial action -Consider
both money and time required
Simple scoring methods (scales of 1 to 3, or
1 to 5) may be helpful in allocating limited
resources. High-consequence, high-
likelihood events deserve more attention and
resources than high-consequence, low-
likelihood events. This type of scoring can
help to determine whether the best option is
to repair, replace, or work around the
particular system or piece of equipment.
Repair - For many systems (databases,
custom computer applications), repair will
require upgrading system code as well as
data. For embedded Y2K problems, the
repair may be as simple as replacing a chip
set or circuit board. In some cases, however,
due to cost, the availability of parts or the
difficulty with accessing equipment, repair
may not be an option. In all cases, you
should mark the equipment for its Y2K
status.
Replace - Systems and equipment of only
marginal benefit should be retired if they are
not Y2K compliant. Exercise caution when
choosing to retire systems and equipment.
Plan to retire them well before December 31,
1999. The absence of certain systems or
equipment may demonstrate that they are
more important than your assessment
suggested. Taking them out of service early
leaves time to reverse that decision and take
whatever steps are possible to make them
Y2K compliant.
Step 3 - Testing/Validation
The third step in the process is to test the
ability of repaired and replacement systems,
including interactive systems, to function
using Y2K rollover conditions in the real
environment or in a realistic simulation. The
risks of system failure should be assessed
before undertaking tests. Testing schedules
should include allowances for dealing with
such failures and any resulting additional
remediation work and re-testing in order to
minimize the impact of any failure.
Conducting appropriate testing may require
close coordination between personnel from
different departments. Because of the
importance of meeting deadlines for
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correcting priority systems and equipment,
testing could cause production and other
operational delays, and staff from all levels
and disciplines already may be under
pressure to minimize downtime. Before you
test, alert local emergency officials, and
make sure your employees and community
are prepared for any possible failures.
Plan to conduct as much of the remediation
and testing as possible in a non-operating
environment. However, at some point, it will
be necessary to put each safety-related
system through a full check in its normal
operating environment. These checks should
be carefully controlled and monitored, and
independent verification of tests may be
appropriate in some cases.
To encourage Y2K testing, EPA has initiated
an enforcement policy designed to encourage
prompt testing of computer-related
equipment to ensure that environmental
compliance will not be impaired by the Y2K
computer problem. Following this policy,
EPA intends to waive 100 percent of civil
penalties and recommend against criminal
prosecution for environmental violations
caused by tests designed to identify and
eliminate the Y2K-related malfunctions.
This policy is limited and subject to certain
conditions. The Web site for the policy is
referenced in Appendix C.
Step 4 - Contingency Plan
The fourth step in the process is to develop
contingency plans to manage unforeseen
problems and emergencies involving each
safety-related system and equipment.
Among other things, these plans should
address how systems would be manually
operated or shut down until problems are
resolved. Development of contingency plans
should be undertaken simultaneously with
the correction part of this process.
Contingency plans should be revised, as
needed, based on the results of the
testing/validation part of the process. These
plans should include consideration of staff
requirements, particularly additional
personnel that may be needed on-site if
automated systems must be manually
operated.
For the contingency plan to be workable, the
people who are expected to implement the
contingency plan need to be involved in its
development. Efforts should begin with
reviewing existing disaster and business
continuity plans. Establish communications
with suppliers. A good plan must consider
Y2K failures of internal systems and with
suppliers, customers, service providers,
business partners and infrastructure service
providers. For example, some scenarios to
consider are the following:
Key Source Raw Material Provider
Cannot Deliver Materials
Transportation Disruptions
Equipment Failure
Telecommunications Disruptions
Power Failure
Water and Sewer Service Interruptions
Application Failure
You may need to determine which
employees need to be on-site on January 1,
2000. Your contingency plan also should
address failure of backup equipment and
systems that also could be affected by Y2K
problems. Consider the possibility that Y2K
disruptions could potentially prevent police,
fire and mutual aid assistance from arriving
promptly or at all. Coordinate with your local
emergency planning committee to ensure
emergency response procedures and
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resources are adequate to cover possible Y2K
consequences.
In some instances, additional staff training
may be necessary to ensure that all relevant
personnel are aware of the details of
contingency plans and be able to implement
them effectively. Once your Y2K
contingency plan is developed, your facility
needs to test it. When first tested, most plans
have a major flaw. Correct problems
identified through testing, to ensure that your
plan will be successful.
Other useful information regarding
contingency planning can be obtained from
the Chemicals Information Technology
Association Y2K Contingency Planning
Guidelines available on the Chemical
Manufacturers Association Web site (see
Appendix C).
Remember, by finding failures earlier in
1999, you are more likely to get the help
you need from vendors, local government,
and utilities than if you wait until crucial
dages (Appendix D) when demand for
support and help may be much greater.
an emergency response practice drill. See
Appendix E for suggestions about activities
for specific audiences and communications.
Step 5 - Communications
The fifth step in the process is to
communicate your facility's Y2K readiness
or your activities to prepare for the Y2K
event. Audiences for such information
include your facility's employees, suppliers,
vendors, customers, emergency response
authorities, local government, and
community organizations. Examples of this
outreach may include facility tours,
community meetings, Y2K readiness
disclosures, communication with the Local
Emergency Planning Committee (LEPC) or
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Appendix A
CHECKLIST OF SYSTEMS AND EQUIPMENT
POTENTIALLY VULNERABLE TO Y2K DISRUPTIONS
IN A HYPOTHETICAL CHEMICAL PLANT
Component
Worst-case Failure Effects
Embedded Microchips
Controllers
Weighers
Reactor
Charging
Temperature
Pressure
Cleaning
Stripper
Dryer
Centrifuge
Storage
Video Cameras
Still Cameras
Alarm Systems
Clocks
Elevators
Phones
Answering Machines
Heating/Ventilation/Air Conditioning
Fire Suppressions Systems
Inaccurate readings resulting in poor conversion
Wrong amounts reacting-poor conversion
Poor conversion-explosion
Poor conversion-explosion
Inaccurate timing-process interruption-release
Contamination of product
Water contamination of product
Poor separation
Overflow release
Failure to work
Failure to work
Failure to work
Show incorrect time
Failure to work
Failure to work
Failure to work
Failure to work
Failure to work
Software
Mainframe, network, desktop, &
communication computers
Office computers
Purchasing
Inventory
Distribution
Sales
Accounting
Personnel
Process Computers
Control
Transportation
Quality Control
Data-generated errors may result in inaccurate data or system
failures
No supplies
Excess supplies
Will issue incorrect orders
Will not be able to fill orders
Will incorrectly compute
Will not be correctly maintained
Explosion release
Buildup of stock
Poor quality
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Appendix A
CHECKLIST OF SYSTEMS AND EQUIPMENT
POTENTIALLY VULNERABLE TO Y2K DISRUPTIONS
IN A HYPOTHETICAL CHEMICAL PLANT
(Continued)
Component
Worst-case Failure Effects
Supply Chain
Utilities
Electricity
Water
Waste
Communications
Raw material suppliers
Primary feedstock
Initiator-catalyst
Service providers
Insurance
Hospitals
Vending
Customers
Process shutdown
Process shutdown
Waste buildup beyond capabilities
No communication
Process shutdown
Process shutdown
Extra expenses
No medical care
No food
No incoming funds
Video cameras
Security lights
Access
Parking
Building
Room
Fire
Intrusion
Warning
Process
Alarms
Failure to work
Failure to work
Failure to work
Failure to work
Failure to work
Failure to work
Failure to work
Failure to work
Failure to work
Note: The information given in this table is provided as an example o>nly. Checklists like this
should be developed on an individual, plant-specific basis using criteria and knowledge that are
unique to the plant. \
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Appendix B
ASSESSING SYSTEM VULNERABILITY
Assessing Relevance to Safety
Safety is the overriding consideration for assessing your control systems for possible year
2000 problems. This appendix provides a method for assessing whether or not your systems are
(a) safety and (b) date-dependent.
The following aspects should be considered when assessing the safety of a control system:
(a) Its contribution to safety, i.e., the importance of the system to maintaining safety
(which is a function of how control systems are arranged to provide the required
reduction in risk); and
(b) The consequences of its failure (the effects of a hazardous event).
The assessment sequence in Figure 1 (next page) is one of several methods for rating, on a
scale of 0-3 (3 being the highest level), the contribution of a particular control system to the safety
of your plant or process. Once you have determined the "contribution" of a system, estimate the
"consequences" of its failure using the following'rating scale:
(a) no consequences = 0
(b) minor accident/reversible injury = 1
(c) irreversible injury/loss of one life = 2
(d) loss of many lives = 3
Any system with a "consequence" rating of zero (0), should not be considered further. Assess the
importance of each remaining system to safety by adding its "contribution" and "consequence"
ratings. Its safety rating will be expressed on a scale of 2-6.
Assessing Date Dependency
Once the safety importance has been established, determine the date dependence of the
system. Your employees may be the best source for obtaining this information.
The date-dependence checklist in Figure 2 (page 3) is designed to assist you. Any YES
answer indicates that the system has a potential date dependence that will require further
investigation. Even if all answers recorded are NO, it is strongly recommended that you
confirm, through further investigation, that systems with a high safety importance are not
date-dependent.
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Some systems, particularly "embedded" systems, may have date dependence that is not
obvious. This "hidden" date dependence may affect other functions of the system. For example,
printer output usually is date-stamped, so the presence of a printing option may introduce date
dependency even if the printing option is not used.
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Figure 1: Y2K Assessment
Start
Consider the fellow ing
for each programmable system
Is there one or more
additional protection
system(s)for
ensuring safety?
Does the
programmable
system have
j control iinctions?
Does the programmable
system provide signals
or data to any safety-related
programmable system, or are
data from it used for scheduling
processes affecting safety.
e.g., proof testing or
rrsintenance, etc.?
Increased likelihood of
a demand on the non-
programmable back-up
system
Possible reduction in
level of availability
protection
: 2
Possibility of common
cause feilure resulting
in loss of both control
and protection systems
3
Ifes
Yes
Ho
Is there an additional
non-programmable
protection system?
Ho
__ __
Does the
programmable system
act as a protection
system or back-up to
a programmable-based
control system?
Ho
Failure Hi ill not
affect safety.
Cb/iiibuMon: 0
Do not take
consideration
Possibility of date
corruption or failure to
provide signals or data
: 2
Notes
1. This method is intended only as an aid to developing
the priority in which systems will be subjected to farther
investigation. It assumes that the risk reduction is spread
evenly across all the safety-related systems.
2. The exception to the assumption in #1 is a back-up system
that is capable of providing the entire risk reduction in its own right.
3. In cases where the actual risk reduction is known, a more
refined prioritization may be more appropriate.
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Figure 2: Date Dependence Checklist
Date Dependence
Does the system:
Display or print a date or time?
Implement a time control sequence?
Perform operations on a timed basis?
Produce time reports (hourly/daily/weekly)?
Calculate time-based totals, averages, rates, or trends?
Time stamp its data, or use time-stamped data?
Maintain historical records?
Display or print data by time sequence?
Generate alerts at predetermined intervals (such as when
set or maximum safe running time has been exceeded)?
Request the date when started/powered up?
Know which day of the week it is by date?
Send date and time information to other systems?
Connect to or contain a time transmission receiver?
Connect to a network providing access to the date?
Did a visiting service engineer set its date?
Require adjustment to allow for Daylight-saving Time?
Can a command or function allow the date to be set?
Navigate or position itself automatically (such as
receivers for Global Positioning System satellites)?
Remember user-defined data or settings even after being
turned off for a long period?
Need to be connected to a computer-based terminal for
maintenance?
Does system have a lithium battery?
Yes
No
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Appendix C
INFORMATION RESOURCES
The following are some resources to help you get started in addressing the potential Y2K problem in your
facility.
American Petroleum Institute
The site provides industry activities, company status reports, Y2K database, and technical links.
http://www.api.org/ecit/y2k/index.html
Case Study of One Chemical Manufacturer's Approach to Y2K Problem
http://www.dell.com/smallbiz/y2k/studies.htmlfmerisol
Chemical Manufacturers Association (CMA)
CMA has member Y2K survey results and Y2K Contingency Planning Guidelines and practices available. Scroll
down to Y2K category, http://www.cmahq.com/cmawebsite.nsf/pages/newsinfo
Electronic Information Clearing House on Chemical Emergencies.
This site is provided by the Organization for Economic Cooperation and Development (OECD) Working Group on
Chemical Accidents. It has Y2K tools and links to help industry including an OECD Manual, The Year 2000
Problem: Risks and Solutions. This site is aimed at small and medium-size enterprises. It includes a system for
routing inquiries and information about Y2K and hazardous installations to contacts in government and industry who
have had some experience in dealing with the problem, http://www.oecd.org/ehs/y2k/index.htm
Electronic Industries Alliance
This trade association representing the high-tech industry has a Web site that provides a knowledge base and
information center. It provides information sharing with its members, the government and the public.
http ://www.eia.org/y2k/default.htm
Embedded Industrial Control Systems and Y2K
http://www.compinfo.co.uk/y2k/scada.htm
Fire Alarm Systems and The Year 2000 Problem
This site provides reference system for assessing whether fire alarm equipment may have a Y2K compatibility
problem, http://www.fireline.com/firealarmsystems/y2000firealarmsystems.html
Health & Safety Executive (UK)
The British HSE Web site offers several reports on the Y2K problem: Health and Safety and the Y2K Problem-
Guidance on Year 2000 Issues As They Affect Safety-Related Control Systems and Contingency Planning for a Safe
Year 2000 and Year 2000 Risk Assessment: Will You Come Through the Millennium Safely?
http://www.open.gov.uk/hse/dst/2000indx.htm
Information Technology Association of America
The ITAA is a major trade association for the Y2000 software conversion. It's Year 2000 Home Page contains useful
resources, publications, and guides, http://www.itaa.org/year2000/index.htm
Institution of Electrical Engineers (U.K.)
IEE has a report addressing embedded chips. The Millennium Problem in Embedded Systems on its Web site.
http ://www.iee.org.uk/2000risk/
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Manufacturing Marketplace
Has a Year 2000 page with Q&As, news about manufacturing and Y2K, reports on Y2K issues such as contingency
planning, supply chain, etc., and Y2K/industry issues chat transcripts.
http://mvw.manufacturing.net/y2k/
Mary Kay O'Connor Process Safety Center
The site has links to compliance status of some manufacturers' control systems. Click on Y2K information.
http://process-safety.tamu.edu
Mitre Corporation
The site provides information on Y2K Certification, Compliance, Solutions, Testing and Evaluations, Contingency
Plans, Cost Estimation, Tools and Services, http://www.mitre.org/technology/y2k
National Fire Data Center
A basic system check that can help you determine if your organization's computer system is Y2K compliant is
available on this Web site, http://www.usfa.fema.gov/y2k/y2kcom.htm
National Institute of Standards and Technology (NIST)
The site has links to free software tests, self-help tools and product compliance status databases for use in
Y2Kassessment, testing, contingency planning and remediation. Information is provided for smaller manufacturers
through the Manufacturing Extension partnership, a nationwide network of centers providing technical and business
assistance to smaller manufacturers. Small manufacturing firms can call 1-800-MEP-4MFG.
http://www.nist.gov/y2k/
President's Council on Year 2000 Conversion
This site has a list of computer manufacturers' Y2K sites. http://www.Y2k.gov/java/product_compIiance.html
National Bulletin Board for Year2000
Provides tools for analysis, conversion, and testing for Y2k problems, http://it2000.com/solutions/index.html
PC Test Results for Y2K Problems
http://wwv.hqisec.army.mil/y2kweb/y2kresults.html
http://mvw.nim.com.au/year2000/ye02001.htnrfye02004
Synthetic Organic Chemical Manufacturers Association (SOCMA)
The 1999 Chemical Industry Y2K Readiness Survey, U.S. Senate testimony, and Y2K resources for the chemical
industry, including this guide, are available, http://www.socma.com/y2k.html
Tava Technologies
Plant Y2K: A White Paper that Discusses the Significance of the Effect of the Millennium, Bug (Y2K) on Process
Control, Factory Automation & Embedded Systems in Manufacturing Companies.
http://www.tavatech.com/files/TA VA3_0.pdf
U.S. Chemical Safety and Hazard Investigation Board (CSB)
The CSB has sponsored a conference and report on the Y2K problem and the potential of accidental chemical
releases. The site includes the full text of the report Year 2000 Issues; Technology Problems and Industrial Chemical
Safety as well as useful chemical safety Y2K links, http://www.chemsafety.gov/y2k
U.S. Environmental Protection Agency (EPA)
Provides information on EPA's efforts to address the Year 2000 problem for Environmental Y2K Sectors. Included
is Y2K guidance for wastewater systems (including a checklist of basic systems) and a flyer on waste management
and the Y2K problem, http://www.epa.gov/year2000/
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EPA's Y2K Testing Enforcement Policy
http://es.epa.gov/oeca/eptdd/ocy2k.html
EPA's Office of Solid Waste and Emergency Response Y2K information
http ://clu-in.org/y2k.htm
EPA's Chemical Emergency Preparedness and Prevention Office (CEPPO) has Chemical Emergency Y2K
alert and updated links, http://www.epa.gov/swercepp/y2k.htm
U.S. General Accounting OfficeGuide: Year 2000 Computing Crisis: Business Continuity and Contingency
Planning has general principles for use by businesses as well as government agencies.
http://www.gao.gov/special.pubs/bcpguide.pdf
U.S. National Institute of Occupational Safety and Health (N1OSH)NIOSH has Y2K case studies, a web forum,
vendor list, and an equipment manufacturer directory, http://www.cdc.gov/niosh/y2k/y2k-hmpg.html
U.S. Occupational Safety and Health Administration (OSHA)
The OSHA has resources and links for addressing the Y2K Impact on Safety and Health.
http ://www.osha-slc.go v/html/oshay2kpage.html
U.S. Small Business Administration (SBA)
This Web site offers information specific to helping small businesses address the Y2K problem. It provides a list of
questions to help identify date-sensitive equipment. SBA also has an extensive list of links to major corporations that
post their Y2K status online.
http://www.sba.gov/y2k/ Hotline: 1-800-U-ASK-SBA (1-800-827-5722)
Year 2000
The site has a list of Year 2000 vendors and consultants.
http ://www.year2000.com
Y2K Freeware and Shareware
http://www.aphis.usda.gov/y2k/wares.html
Year 2000 Embedded Systems Vendors, Associations, and Manufacturers
http://ourworld.compuserve.com/homepages/roleigh_martin/y2k_com.htm
All URL address were accurate and active as of 6/24/99.
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Appendix D
IMPORTANT DATES TO CHECK FOR Y2K DISRUPTIONS
Date
08/21/1999
09/09/1999
12/31/1999
01/01/2000
01/02/2000
01/03/2000
01/10/2000
02/28/2000
02/29/2000
02/30/2000
03/01/2000
10/10/2000
12/31/2000
01/01/2001
Reason fop Concern
Global Positioning system date rollover may affect military, transportation, Geographic
Information System, and Automatic Vehicle Locator.
Programmers use 9/9/99 as an end of file or infinity. (Ninth day of the ninth month of 99th
year).
End-of-year baseline (to be used in rollover scenario).
Date rollover.
First 24-hour look back period.
First work day.
First date requiring full use of seven digits.
Date prior to Leap Year (to be used in rollover scenarios).
Leap Year 2000.
Invalid date. Test to ensure that Leap Year logic is functioning.
First valid date after Leap Year.
First date requiring full use of eight digits.
Some systems using Julian dates may not recognize the 366th day of the Leap Year.
First date in 2001 . Check rollover functions.
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Appendix E
Communicating Your Facility's Y2K Activities
One of the most important ways that your facility can maintain a positive image in the eyes of your
local community, government, and customers is to communicate what your plant is doing, or has
done, to prepare for the Year 2000 transition. The following is a brief list of suggested audiences
and methods for communicating your Y2K activities:
Employees - Employee communication and involvement is an important component of a facility
communications program. It also is a good first step toward educating the local community about
your plant's Y2K safety procedures because most employees live in the local community. Some
suggested employee activities are the following:
Roundtables with the plant manager
Emergency planning training programs
In-house newsletters
Display Y2K readiness disclosure in
common areas
Reviewing Y2K contingency plans with
employees at staff meetings
Distribute Y2K information to
employees
Conduct lunch hour meetings
Include employees in development of
contingency plan
Local Community - Communicating that your facility is Y2K compliant, or working to become
Y2K compliant, is important for maintaining public trust. You can communicateY2K activities in
many ways, including the following suggestions:
Join local groups (Chamber of
Commerce, Local Emergency Planning
Committee (LEPC), City Public Works
Board, neighborhood associations, etc.)
One-on-one community meetings (door-
to-door announcements/meetings)
Conduct neighborhood meetings
Conduct facility tours
Visit local schools
Attend town meetings
Write public service announcements for
local media
Develop and disseminate plant informatio
sheets that include Y2K activities
Local Emergency Resvonders - Once you have developed a Y2K contingency plan, you should
distribute it, along with any other emergency response plans, to the following groups and/or
agencies:
Department of Environmental
Management
County sheriff's department
Local fire department/HAZMAT Team
LEPC
Local hospitals
Local police department
Regional or local civil defense
organization
Facility emergency team
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You also should coordinate meetings and events with the local fire department and/or HAZMAT
team to review all procedures and on site chemicals. Conducting a Y2K emergency response drill
with local emergency responders will test your contingency plan and prepare all those involved.
Customers and Vendors - Letting your customers and suppliers know that you are actively
preparing your facility for the Y2K conversion is an important business activity to ensure customer
confidence and vendor rapport. The following are ways communicate with this important group:
Put a "Y2K Compliant" stamp on
invoices and orders
Have sales force state Y2K readiness in
calls, meetings and customer service
activities
Distribute a Y2K disclosure statement
Place a "Y2K Compliant" line on
company advertisements
Telephone calls
The Y2K Disclosure Statement
Once your company is Y2K compliant, perhaps the most effective way to communicate this status
is to prepare a Y2K disclosure statement. This document must be titled as a "Y2K Disclosure
Statement" to avoid potential legal liability. A sample Y2K disclosure statement follows:
XYZ Chemicals
Y2K Disclosure Statement
Month/Date, 1999
Dear Customers and Suppliers:
As a trusted supplier of chemicals/services, this disclosure describes XYZ
Chemical's Y2K status to inform you of our preparedness as defined by the Year 2000
Information and Readiness Disclosure Act (15 USC 1 Note, PL 105-271). We have
evaluated all of our machinery and equipment and have determined that there do not
appear to be any issues that may affect our operations before, during or after the Year
2000. We have contacted and are actively dealing with all of our computer hardware and
software vendors to continue our commitment of quality and service beyond the Year
2000.
When appropriate and important, efforts are being (have been) made to determine
if other relevant third party vendors, suppliers and service providers beyond XYZ's
control, also are actively engaged in achieving Y2K compliance in their products, services
and general corporate viability, whichever may apply.
I hope this disclosure satisfies any concerns you have regarding XYZ Chemical's
Y2K readiness. If you have any questions, please call me at (000) 555-1234.
Sincerely,
John Doe
Title
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