THE CHEMICAL SAFETY AUDIT PROGRAM:
FY 1991 STATUS REPORT
Prepared for:
Chemical Emergency Preparedness and Prevention Office
U.S. Environmental Protection Agency
Washington, B.C.
Prepared by:
ICF Incorporated
November 1991
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THE CHEMICAL SAFETY AUDIT PROGRAM:
FY 1991 STATUS REPORT
Prepared fon
Chemical Emergency Preparedness and Prevention Office
U.S. Environmental Protection Agency
Washington, D.C.
Prepared by:
ICF Incorporated
November 1991
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TABLE OF CONTENTS
EXECUTIVE SUMMARY i
1.0 CHEMICAL SAFETY AUDIT PROGRAM: HISTORY AND FUTURE 1
1.1 CSA Program Background 1
1.2 CSA Database 4
1.3 CSA Training Workshop 5
1.4 State CSA Programs 6
1.5 Clean Air Act Amendments 7
2.0 OVERVIEW OF CSA PROGRAM RESULTS 9
2.1 Chemical Safety Audits and Reports Completed 9
2.2 Chemical Safety Audits by SIC Code 9
2.3 Chemical Safety Audits by Hazardous Substance 9
2.4 CSA Training Workshops 13
3.0 ANALYSIS OF CSA PROFILE RESULTS ' 17
3.1 Facility Background Information 17
3.2 Chemical Hazards 19
3.3 Process Information for Hazardous Chemicals 20
3.4 Chemical Accident Prevention t 29
3.5 Accidental Release/Incident Investigation 39
3.6 Facility Emergency Preparedness and Planning Activities 41
3.7 Community and Facility Emergency Response Planning Activities 49
3.8 Public Alert and Notification Procedures 52
4.0 STATUS OF CSA PROGRAM IMPLEMENTATION 55
4.1 Regional Implementation 55
4.2 Regional Activities 56
APPENDICES
Appendix A: Outline of the Chemical Safety Audit Protocol
Appendix B: List of Chemical Safety Audits
Appendix C: Hazardous Substances Examined in Chemical Safety Audits
Appendix D: Chemical Safety Audit Report Profiles
EXHIBITS
Exhibit 1: Status Summary of the Chemical Safety Audit Program
Exhibit 2: Summary of Chemical Safety Audits and Final Reports Completed by Region
Exhibit 3: Breakdown of Audited Facilities by SIC Code
Exhibit 4: Chemical Safety Audit Workshop Attendees by Affiliation, FY 89 through FY 91
Exhibit 5: Chemical Safety Audit Workshop Attendees by Affiliation
Exhibit 6: Chemical Safety Audit Workshops: Number of Persons Trained by EPA Region
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EXECUTIVE SUMMARY
This report provides a comprehensive overview of the status of the U.S. Environmental Protection
Agency's Chemical Safety Audit (CSA) program since its inception in FY 89, and a discussion of the
future direction of the program.
The CSA program evolved from the efforts of the U.S. Environmental Protection Agency (EPA)
under the Chemical Accident Prevention (CAP) program. 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 the results with the community,
industry, and other interested groups. The CSA program was established as part of this broad initiative.
The purpose of the CSA program is:
• To visit facilities handling hazardous substances to gather information on safety practices
and technologies;
• To heighten awareness of the need for, and promote, chemical safety among facilities
handling hazardous substances, as well as in communities where chemicals are located;
• To build cooperation among facilities, EPA, and other authorized parties-by conducting
joint audits; and
• To establish a national database for the assembly and distribution of chemical process
safety management information obtained from the facility audits.
The CSA program is not a compliance or regulatory program; however, EPA does have legal
authority for entering a facility and conducting a chemical safety audit under CERCLA sections 104(b) and
104(e), as amended by SARA. The auditing team consists of EPA employees and other designated
representatives, including contractors, part-time EPA employees from the American Association of Retired
Persons (AARP), and representatives of State Emergency Response Commissions (SERCs) and Local
Emergency Planning Committees (LEPCs). The audit consists of interviews with facility personnel and an
on-site review of various aspects of facility operations related to the prevention of accidental chemical
releases. Observations and conclusions from the audit are detailed in a report prepared by the audit team.
The audit report, which is available to the public, identifies and characterizes both problematic and
successful chemical process safety management practices, as well as technologies for preventing and
mitigating chemical releases.
This status report is intended to provide EPA headquarters and regional management with a
better understanding of the audit program purpose and goals, the type of information being generated and
its uses, and how the program is being implemented both in headquarters and the regions. The following
four topics are the focus of this report — program background, program results, analysis of audit report
information, and regional implementation status. In addition, this report addresses the impact that
implementation of the Clean Air Act Amendments of 1990 can be expected to have on the CSA program
and the future course of the program. The chapter on CSA report analysis is based upon standardized
profiles or summaries developed from the 80 final audit reports received by EPA headquarters as of
August 31, 1991; Appendix D contains 48 report profiles which were not included in the FY 1990 CSA
Status Report. This Executive Summary summarizes key findings of the program results, analysis, and
implementation status chapters.
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Program Results
The audit program results, further documented in Chapter 2, are based on the number of audits
conducted and reports completed in each region, along with a summary of the audits by the facility's
Standard Industrial Classification (SIC) code and by the hazardous substances examined during the audit.
An overview of training workshop participation is also included.
For FY 89 and FY 90, each region was assigned a target of conducting 4 audits per year under
EPA's tracking and evaluation system; in FY 91, the total target for all ten regions remained at forty, but
the regions were assigned individual targets based on the nature of their programs. The regions conducted
32 audits in FY 89, 39 audits in FY 90, and 52 audits during FY 91, for a total of 123 audits. As of
September 30, 1991, the regions had submitted 101 final audit reports to EPA headquarters, of which 80
were examined for this status report. Exhibits 1 and 2 in Chapter 2 provide a complete summary of the
number of audits and reports completed. Overall, there was a noticeable increase in the number of audits
conducted and audit reports completed in FY 91.
To realize the goals of the CSA program to collect and disseminate information on chemical
process safety issues and to improve program coordination, the Chemical Emergency Preparedness and
Prevention Office (CEPPO) is assembling a computerized database to provide EPA regions and
headquarters with information gathered from final chemical safety audit reports, organized in a uniform
format consistent with the CSA protocol. Although the database will not be directly available to the
public and industry, it will be used to develop guidance and technical assistance documents that will be
distributed to individuals and organizations involved in chemical accident prevention. Each regional CEPP
coordinator will be receiving a copy of the initial version of the database, containing information from at
least 40 CSA reports, on two or three diskettes that can then be downloaded to a hard disk drive.
CEPPO has designed a four-day chemical safety audit workshop that provides potential audit team
members with the training to conduct an audit. During FY 89 to FY 91, a total of 10 workshops were
conducted in Regions 3 through 10. A total of 336 individuals have attended the 10 workshops, including
137 individuals who attended the four workshops held in FY 91. One notable trend in the CSA program
has been increased state and local involvement, evidenced by the fact that the percentage of state and local
government attendance at the CSA workshops has grown substantially.
A related trend in the CSA program has been the interest of some states in developing their own
ability to conduct chemical safety audits, or to develop their own CSA program to support chemical
accident prevention initiatives at the state and local level. This interest has been fostered by the states'
emergency preparedness responsibilities under Title III and other related state legislation. The regional
CEPP offices have been actively supporting state and local involvement in the CSA program, including
developing state CSA programs. The most notable examples of this trend are in the states of Colorado
and Nevada.
Program Analysis
Chapter 3 characterizes the notable and problematic safety practices identified from the report
profiles developed from the 80 final audit reports. The analysis summarizes and evaluates the types of
observations and recommendations presented in the audit reports according to the CSA protocol, the
outline which provides the structure of the audits and the audit reports. The following general categories
of actions recommended for the audited facilities have been identified and will serve as a baseline for
further analysis of the CSA database as information from additional audits becomes available:
• Improvements in facility security measures to restrict access to areas containing hazardous
substances;
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Ill
• Improvement of labeling and color-coding for storage areas, storage containers, and
process and on-site transfer equipment;
• Improvements in safety procedures during shipping and receiving operations involving
hazardous substances;
• Expansion of both process and environmental monitoring systems;
• Increased support for chemical process safety programs by facility and corporate
management.
• Development of process-specific standard operating procedure manuals and distribution to
all appropriate employees;
• Increased availability of chemical hazard and process safety information to employees and
other on-site personnel;
• Establishment of formal preventive maintenance programs, including regular inspection
and testing of equipment and instruments;
• Development of facility procedures for conducting regular hazard evaluations of process
units where hazardous substances are present;
• Refinement or installation of secondary containment measures;
• Expansion of incident investigation policy to include all releases, spills, and near-miss
incidents;
• Refinement of facility contingency plans and establishment of schedules for regular
reviews and exercising of such plans;
• Increased availability of emergency equipment and emergency response training for
employees;
• Improvements of on-site emergency alarm and communication systems;
• Increased coordination with community planning activities; and
• Development of procedures for notifying the public during an emergency.
Regional Implementation Status
Chapter 4 addresses the status of the CSA program and program implementation issues that have
been identified by headquarters and the regions during FY 89 and FY 90. Program status is presented
based upon a review of the number of audits conducted and reports completed and the quality of report
contents.
In general, a review of the numbers of audits conducted from FY 89 through FY 91 indicates that
the regional offices have been attempting to commit resources for CSA program implementation. In the
past, problems have occurred that have prevented some regional offices from accomplishing the targeted
number of audits every year, such as the loss of trained personnel and canceled or postponed audits.
During FY 91, there has been an increase across all the regions in the number of audits conducted. In
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IV
addition, following up on a concern identified in the FY1990 Status Report, the time required to finalize
audit reports has been reduced significantly. As of September 30,1991, final reports had been submitted
for a significant majority of the audits conducted in FY 91, although a number of audit reports remain
outstanding from FY 89 and FY 90.
A related area of concern in the program has been the lack of consistency in audit report format
from region to region. Consistency across audit reports and timeliness of report preparation facilitate
analyzing conclusions and recommendations, identifying successful and problematic practices and
technologies, and sharing information. To address these concerns, CEPPO is considering revisions to the
CSA training materials, including developing a CSA report preparation module and advanced CSA
training courses. Headquarters will coordinate these activities and other program implementation issues
with the Regional Chemical Safety Audit Committee chaired by Region 6.
Most regional offices actively seek LEPC and SERC participation in audits, but several of the
regional offices have also been actively involved in the development of CSA expertise at the state and local
level. Region 4 held an EPA-sponsored CSA workshop in Charleston, SC, in FY 91 that was attended by
over 30 state and local officials, and plans to conduct its own chemical safety audit workshop in FY 92 at
the request of the North Carolina SERC. Region 8 is currently assisting the Colorado SERC in providing
a series of CSA workshops to LEPC members throughout the state. Region 9 is providing assistance to
Nevada in developing its own chemical safety audit program, which will include audits conducted under the
authority of a new state law on chemical accident prevention.
Conclusion
In summary, EPA views the CSA program as a cornerstone in the Chemical Accident Prevention
program and as a continuing means of focusing chemical accident prevention initiatives. Current benefits
from the CSA program include the following:
• CSA training workshops and audit participation provides EPA, SERCs, LEPCs, and other
federal agencies with a better understanding of chemical process safety management and
facility practices to prevent and mitigate chemical releases; and
• Jointly conducted audits and training are sponsoring cooperation and coordination on
chemical safety programs among federal, state, and local government agencies.
In the next few years, the influence of the Clean Air Act Amendments of 1990 and the
development of independent state chemical safety audit programs will further expand the potential
contribution of the CSA program to chemical accident prevention. Future activities under the CSA
program include:
• Dissemination of information from CSA reports as part of guidance to promote a greater
awareness among facilities and state and local officials of chemical process safety
management, and an understanding of effective prevention and preparedness techniques.
• Use of CSA training workshops to prepare EPA regional, as well as state and local
personnel for their responsibilities under the Clean Air Act, particularly in understanding
risk management programs and providing technical assistance to covered facilities; and
• Use of the CSA database to help EPA identify problematic and successful industry
practices related to preventing chemical accidents for the development of the "reasonable
regulations" under the Clean Air Act.
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1.0 CHEMICAL SAFETY AUDIT PROGRAM: HISTORY AND FUTURE
This report is intended to provide U.S. Environmental Protection Agency (EPA) headquarters and
regional management and other program offices with a better understanding of the Chemical Safety Audit
(CSA) program. The CSA program is part of a broad EPA initiative designed to accomplish four chemical
accident prevention goals:
• Visit facilities handling hazardous substances to learn and understand problematic and
successful practices and technologies for preventing and mitigating releases;
• Heighten awareness of the need for and promote chemical safety among chemical
producers, distributors, and users, as well as in communities where chemicals are located;
• Build cooperation among authorized parties by coordinating joint audits where
appropriate; and
• Establish a national database for the assembly and distribution of chemical safety
information obtained from facility audits and from other sources.
This report focuses on the information being generated by the CSA program and its current and
intended uses, as well as how the program is being implemented at headquarters and in the regional
offices. The remainder of this chapter describes the key features of the CSA program, including its history,
scope, and purpose, and other key CSA activities - developing the CSA report database, conducting
regional training workshops, and supporting state and local government involvement in the CSA program.
In addition, the last section of this chapter will discuss the potential influences of the Clean Air Act
Amendments of 1990 on the CSA program. Chapter 2 provides a statistical overview of the results of
CSA program activities and achievements. Chapter 3 analyzes the successful and problematic practices and
techniques identified in final CSA reports. To identify these industry trends, the analysis examined the 80
final CSA reports submitted to EPA's Chemical Emergency Preparedness and Prevention Office (CEPPO)
as of August 31, 1991. Finally, Chapter 4 provides an overview of regional activities in implementing the
CSA program.
Of the 123 audits conducted as of September 30, 1991, 80 final audit reports have been completed
by regional personnel (see Appendix B); the data from the 43 additional audits have not been considered
for the purposes of this analysis because the final audit reports were not completed by August 31, 1991.
To compile information for this report, the final audit reports have been summarized in standardized
profiles consistent with the CSA protocol. Copies of the latest profiles (those completed after the
publication of the FY1990 Status Report) are enclosed as Appendix D of this report. The profiles provide
a summary of audit observations, and include the conclusions and recommendations made by the audit
team. The profiles also contain other information, such as facility name, location, primary processes and
product(s); the hazardous substances examined for the audit; and the name, affiliation, role, and expertise
of each audit team member.
1.1 CSA Program Background
History
Following the 1984 release of methyl isocyanate in Bhopal, India, and subsequent incidents in the
United States, 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. EPA established the Chemical
Emergency Preparedness Program to help states and communities plan for chemical emergencies. Many of
the features of this voluntary program were incorporated into Title III of the Superfund Amendments and
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Reauthorization Act of 1986 (SARA Title III), which established a chemical emergency preparedness
infrastructure within each state, territory, and Indian land.
Recognizing accident prevention as the next step after instituting local emergency preparedness
efforts, EPA created the Chemical Accident Prevention (CAP) program in 1986. The CAP program seeks
to identify causes of accidental releases of hazardous substances and the means to prevent them from
occurring, to promote accident prevention in industry, and to share information with the community,
industry, and other groups (e.g., academia, professional organizations, trade associations, labor, and
environmental groups).
Many of these key concerns were identified in the Congressionally mandated SARA Title III
section 305(b) study, Review of Emergency Systems. This study reviewed technologies, techniques, and
practices for preventing, detecting, and monitoring releases of extremely hazardous substances, and for
alerting the public to such releases. As part of the information gathering efforts to prepare this study, the
CAP program conducted a number of audits of facilities to evaluate, first-hand, their chemical process
safety management practices. As one method of acquiring additional information and encouraging
awareness of accident prevention at facilities, the study recommended that EPA continue the program of
facility audits, thus inaugurating the CSA program.
Authority
While the CSA program is not a compliance or regulatory program, EPA does have legal
authorities for entering a facility and conducting a chemical safety audit. The primary authority for EPA
and its designated representatives to enter a facility and review its records and operations is provided by
CERCLA sections 104(b) and 104(e), as amended by SARA. The audits are intended to be non-
confrontational and positive, so that information on safety practices, techniques, and technologies can be
identified and shared between EPA and the facility. If serious problems are discovered during the audit,
however, EPA has a variety of legal authorities to use in response to them.
Audit Team
An EPA audit team consists primarily of EPA employees and other designated representatives,
including contractors and members of the American Association of Retired Persons (AARP). Other
federal, state, and local government personnel, particularly representatives of State Emergency Response
Commissions (SERCs) and Local Emergency Planning Committees (LEPCs) established under SARA
Title III, are encouraged to participate in audits as team members or as observers. The audit team can
vary in size depending on the scope of the audit and the expertise of individual team members. Although
states and local governments must use their own authorities for audit participation, the CSA program
encourages the involvement of LEPC and SERC members.
Audit Selection
In selecting a facility for a chemical safety audit, the EPA regional office may consider a number
of factors, including but not limited to the hazardous substances used, the facility's releases history, the
facility's proximity to a sensitive population or high population density, its accident prevention technology,
or the industry's concentration in the area. The regional office may want to review information sources
such as federal, state, and local release notification reports and follow-up reports; On-Scene Coordinator
(OSC) reports; Regional Response Centers; Accidental Release Information Program (ARIP) reports;
Emergency Response Notification System (ERNS); and other sources. Currently, most facilities selected
have been identified through ARIP reports.
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At present, there are no formal procedures an EPA regional office must follow when selecting a
facility for an audit, provided the following two important requirements are met:
• Under CERCLA, EPA may enter a facility only if a release of a CERCLA hazardous
substance, pollutant, or contaminant has occurred at the facility, or there is "reason to
believe" that a threat of such a release exists; and
• The Office of the Regional Counsel and the SERC must be consulted to identify any legal
actions currently being pursued or anticipated against the audited facility. Although not
compliance-oriented, a chemical safety audit conducted at a facility where legal action is
on-going or anticipated may interrupt or otherwise have an impact on the settlement
process. It is also suggested that other regional program offices be consulted.
EPA can, of course, enter a facility and conduct an audit at the invitation or with the voluntary consent of
the facility's management.
Audit Process
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;
• Emergency planning and preparedness activities;
• 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 the audits are detailed in a report prepared by the audit team.
The report identifies and characterizes the strengths and weaknesses of specific chemical accident
prevention program areas to allow the elements of particularly effective programs to be recognized and to
share information on problematic practices. Copies of the report are given to the facility and to its
corporate management so that weak and strong program areas may be recognized.
The audit is conducted in accordance with the Guidance Manual for EPA Chemical Safety Audit
Team Members, which contains mandatory procedures, as well as recommended actions 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 should be sent to the facility prior
to the audit. The guidance manual also contains an audit protocol (see Appendix A), a detailed outline
that directs the scope and content of the audit and provides a structure for preparing the audit report.
The protocol is designed to provide CSA teams with an organized and detailed format for conducting an
audit and preparing a comprehensive report. By following the protocol in preparing CSA reports, regional
staff will ensure continuity and consistency in report preparation.
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EPA sets individual targets for the number of audits (and audit reports) to be completed each year
by each region. A total of forty audits and audit reports is targeted annually, with each region responsible
for three to six audits. CEPPO uses the Strategic Targeted Activities for Results System, or STARS, to
track the regions' progress toward these goals, although STARS does not involve a review of the focus and
contents of the audit reports.
1.2 CSA Database
To realize the goals of the CSA program to collect and disseminate information on chemical
process safety issues and to improve program coordination, CEPPO is assembling a computerized database
to provide EPA regions and headquarters with information gathered from final chemical safety audit
reports, organized in a uniform format consistent with the CSA protocol. The information contained in
the database will be useful to EPA regions for a variety of purposes, such as identifying field experts and
comparing processes at different facilities for the same chemicals. Although the database will not be
directly available to the public and industry, it will be used to develop guidance and technical assistance
documents that will be distributed to individuals and organizations involved in chemical accident
prevention.
Through manipulation of the data, CEPPO will be able to use the database to assemble and
distribute information on chemical process safety management and chemical accident prevention issues.
The database will assist CEPPO in identifying successful and problematic techniques or practices used to
manage process safety at facilities handling hazardous substances. CEPPO will also be able to use the
database to assess the implementation of the CSA program in terms of number of audits conducted.
The CSA database will make it possible to quickly examine audit information about specific
facilities. For example, the database user could easily examine and compare audit observations and
recommendations for facilities that use similar chemicals, that manufacture similar products, or that are
located in the same region. Users can search the database for different types of information, such as
chemical names, SIC codes, processes, and process safety practice or technique, or a combination of fields.
For example, a user could search the database to identify the type of containment systems present at
chemical manufacturing facilities (SIC code 28) that use chlorine. EPA regional and headquarters
personnel may also use the database to:
• Identify field experts for auditing advice, or even possible participation in an audit;
• Identify facilities with similar processes or practices to support an ongoing audit;
• Compare successful or problematic safety practices among similar facilities;
• Identify previous recommendations for a similar process safety practice or technique;
• Compare safety equipment among similar facilities;
• Assemble information on a specific chemical safety process management practice; and
• Determine the number of audits conducted, the number of audit reports completed, and
the general areas of information contained in the reports.
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Each regional CEPP coordinator will be receiving a copy of the initial version of the database
containing information from at least 40 CSA reports, on two or three diskettes that can then be
downloaded to a hard disk drive. As additional chemical safety audit reports are completed, profiles will
be developed and entered into the database. The database will updated annually and new diskettes will be
provided to the regions.
1.3 CSA Training Workshop
In order to provide guidance on the procedural and technical aspects of conducting an audit and
to promote a better understanding of the objectives of the CSA program, EPA has designed the Chemical
Safety Audit program workshops. The workshops are presented to a combination of regional, AARP,
contractor, and state and local government personnel who are or will be involved in conducting chemical
safety audits. EPA is evaluating the need for a refresher workshop to discuss more advanced issues related
to conducting audits for personnel already familiar with the CSA program.
The topics addressed during the current four-day workshop include:
• EPA's Chemical Accident Prevention program;
• Chemical process safety management
/ • Guidance Manual for EPA Chemical Safety Audit Team Members;
• Chemical safety audit protocol;
• Chemical and process hazards;
• Hazards evaluation and application;
• Process safety systems and practices;
• . Incident investigation; and
• Conducting interviews.
A series of sequential group exercises are held during the workshop to provide participants with the
opportunity to apply theoretical knowledge in scenarios that simulate all phases of conducting a chemical
safety audit, including interviewing facility personnel.
Following a pilot workshop held in FT 88, EPA conducted three CSA workshops in both FY 89
and FY 90. In FY 91, four workshops were held throughout the country ~ San Diego, California;
Charleston, South Carolina; Denver, Colorado; and Chicago, Illinois. A total of 336 regional, AARP,
contractor, state and local government, and other federal agency personnel have attended these ten
workshops. For FY 92, a workshop is scheduled in the Washington, D.C., area for November 4-7, 1991;
future workshops are planned on an as-needed basis.
One significant trend in FY 91 has been the increased participation of state and local government
in the CSA training workshops. For example, the South Carolina SERC, in order to build state auditing
expertise, requested that Region 4 conduct a CSA training workshop in Charleston in 1991, rather than in
Atlanta where it was originally planned to be held. South Carolina sent over 30 state and local
government employees to this workshop, which had largest attendance of the FY 91 workshops.
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EPA Region 9 decided to follow the four-day San Diego CSA workshop (January 7-10, 1991) with
a one-day workshop on implementation issues related to California's Risk Management and Prevention
Program (RMPP). This was done as a result of the interest expressed by the California SERC and local
officials within California who wanted to discuss ways to better implement California's RMPP using the
knowledge gained from the CSA workshop. Like EPA's CSA program, California's RMPP is designed to
minimize or prevent accidental releases. Many workshop attendees believed the information from the
CSA workshop would be useful in reviewing facilities' risk management plans.
1.4 State CSA Programs
Another significant trend in the CSA program has been the interest of some states in developing
their ability to conduct chemical safety audits or to develop their own CSA program to support chemical
accident prevention initiatives at the state and local levels. This interest has been fostered by the states'
emergency preparedness responsibilities under Title HI and other related state legislation. Regional CEPP
offices have been actively supporting state and local involvement in the CSA program, including
developing state CSA programs. The most notable examples of this trend are in the states of Colorado
and Nevada.
Colorado
Colorado decided to develop its own CSA workshop to train potential state and local audit team
members and expand awareness of chemical process safety management issues and practices within the
state. Region 8, with support from CEPPO, assisted the Colorado SERC in designing, organizing, and
delivering a series of workshops to train LEPC members from across the state. The first workshop was
held in Pueblo on September 4-5, 1991, a second is scheduled for November 22-24, 1991, in Durango, and
additional workshops are planned. The workshops were specifically designed to provide Colorado's LEPCs
with the tools and knowledge to conduct effective audits, to understand the concepts of chemical process
safety management, and to enable them to participate in audits conducted by EPA.
Nevada
Nevada recently enacted a law (S.B. 641, June 15, 1991) governing the handling of hazardous
chemicals that is designed to prevent catastrophic releases from occurring. If a facility has a chemical
accident, near-miss, or poses a "catastrophic threat" to public health and safety, the governor can appoint a
committee to inspect the facility. The committee will review the facility's compliance with fire codes,
regulations, standards and safety orders of the division of occupational safety and health of the department
of industry, and any other state and federal regulations and standards; the effectiveness of these agencies in
the enforcement of their respective rules and regulations; and the adequacy of emergency response plans
adopted for the area in which the facility is located. The committee may also review and make
recommendations to the reviewing authority regarding permits to construct, substantially alter, or operate
a facility that has been the subject of the committee's review and evaluation.
EPA Region 9, with support from CEPPO, is providing assistance to Nevada in developing its own
chemical safety audit program, which will conduct audits under the authority of the new law. A Nevada
CSA manual, based on the Guidance Manual for EPA Chemical Safety Audit Team Members, is being
developed to serve as the guide for the program and will be supported by a series of training workshops to
be conducted later in FY 92.
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As more and more SERCs and LEPCs look for ways to better prepare for, or prevent, chemical
accidents, interest in the CSA program increases. In Chapter 4, more information is available on regional
efforts to promote the CSA programs at the state and local levels. The results are encouraging; as an
example, Region 4 conducted its own CSA workshop in Greensboro, North Carolina, at the request of the
SERC on October 22, 1991.
1.5 Clean Air Act Amendments
Probably the most important influence on the future of the CSA program is the passage of the
Clean Air Act (CAA) Amendments of 1990. The chemical accident prevention provisions, found in
section 112(r) of CAA, require EPA to develop several regulations, including a list of regulated substances,
and the requirements for development of reasonable regulations, including risk management plans and a
system for auditing these plans. In addition to the regulatory requirements, EPA is also required to
provide technical guidance in accordance with section 112(1)(3) of CAA to state and local agencies.
Section 112(r) requires the development of a list of at least 100 substances which are known to
cause or may be anticipated to cause death, injury, or serious adverse effects to human health or the
environment. The list will also include specific thresholds for each chemical.
Facilities handling a listed substance at or above the threshold will be required to prepare a risk
management plan (RMP) as well as comply with other applicable reasonable regulations. The RMP must
contain a hazards analysis, an accident prevention program, and an emergency response plan. EPA is also
required to develop an auditing system for reviewing the RMPs from regulated facilities. The auditing
responsibilities will be delegated to the state and local agencies who are authorized to implement section
Section 112(r)(7)(ii) requires EPA to publish reasonable regulations for the .prevention and
detection of accidental releases of regulated substances. The regulations shall, as appropriate, recognize
differences in size, operations, process, class, and categories of facilities and the voluntary action of
facilities to prevent and respond to accidental releases.
There are several important areas in which the CSA program can support the implementation of
CAA. The CSA training workshops have and will continue to play an important role by providing state
and local agencies with the expertise to conduct reviews of chemical process safety management practices.
The workshops can also provide state and local officials with a basis for understanding the use of the RMP
information to support local chemical preparedness and prevention efforts. For example, the activities of
the States of Nevada and Colorado in developing the tools and knowledge to conduct effective chemical
safety audits will enhance their states' ability to review RMPs under the CAA The information which has
been collected under the CSA program may also be used in the regulatory development phase of
implementing section 112(r). EPA may also use the CSA database as a means of identifying areas which
need to be addressed by reasonable regulations.
When discussing the future of the CSA program, it is necessary to look at the two parts of the
program structure -- providing training to state and local agencies on how to perform a chemical safety
audit and actually performing chemical safety audits at facilities. Although the role of the CSA program
in the implementation of the CAA is still being considered, EPA envisions several options for the
direction of the CSA program. First, the CSA program in its current non-regulatory format may continue
to operate as a technical guidance program. This guidance from the federal level could be provided in
accordance with section 112(1) (3) to state and local agencies. In addition, section 507 of CAA provides
assistance for small business that may have difficulty complying with the requirements of the Act. States
are, therefore, required to establish small business technical and environmental compliance assistance
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8
programs. In support of these programs, the CSA training workshops can be adapted to assist states and
local agencies in reviewing RMPs.
Second, the CSA program may also evolve into the federal compliance arm of the accidental
release provisions of CAA, with audits focusing only on the review of the RMPs and the facilities that are
subject to section 112(r). Finally, EPA may also combine these approaches, with the Chemical Safety
Audit program remaining a technical assistance tool for state and local agencies while adapting the audit
procedures to also establish an RMP auditing system.
While the relationship between the CSA program and the CAA has not been decided, the
requirements in various sections in the statute indicate that EPA is obligated to provide technical
assistance to states and local agencies, set up an auditing system for state and local agencies to evaluate
facilities and RMPs, and require facilities to modify their RMPs periodically. Section 112(1)(3) requires
EPA to provide technical assistance to states and local agencies.
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2.0 OVERVIEW OF CSA PROGRAM RESULTS
As of September 31,1991, EPA regional offices have conducted a total of 123 chemicals safety
audits. This chapter provides an overall summary of the achievements of the Chemical Safety Audit
program focusing on the following subjects:
• The number of chemical safety audits and audit reports completed in each fiscal year;
• A breakdown of the audited facilities by Standard Industrial Classification (SIC) code;
• The number of hazardous substances examined by the audit team and indicates those
substances that appeared most frequently in the audit reports; and
• The ten chemical safety audit training workshops conducted by the EPA for the regions.
2.1 Chemical Safety Audits and Reports Completed
As of September 30, 1991, a total of 101 audit reports for the 123 chemical safety audits
conducted have been finalized.
For FY 89 and FY 90, each EPA region was assigned a target of conducting four audits each year
under the Agency's tracking and evaluation system, Strategic Targeted Activities for Results System
(STARS). Beginning in FY 91, the STARS measure was expanded to include both the fulfillment of an
on-site facility visit and the subsequent audit report. In addition, specific STARS targets were set for each
region to better reflect regional priorities and capabilities.
Exhibit 1 provides totals for the number of chemical safety audits that the regional offices
conducted during each fiscal year. The number of reports completed by each regional office is also
included. The chart indicates that 32 chemical safety audits were completed in FY 89. In FY 90, an
additional 39 chemical safety audits were completed. Fifty-two chemical safety audits were completed in
FY 91. Exhibit 2 provides a summary of the chemical safety audits and final reports completed by region.
2.2 Chemical Safety Audits by SIC Code
The majority of the regional offices conducted their chemical safety audits at chemical
manufacturing facilities (SIC code 28). Exhibit 3 provides a breakdown by SIC code of the type of
facilities at which chemical safety audits were conducted; note that some facilities are categorized in more
than one SIC code, so that the total is more than 80. Forty-one of the 80 facilities at which chemical
safety audits were performed were chemical manufacturing facilities. Most of these were further classified
under SIC codes 281, 282, or 287. Seven audits involved facilities in the petroleum refining industry (SIC
code 29). Five of the audits involved facilities in the fabrication metal products category (SIC code 34)
and five other facilities were classified as electronics manufacturers (SIC code 36). The remaining facilities
audited were classified in a variety of other SIC codes.
2.3 Chemical Safety Audits by Hazardous Substance
A total of 157 hazardous substances were examined by audit team members at the 80 audited
facilities. Appendix C of this report provides a complete listing of the hazardous substances examined
during the audits. The five most commonly examined hazardous substances were sulfuric acid (38 audits),
chlorine (31), sodium hydroxide (27), hydrochloric acid (21), and ammonia (18). On average, four
hazardous substances were examined at each audited facility.
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Exhibit 1
Summary of Chemical Safety Audits and
Final Reports by Year and Region
FY 89 Through 91
Region
1
2
3
4
5
6
7
8
9
10
FY89
4
2
4
5
3
4
0
3
4
3
FY90
4
4
4
5
5
5
0
4
4
4
FY91
3
2
4
15
3
5
4
6
4
6
Total Audits
11
8
12
25
11
14
4
13
12
13
Number of Final Reports
11
5
11
19
4
14
3
13
11
10
Total 32 39 52 123 101
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Exhibit 2
Summary of Chemical Safety Audits and
Final Reports Completed by Region
FY 89 Through 91
25
20
15
10
0
5 6
EPA Regions
8
10
Number of Chemical
Safety Audits Completed
Number of Chemical Safety Audit
Final Reports Completed
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Exhibit 3
Breakdown of Audited Facilities
by SIC Code*
FY 89 Through 91
All Other SIC Codes
25 Audits,
30.5%
SIC Code 36:
5 Audits,
6.1%
SIC Code 28:
41 Audits,
50.0%
SIC Code 34:
5 Audits,
6.1%
SIC Code 29:
6 Audits,
7.3%
*This analysis is based on the 80 completed audit reports. Several of the
facilities are classified under more than one SIC Code. This is reflected in the Exhibit.
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2.4 CSA Training Workshops
As of the close of FY 91, CEPPO has conducted a total of 10 CSA workshops in eight of the ten
EPA regions. Although workshops were not held in Regions 1 and 2, representatives from these regions
did participate at workshops in neighboring regions. In FY 90 and 91, the host regions were co-sponsors
of the CSA workshops and provided valuable assistance in organizing and conducting the workshops. In
addition, hosting the workshop in cities near the locations of the regional office allowed other EPA
program offices, and other federal agencies to attend.
EPA conducted workshops in Atlanta, Dallas, and San Francisco in FY 89. In FY 90, workshops
were held in Philadelphia, Seattle, and Kansas City. In FY 91, workshops were conducted in Denver, San
Diego, Charleston, SC, and Chicago. Exhibit 4 provides a break-down of attendees by affiliation. A total
of 336 individuals have attended the ten workshops, including 112 regional personnel, 30 AARPs, 78
contractor personnel (primarily technical assistance team members), 83 state and local officials, 10
representatives from other federal agencies, and 23 others (e.g., EPA HQ personnel). Exhibit 5 compares
the percentage of attendees by affiliation between FY 89-FY 90 and FY 91; indicating the growing
involvement of state and local personnel in the CSA program.
Exhibit 6 is a breakdown by region of the number of audit team members who have received
training. State and local officials, HQ personnel, HQ contractors, and other federal agency representatives
are not included in these figures. The largest number of personnel attending a workshop were from
Region 4 (64), Region 3 (30), and Region 6 (25).
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Exhibit 4
Chemical Safety Audit Workshop Attendees
by Affiliation
FY 89 Through 91
Other Federal Agencies
Other* 3 o%
7.0%
AARP
9.0%
TAT/Other
Contractors
23.0%
EPA Regional
Personnel
33.0%
State & Local
Officials
25.0%
Other includes personnel from EPA HQ and EPA HQ contractors.
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Exhibit 5
Chemical Safety Audit Workshop Attendees
by Affiliation
FY 89 Through FY 90
TAT/Other
Contractors
22.7%
State & Local
Officials
20.2%
EPA Regional
Personnel
36.4%
Other
5.1%
AARP Other
11.6% Federal Agencies
4.0%
FY91
TAT/Other
Contractors
23.9%
State & Local
Officials
31.2%
EPA Regional
Personnel
29.0%
AARP
5.1%
Other
9.4%
Other
Federal Agencies
1.4%
* Other includes personnel from EPA HQ and EPA HQ contractors.
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Exhibit 6
Chemical Safety Audit Workshops
Number of Persons Trained by EPA Region
FY 89 through FY 91
70
60
50
40
30
20
10
0
456
EPA Regions
8
10
* Totals include EPA Regional personnel, AARPS, TAT and other contractor
personnel, but do not include state and local officials, EPA HQ personnel,
EPA HQ contractors, and other Federal agency offcials who received training.
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3.0 ANALYSIS OF CSA PROFILE RESULTS
This chapter highlights the major trends and issues from EPA's chemical safety audits, based on
report profiles developed from the 80 final CSA reports received by EPA headquarters as of August 31,
1991, as well as from conversations with EPA regional staff. The CSA protocol, which was designed to
serve as an outline for conducting audits and a structure for preparation of audit reports, provides the
format for this analysis. An outline of the CSA protocol can be found in Appendix A The following
eight major elements of the CSA protocol are examined in this section of the report:
• Facility background information;
• Chemical hazards;
• Process information for hazardous chemicals;
• Chemical accident prevention;
• Accidental release/incident investigation;
• Facility emergency preparedness and planning;
• Community and facility emergency response planning; and
• Public alert and notification procedures.
This chapter provides an overview of the principal trends identified in the conclusions and
recommendations relating to the eight CSA protocol elements listed above. CSA report conclusions
highlight chemical process safety practices observed at the facility; they reflect the audit team's perception
of the facility's understanding of and commitment to chemical process safety management, but are not
judgments of adequacy or inadequacy of the practices observed by the team. CSA report recommendations
address options that the facility may consider implementing to enhance facility knowledge of and practices
in chemical process safety management. These recommendations are based solely on areas observed
during the audit and are not required or mandatory actions to be taken by the facility.
Each section of this chapter will be introduced by an overview of the key features of the
corresponding protocol element, explaining the purpose for its inclusion in the CSA protocol and its
relevance to chemical process safety management. The introduction will be followed by a discussion of
unique and successful facility practices which support chemical process safety. The sections will conclude
with a discussion of trends in the concerns and recommendations in the CSA reports, and provide
examples for these issues.
3.1 Facility Background Information
This section of the report addresses the recommendations and conclusions made in the chemical
safety audit reports regarding general facility information. This section of the protocol is concerned with
the facility site and surrounding area, and includes the following:
• Comprehensive facility profile and history;
• Description of site topography and meteorological conditions;
• Transportation access;
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• Special and sensitive populations and environments in the surrounding area;
• Community demographics; and
• Identified vulnerable zones that provide information on the potential risks facility
activities pose to the community.
Many of the final audit reports contained conclusions involving facility background information.
The issues stressed in the conclusions fell into four general categories. Many of the conclusions focused
on either old or outdated equipment and/or the installation of safer equipment. Some of the conclusions
referred to the growth or decline of the facility in terms of size, staffing requirements, or productivity.
Other conclusions identified transportation concerns or topographical limitations which present a potential
risk to the vicinity around the plant during operations. The remainder of the conclusions focused on site
access. Below are a couple of examples of successful practices for this element of the protocol:
• A chemical manufacturing facility replaced windows with explosion proof glass designed to
drop out to minimize flying glass in the event of an explosion.
• A payload processing facility designed security measures based on DOD and ATF
explosive siting criteria. The facility's perimeter access is restricted by a chain link fence
topped with barbed wire. Access through the main entrance gate is controlled 24 hours a
day in order to regulate visitor traffic through conventional sign in procedures. An
additional badge exchange guard station limits access to the entire hazardous work area
during potentially risky operations.
Concerns about facility background information tended to focus on hazards posed by the
geographical and meteorological conditions at the facility's location and limited site access in emergency
situations. A number of audited facilities located in active seismic zones, or in areas where normal
meteorological conditions increase the risk of a chemical accident, lacked measures for reducing or
mitigating the threat posed by earthquakes, hurricanes, or volcanic activity. In addition, several reports
referred to a lack of sufficient access and evacuation routes, limiting entrance to facilities by response
crews in case of an emergency and departure from facilities for employees and at-risk populations
attempting to evacuate the immediate area. The following is an example of these concerns:
• Railroad tracks were frequently blocked at an agricultural products facility. Since there is
only one other vehicle access entry to the facility, it would be difficult for responders to
take action in the event of an emergency. The audit team recommended that the facility
insure that the railway entrance is kept clear.
Recommendations within the chemical audit reports relating to general background information
focused primarily on security issues and facility access. A few audit reports made recommendations based
on facility background information. These recommendations focused on improving security measures by
improving or expanding fencing along the perimeter of the facilities, having a third party conduct a security
evaluation of the plant, or modifying facility access procedures. For example, certain facilities needed
additional fencing, dikes, containments, and warning signs around hazardous areas such as sulfur pits or
ammonia storage tanks. General site access and gate control and guarded entry, as well as visitor safety
were issues addressed in a number of other reports.
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3.2 Chemical Hazards
This section of the report addresses the conclusions and recommendations made in the chemical
safety audit reports regarding chemical hazards, as well as how the facility identifies and understands the
risks posed by hazardous substances at the facility. This section also examines the methods by which the
facility communicates these hazards to its employees in the form of training, available information, policy,
and safety procedures. There are two parts to this element of the protocol:
• Overview of Hazards for Chemical(s) Being Audited -- covers the dangers posed by
hazardous chemicals that the audit team examined at the facility. This part does not
include detailed information, such as Material Data Safety Sheets (MSDSs), which may be
included as attachments to the report, if necessary.
• Facility Management of Chemical Hazard Data — encompasses the facility's policies and
practices regarding the hazards it perceives at the facility, the documentation of those
hazards, the availability of that documentation, and mechanisms for updating the
information and monitoring potential toxic effects on the work force.
The facility's understanding of its chemical hazards can indicate the extent to which it examines its
processes for potential accidents, and is important to the facility's emergency planning efforts. The
management of chemical hazard data, such as MSDSs, also demonstrates the facility's commitment to
employee safety and training; a facility that ensures that its employees are trained in chemical hazards has
demonstrated a significant dedication to safety. Examples of facilities that have successful practices in
chemical hazard information include the following:
• A metal plating facility converts all MSDSs received from manufacturers into a standard
format; this makes it much easier for employees to understand. They are updated
annually or when new information is received.
• A pesticide plant maintains an thorough hazard review report for every chemical on the
premises. Each report includes a description of the equipment used in the process,
associated chemical hazards, a decision tree path, moderate hazards, minor hazards,
investigations and findings, equipment design parameters, instrument control, SOPs,
possible malfunctions, and an electrical check list.
• A circuit board producer requires all employees to pass an English exam to ensure that
personnel can read and understand operation procedures and MSDSs.
• A semiconductor plant maintains a computerized employee health tracking system that
logs health surveillance, risk, environmental, accident, and injury data for analysis and
statistical review.
The most significant issues in chemical hazard recommendations are the facility's awareness of
hazards associated with chemicals used, stored, and produced at the facility; the availability of information
on those hazards - usually in the form of MSDSs — to all plant employees; updating of existing MSDSs;
employee training about chemical hazards; and health monitoring and medical surveillance programs.
Several audit reports commented on facility practices concerning chemical hazards. The following are five
examples illustrative of the issues:
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• At a lighting equipment plant, although MSDSs exist in certain areas, employees who do
not understand English are not able to read or comprehend the chemical information.
Because most of the employees are Spanish-speaking, the MSDSs should be translated
into Spanish.
• A tool manufacturing facility did not display chemical hazard information in risk areas.
The plant should post required protective clothing requirements for handling hazardous
chemicals at the storage and handling locations.
• Personnel at a chemical storage facility were not aware of the potential for fire conditions
to create large quantities of toxic gas such as hydrogen chloride which could affect workers
and off-site personnel.
• An audit report from a wood preserving plant recommended that the facility reinstate its
medical surveillance program, including on-going health monitoring and urinalysis testing,
in order to expand the cross-section of workers in an industrial hygiene study and
statistically increase the validity of the results.
• At a chemical facility, the audit team noted that employees drank coffee, ate, and smoked
in areas where those activities presented a hazard to operations. The facility should
establish eating, drinking, and smoking practices for process, maintenance, and control
areas.
3.3 Process Information for Hazardous Chemicals
The sixth element of the CSA protocol is process information for hazardous chemicals, which
reviews operational and storage procedures within the facility. There are three sub-elements:
• Storage and Handling — which examines facility storage systems, shipping and receiving,
and material transfer involving hazardous substances;
• Process Description — which evaluates the process steps, equipment, system backups, and
monitoring procedures; and
• Process Hazards - which determines significant process hazards at the facility.
Storage and Handling
This section addresses facility storage, shipping and receiving, and on- site transfer involving
hazardous substances. Examining storage and handling procedures and process operations can reveal a
facility's overall safety practices and its comprehension of process hazards. Chemical safety audits examine
storage and handling practices in order to identify facility awareness of potential hazards, as well as to
recommend alternative practices to those facilities which need storage and handling improvement.
Storage Systems
Examining storage systems is an essential part of reviewing facility operations. Chemical safety
audits review storage methods to assess the safety and efficiency of storage procedures. Capacity, location,
identification, maintenance and housekeeping are examined to better understand routine storage
procedures and operations. Many of the chemical safety audit reports noted exceptional storage
procedures at the audited facilities. The following are some examples of successful storage methods and
procedures:
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• At a lighting equipment manufacturing facility, all chemicals are segregated into two
storage areas: the caustic/cyanide storage area and the acid storage area. The two areas
have wire screen walls, dikes, and are kept locked.
• At an alkalies and chlorine facility, cell line capacity contains provisions for cell downtime
for anode replacement and normal maintenance. Spare pumps and valves for all critical
products and utilities are available. There are also back-up process and storage tanks on
site to allow for maintenance.
• At an agricultural chemicals plant, surface runoff paths have been identified and holding
ponds are in place to control surface runoff from a spill or fire incident. One tank farm is
adjacent to an emergency runoff pit, to which all materials can be diverted in the event of
an emergency.
• At a facility manufacturing agricultural chemicals, storage of methyl isocynate (MIC) is
minimized to decrease the chances of a disastrous release. In addition, the above ground
MIC storage tank is covered by a steel cable mat to prevent projectiles from damaging
these tanks in the event of another nearby explosion.
• At a facility that manufactures bromide-based products, the reduction in size of bromine
storage tanks has minimized the risk of a large release; the maximum quantity that could
be released is lessened and consequently more easily contained.
• At an industrial organic chemicals facility, toluenediamine is stored in an insulated, steam
heated tank under nitrogen to prevent moisture from contaminating the chemical.
• At a fertilizer manufacturing facility, ammonia storage tanks are covered with glass foam
insulation to maintain the ammonia in liquid form. Vapors are collected, liquified, and
recycled back into the storage tanks.
• At a chemical manufacturing facility, hydrogen cyanide storage capacity has been reduced
from over 100,000 gallons to a present capacity of 60,000 gallons, divided equally among
two storage tanks. When this new system was constructed, the facility installed new
piping, pumps, and tank monitoring instrumentation.
• A bleach manufacturing facility has instituted a waste minimization program where
products which do not meet specification are recycled back into the process. This
eliminates storage and disposal of refuse material.
EPA audit teams expressed a variety of concerns regarding storage practices and procedures.
Many facilities should consider monitoring tanks for corrosion and maintenance needs on a scheduled
basis. Observations and corrective action should be recorded in a log book. Common concerns included
improper placement of storage area drains, storage tank exposure to the elements, and lack of pressure
valve release units in storage tanks. Poor identification of hazardous materials, unrecorded quantities of
chemical ingredients and product yields, leaky storage tanks, and grouping of incompatible materials are
some other examples of improper chemical safety procedures. Such operations unnecessarily contribute to
the risk of an accidental release. Many of these procedures can be easily corrected to lessen this threat of
hazards. Some of the more typical concerns are as follows:
• At a petroleum products storage terminal and asphalt refinery, various combustible
materials and ignition sources were found within the main tank farm. In addition, the
storage tanks in the terminal and the refinery were constructed before the current NFPA
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guidelines were established, so many of the tanks were spaced closer than these guidelines
recommended. The audit team believes these factors increase the probability or severity
of a fire spreading throughout the tank farm. The facility should segregate combustible
materials and should reduce the number of containers stored in any one location within
the warehouse.
A sodium hydroxide tank was located near sulfuric acid tanks at a facility that produces
electricity. The tanks should be relocated because of the possibility of tank rupture which
could occur if the acid and the base are inadvertently mixed.
At a petroleum refining facility, process flow lines, pipelines, and equipment are not
routinely labeled and numerous pipe lines are not insulated. Although some flow
directions are indicated, the lack of uniformity could cause confusion during operations,
maintenance or an emergency. These current housekeeping practices create safety hazards
and should be reevaluated. At the same petroleum facility, contents of the storage tanks
are not apparent by labeling. Process flow lines, storage tanks, and equipment should
receive permanent labeling.
At a facility that produces liquid chlorine and caustic soda, the sulfuric acid storage tank
is elevated and could cause an uncontrollable hazardous release should a rupture occur.
The facility should consider grounding the tank of sulfuric acid.
At a facility that specializes in the production of metal products, storage tanks were old,
corroded, deteriorated and are not coated. The foundations and supports of the tanks are
deteriorated and the tank bottoms cannot be inspected. The storage area for flammable
chemicals should be upgraded and moved to an approved area of the plant.
At a polymer manufacturing facility, at least one operating area had small quantities of
flammables, acids, and caustic stored next to each other on the floor. Incompatible
materials such as these should be separated by greater distances.
At a facility that produces cyclic organic crudes and intermediates, and organic dyes and
pigments, ground cables were not used to guard against static buildup and lightning rods
are not present to dissipate lightning strikes. Ground cables and lighting rods should be
placed on and near all of its storage tanks to prevent a release due to lightning.
At a facility which produces monochloroiodine, chlorine cylinders contained chemicals
other than chlorine and had no feature to prevent them from falling over. Since the caps
of these cylinders are removed, the cylinders should be chained or otherwise prevented
from tipping.
At a facility that produces intermediates for Pharmaceuticals, dyestuff, and pesticides, large
numbers of one-ton phosgene and chlorine gas storage cylinders are stored in an open
storage area and are manually handled with hoists and transport equipment. These
cylinders should be stored in a dry area away from excess heat or danger of fire and
protected from accumulation of snow and ice.
At a jewelry manufacturing facility, there was no capability for detecting wind direction
near ammonia storage tanks. The facility should install wind socks in order to detect wind
patterns.
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• At a facility that produces surfactant polyol, warehouse personnel were not fully aware of
what chemicals were in storage, or the location of these materials in the warehouse. A
diagram of warehoused materials was not maintained for identifying even the location and
quantity of any hazardous and/or extremely hazardous substances. A diagram should be
developed and maintained showing the location of any hazardous or extremely hazardous
substances and their amounts.
Shipping and Receiving
Methods of loading and unloading materials indicate a level of facility responsibility for handling
process hazards. This sub-section addresses shipping and receiving procedures for hazardous substances
examined during the audit, including methods of transportation, responsible personnel, and training
programs. Schedules and quantities of shipments are noted but depend on site-specific information such
as the capacity of storage units, the size of the facility, and the quantities of chemicals needed for
processing. Most shipping and receiving is handled by truck, rail, and sometimes barge. Hazardous
materials are usually loaded into railroad tank cars by facility employees and into tanker trucks by truck
drivers. Hazardous liquids and gases are often transported to and from the facility by pipeline. The
following examples of notable success in shipping and receiving practices were mentioned in the audit
reports:
• At a facility producing chemicals for use in paper products manufacturing, formal transfer
procedures are followed in the transfer of all liquid chemicals entering the facility. The
material is verified by shipping papers. The proper valve hook up is checked and the
receiving tank is checked for sufficient volume. The connecting valve is unlocked by a
supervisor and the transfer is documented.
• At an agricultural products storage facility, a written standard operating procedure for
shipping and receiving covers accurate inventory, receiver accountability, and
responsibilities during the unloading process.
• At a facility manufacturing bromide-based products, facility shipping stations are equipped
with scrubbers to control bromine vapor from escaping into the atmosphere.
Concerns about a number of different shipping and receiving practices were addressed in the audit
reports. Location in proximity to sensitive areas, security, recording schedules, quantities of shipments,
designated responsibility, and storage in receiving areas were all areas of concern. Many of the facilities
need to improve their control of shipping and receiving to prevent releases during material transfer
operations. Shipping and receiving are not always supervised by trained and experienced personnel and
loading and unloading areas are not provided with appropriate hazard information. Some of the more
specific areas of concern are as follows:
• At a facility that produces industrial organic chemicals, the hazardous materials rail car
unloading area is in close proximity to a river and the rail cars are not always secured
prior to a materials transfer operation. A diked pad with a collection sump should be
installed to minimize the impact from a catastrophic rail car failure or release during bulk
unloading operations. Wheel chocks must be used to prevent movement of hazardous
materials rail cars during unloading operations.
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• At a copper and sulfuric acid production facility, nighttime operations are potentially
hazardous because of poor visibility, access, and communications. Loading of sulfuric acid
into tanker trucks is accomplished by the truck drivers, who may or may not have had
specialized training in the handling of the chemical. Acid loading should be limited to
daylight hours and an operator should be required to supervise loading procedures.
• At a facility that produces circuit boards, sections of the shipping and receiving area are
used for storage of empty drums, waste, and containers of chemicals waiting for off-site
recycling. There is no inventory or management system for this area; some drums were
mislabeled and drums of different classifications were mixed together. These drums
should be clearly dated and labeled, and should be shipped off-site for treatment, storage,
or disposal within 90 days.
• At an electric utility, the only way for anyone to know when unloading is completed is to
listen for the sound of air venting from the relief valves on the truck tank. An audible
alarm system should be installed to alert personnel when tanker unloading is completed.
• At a sanitary services facility, both cyanide and acid solutions are present in the truck bay,
and hoses used to unload these materials from the trucks into storage tanks are
interchanged. It was recommended that specific hoses be dedicated for each activity.
Material Transfer
Methods and procedures for transferring hazardous materials throughout a facility can significantly
influence its safety practices and its potential for chemical accidents. The chemical safety audit evaluated
on-site material transfers by determining the status of pipes, valves, pumps, valves, color-coding and
labeling. Methods of transferring materials from storage areas to different stages of chemical processing
were reviewed. Initial transfer occurs as hazardous materials are moved from receiving stations to storage
and process areas. Cylinders and drums of dry hazardous materials are often transferred by forklift or
dolly. Hazardous liquids and gases are often pumped from trucks and rail cars by hoses that lead to the
storage systems. A few of the more notable findings are:
• At a plastics facility, buildings in which phosgene or chlorine are used are under negative
pressure. Air from these buildings and nitrogen used in the piping system are passed
through scrubbers. Chlorine pipes are painted green, and phosgene pipes are painted red
for identification. In high hazard areas at the facility, pipes are double-piped, space
between pipe walls is swept with nitrogen, and the nitrogen is analyzed for contaminants.
• A chemical manufacturer has replaced jacketed pipes with stainless steel pipes containing
heat traces to improve leak detection, and uses easily identifiable markings and placards
on buildings, tanks, and pipes.
• At a petroleum refinery, all critical pumps have steam-driven backup pumps available for
use if the primary pump goes down or the electricity fails.
The condition of equipment, coding and material of pipes, and housing of transfer system affect
the safety of material transfer operations. Many facilities should review routing, supports, materials, and
connections to tanks and equipment. In addition, deficiencies in coding and identification of hazardous
materials pipes, tanks, and vessels were identified at many of the audited facilities. Some of the specific
concerns were as follows:
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• A petroleum products facility has a checklist, but no formal written procedures to be used
during transfer operations. The facility should also document transfer operations.
• At a petroleum products facility, piping systems within the process units and between
storage areas are not protected from potential damage by trucks, especially the crude oil
pipelines which run along major refinery thoroughfares. The facility should install a rail
guard or florescent tape to protect piping near the vehicle loading and unloading area.
• At a facility that produces bleach, piping was made out of mild steel schedule 40, which
may be corroded by chlorine byproducts. This facility should assess the compatibility of
construction materials and process conditions.
• The unloading nozzles for the sulfuric acid tank is identical to that of sodium hydroxide at
a facility that manufactures printed circuit boards. The proximity is a major hazard
because the chemicals could be unloaded into the wrong tanks. The piping and the filter
at the storage tank is inadequately supported and fastened. The ground level location of
the piping and wiring is a hazard because personnel could trip. Measures should be taken
to prevent tripping over wire and unloading into incorrect tanks.
• A facility that produces chlorine and caustic soda provides a site plan and paints some
tanks and piping yellow. The facility should consider developing a documented color-code
system for all piping carrying hazardous materials. This would be very helpful to local
emergency personnel responding to an incident at the facility.
Process Description
A key element in understanding the causes of past and possible future chemical releases is an
investigation of facility process steps and procedures. Without a critical investigation of the chemical
processes and the mechanisms for controlling these processes, it is impossible to effectively identify the
source of potential chemical releases. Chemical safety audits examine several aspects of facility chemical
processes, including:
• Process steps which could be improved to decrease the chance of a release;
• Process equipment which may be substandard or which could be upgraded to improve
efficiency and reduce the likelihood of system failure;
• Systems with or in need of backups or automatic shutdowns;
• Methods of monitoring process parameters; and
• Devices for environmental monitoring.
Overview of Processing Steps and Operating Procedures
An examination of the basic process steps and operating procedures can reveal critical procedures
and parameters, deviations from which could lead to unwanted releases. This sub-section of the audit
addresses processing steps and operating procedures for the hazardous substances examined during the
audit. A common problem among facilities seemed to be the availability of up-to-date process and
instrumentation diagrams. It was recommended that these facilities update and distribute these diagrams
to assist training, maintenance, and safety efforts. Other recommendations focused on process
modifications and standardization of equipment. The following are illustrative recommendations:
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• At a payload processing facility, changes in recent years in payload processing operations,
prompted the audit team to recommend that the facility consider evaluating the feasibility
and safety of modifying the sequence of processing operations dealing with this process to
minimize the possibility of releases.
• The audit team suggested that a refinery should update process schematics and diagrams
and convert them to computer drawing files, because the diagrams were last reviewed in
1951 and did not indicate the extensive modifications that have been made in the
intervening years.
• At an ammonia manufacturing facility, the audit team suggested that the pill tower should
be replaced with another process that emits less paniculate and vapor, or they should
install appropriate emission control devices.
Process Equipment
Process equipment is another important aspect of chemical processes which should be examined.
In the audit program, this area covers capacity and design conditions, flow rates, construction material, and
chemical use rates. In the audit reports, most comments were simply proposals for replacing equipment,
like valves and flanges, in order to make the process more resistant to upset. Some specific concerns and
recommendations were:
• At a plating facility, an audit team suggested that the facility should study the possibility
of eliminating all but the most vital flange systems in the hydrogen cyanide process and
replacing the jointed flanges with welded seams.
• At a food manufacturing facility, an audit team suggested that, to prevent corrosive
failure, threaded drain couplings in the sulfuric acid storage tank should be replaced with
flanged connections, because they are less susceptible to corrosion.
• In light of an aluminum release incident, the audit team suggested that a sulfuric acid
producer should continue their replacement of vinyl-shelled pools with steel tanks.
Some recent audits, however, seem to be focusing on process rate modifications. Even the best
equipment is prone to upset when operated at rates beyond design specifications. Although this may be
obvious, many processes are modified over time, making it difficult to determine original designed flow
rates. One specific recommendation appears below:
• The audit team suggested that an ammonia production facility should review historical
records to see if a correlation between process throughput and frequency or magnitude of
ammonia releases exists. If a correlation exist, they should either reduce throughput to
the point that no statistically significant increase in frequency or magnitude of accidental
ammonia releases is anticipated, or comprehensively re-evaluate the process design for
compatibility with the desired rate, and modify or replace unit processes as required. If
the correlation cannot be identified, they should reduce throughput to design levels.
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Backups and Redundancies
An indication of a facility's ability to handle process upsets and system shocks is the existence of
system backups and redundancies. Backups, automatic shutdowns, and the ability to detect and
compensate for disabled control equipment are important methods for preventing accidental releases. The
audits contained many examples of facilities with effective backups and redundant equipment. Especially
in recent audits, comments focussed on positive aspects of facility backups. The following are some
examples:
• At a chemical facility, standby equipment is rotated once a week, ensuring that the backup
equipment is well maintained and ready for emergency use.
• At a chemical manufacturer, computer controlled processes are easily changed to manual
operation for emergency shutdown. Also at this facility, reactors that have critical
isotherms can be quenched by redundant techniques. Such techniques include gravity-fed .
water baths to cool the reactor in the event of a temperature excursion, or nitrogen purge
systems used to provide backup reactor agitation in the event of a mixer failure.
• A plastics facility has a computer-operated console with three sections and a backup
station for each section. If the primary console fails, the operator can immediately switch
to a back-up station and maintain control of the process.
• At a petroleum refinery, all instrumentation in the alkylation unit is in duplicate,
including hydrogen fluoride (HF) level indicators and wiring. Instruments are backed up
with batteries with a half hour power supply. During a power outage, shutdown is
automatic, and HF can be moved back to the holding tanks.
The presence of backups is unimportant, however, if the backup equipment is not well maintained
or if it does not address critical equipment. At most facilities, some backup features existed; however,
many times these backups did not address critical process equipment. Another common problem at
facilities was the lack of adequate backup for electric and other utilities. In the event of a power failure,
many facilities had no means of maintaining process operation or even adequate lighting. The following
are some of the specific observations:
• At a chemical manufacturing facility, there was no backup for a chemical detection unit,
and the audit team recommended that the facility use several chemical-specific portable
personnel monitors as backups. These units would also provide redundance for the
automatic monitoring system.
• At a facility that burns liquid hazardous waste, the audit team noted there was no
automatic backup to the process temperature control system. A significant decrease in the
temperature would create incomplete destruction of the wastes and thus releasing toxic
vapors directly to the environment via stacks.
Process Parameter Monitoring
Many chemical processes must maintain very stringent parameters in order to function safely and
efficiently. For this reason, chemical safety audits look at the methods of parameter monitoring as a
means of early detection of accidental releases or process upsets which could result in a release. In
general, there were only a few facilities with well-integrated parameter monitoring systems with audio and
visual alarms Among those facilities with formal monitoring procedures, the following are examples of
exceptional practices:
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• All operating units at a chemical facility have centralized control rooms where critical
process parameters are monitored and recorded continuously. Critical systems are
connected to audio-visual alarms which are activated when parameters exceed safe levels.
There are periodic inspections and preventive maintenance to minimize breakdowns.
• At a metal manufacturer, flow monitoring of certain waste streams has been instituted
using a data acquisition network. The system tracks flows in the sewer and monitors the
balance between the influent and the effluent. The monitoring unit samples materials that
are transferred to the sewers on a sporadic basis.
• At another chemical manufacturer, each main plant section has its own central control
room, using both digital and analog instrumentation. All significant process parameters
are monitored in the control rooms, and alarms are provided for critical process functions
and equipment.
Recommendations in the area of process parameter monitoring addressed many issues. Among
these were a number of recommendations to improve temperature and pressure monitoring as an easy and
effective way to improve early detection of system malfunctions or releases. Also, many reports addressed
improvements in control room instrumentation, modernization of monitoring equipment, and increased
number of parameters monitored. Among these recommendations were the following:
• At a chlorine production facility, the audit team went as far as saying that the process
monitoring and control systems should be completely overhauled. More automation and
continuous monitoring should be emphasized, especially in the high hazard areas such as
chlorine handling. One control room with centralized digital displays and remote
corrective action would be ideal.
• At an ammonia production facility, an audit team found that although the facility has a
number of alarms and safety shutoffs, it has no routine monitoring capability for the
presence of hazardous chemicals. The facility should consider such monitoring
particularly for hydrogen sulfide, and for ammonia at one or two points in the ammonia
unloading and handling area.
• At a chemical facility, the audit team suggested that additional temperature probes and
recorders should be installed in the reactors in order to develop temperature profiles for
enhanced control and to serve as a backup in the event of a malfunction in the primary
temperature sensor.
• For its own information, the audit team suggested that a hazardous waste burner should
install continuous recorder devices on all meters that show temperature or pH of the
waste.
In several recent audits, corrosion monitoring practices appeared to be of concern in both tanks
and piping. Corrosion is a problem which is often not easy to detect until a release is imminent. Also,
there appears to be an increased focus on the need for level alarms. Level alarms are a primary means of
early warning of a potential release. These level alarms should be both audible and visible to ensure
acknowledgement of a situation. Specific examples appear below:
• At a chlorine manufacturer, the audit team suggested that an adequate corrosion
monitoring program should be adopted. Electronic instrumentation for measuring piping
and vessel wall thickness and integrity should be utilized.
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• The audit team suggested that an electronics firm should install high level alarms on the
sodium hydroxide tanks to ensure that the tanks do not overflow while being refilled.
Environmental Monitoring
The importance of effective environmental monitors cannot be overemphasized. In the event of a
release, these monitors can provide information on the area and severity of the release leading to its
effective mitigation. This sub-section of the report includes discussion of the types of equipment used to
conduct the monitoring and its placement in process and storage areas or on the facility perimeter. Over
half of the audit reports contained numerous recommendations and comments relating to the improvement
or installation of environmental monitoring equipment indicating the importance of this issue. The most
prevalent recommendations among the audit reports was the installation of equipment for monitoring
levels of hazardous substances, for monitoring worker environment, and for monitoring perimeter chemical
concentrations. A common issue in recent audits is the recommendation for meteorological monitoring.
Especially during an air release, knowledge of wind and weather patterns can be critical in determining the
spread of a release. Despite the need for improvement in most facilities, the following are examples of
successful environmental monitoring programs:
• A chemical manufacturer uses the Systematic Approach for Emergency Response
(SAFER) system for environmental monitoring. Sensors transmit exposure information
on chlorine to the SAFER system. An additional warning system is sounded at the main
gate when the concentration at the sensor reaches a certain level.
• A plastics manufacturer has both perimeter air monitoring stations and ground water well
monitoring stations.
• At an electronics manufacturer, an on-site environmental analytical laboratory was
established to conduct analysis relating to water arid wastewater, hazardous and non-
hazardous waste, waste minimization, environmental contaminants, and pollution
abatement materials for all their facilities. During an emergency, the lab can conduct
contaminant and concentration level analysis. On-site equipment includes mercury vapor
detectors, CO analyzers, halide detectors, oxygen meters, aerosol dust monitors, and a
variety of other monitoring and detecting devices.
Process Hazards
Once the entire process at a facility has been examined, the overall system can be evaluated to
identify processes or areas which present the most significant hazards. This determination can be helpful
to a facility in focusing resources to eliminate these hazards first. Audit team concerns related to this
subject were referenced in the conclusion section of the report, and were specific to individual facilities.
3.4 Chemical Accident Prevention
The seventh element of the CSA protocol is chemical accident prevention, a description of the
facility mechanisms for implementing and maintaining safe process systems. There are five sub-elements
within chemical accident prevention:
• Management Activities -- health and safety initiatives and internal auditing practices
developed by facility and corporate management;
• Process Operation and Maintenance - facility standard operating procedures, employee
training practices, and equipment and instrument maintenance policy;
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• Hazard Evaluation and Modeling - facility hazard evaluation techniques and all-media
accidental release modeling;
• Release Prevention Systems -- facility activities and systems designed to prevent the
occurrence of or reduce the severity of an accidental chemical release; and
• Mitigation Systems - facility systems designed to mitigate the health and safety risk posed
by an accidental chemical release.
Management Activities
Corporate and facility management play an integral role in ensuring a coherent and consistent
approach to chemical safety and health issues at a facility. Without a firm management commitment to
chemical process safety, even the best training programs and operating procedures become outdated, and
facility safety can gradually deteriorate. Chemical safety audits examine and evaluate the commitment of
management to chemical process safety through the existence and contents of policy and goals statements,
general operating guidelines, and safety manuals; the availability of corporate financial and technical
support on facility health and safety issues; and the development of an internal audit program to evaluate
individual facilities or operating units.
Corporate Role
By setting an example in its commitment to chemical process safety, corporate management will
provide the basis for the development of greater safety consciousness at individual facilities. Several
chemical safety audit reports commented on corporate management practices that support the goal of
improving facility chemical process safety. The following is an example:
• Corporate management for a chemical warehouse has been active in the Mid-West
Agricultural Chemicals Association's (MACA) efforts to develop standards for storage
structures, to minimize potential public exposures, to evaluate mitigation systems, and to
examine health and safety issues. They have also established a peer review program in
which managers evaluate each other's facilities, training, and preparedness programs.
• Management at the corporate and facility level at an agricultural chemicals facility have
established plant safety committees, standards review boards and personnel, hazard
evaluation decision tree scenarios, training courses, corporate audits, incident investigation
teams, and accountability criteria for managers.
• Corporate policy for an oil refinery provides reimbursement to employees for training
expenses up to 90% for job-oriented courses and 100% for job-mandated courses.
• The corporate laboratory at a photographic equipment manufacturer performs chemical
compatibility studies, design studies for new chemicals and equipment, laboratory testing
of exposure to new chemical compounds, and develops chemical handling and safety
procedures as well as basic physical property data.
There were several concerns raised by the chemical safety audit teams with respect to corporate
management practices. These concerns focused primarily on the commitment of corporate management to
an overall safety policy, in light of the provision of financial and personnel resources to individual facilities
for safety programs and the development of standard corporate health and safety policies. The following is
an example of these concerns and recommendations:
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• A fertilizer manufacturing facility had no standard safety policy. The audit team
recommended that a corporate safety doctrine be developed that includes safety
procedures covering all employees and all aspects of the workplace.
Facility Role
Facility management must establish its commitment to chemical process safety in order to create a
safe and healthy workplace. Many chemical safety audit reports commented on facility management
practices that support the goal of improving facility chemical process safety. A number of the audited
facilities had adopted the Dupont Safety Training Observation Program (STOP), under which unsafe
procedures observed by fellow employees are brought to the employee's attention for discussion and
modification. The following are some other notable examples:
• A chlorine manufacturer has an unsafe condition report procedure to allow employees to
identify potential problem areas. Management response to the report is required within a
specified time frame, and reports and follow-up actions are tracked on a computer.
• Employees at an oil refinery who have had no accidents over a period of three years are
allowed to join a club called the "Armadillo Club," which gives certain off-duty benefits to
workers and is a source of pride for plant employees.
• Managers at a pesticide packaging facility develop an annual safety, health, and
environmental plan to outline activities for the following year, such as conducting
HAZOP reviews for various process units, investigating wastewater treatment options,
investigating better release prevention systems for unloading stations; and conducting a
review of fire protection for the warehouse production room.
• A photographic equipment manufacturer is working toward certification under the
International Standards for Organization 9000 quality management system endorsed by the
European Community. The standard is basically a common sense document setting down
the minimum requirements for a quality assurance system that demonstrates to customers
that a business is committed to quality. Internal audits are conducted to evaluate
compliance with the standard.
There were a variety of concerns raised by the chemical safety audit teams with respect to facility
management practices. These concerns primarily focused on the responsibilities of health, safety, and
environmental management personnel; the development of facility health and safety policies; the regularity
and attendance at scheduled safety meetings; safety incentive programs for employees; and the membership
of facility safety committees. In addition, a number of audit reports addressed security measures to restrict
access to hazardous substance process and storage areas. Several illustrative concerns and
recommendations made were:
• At a fertilizer manufacturer, the safety director also serves as the traffic manager and the
security manager, and as a result devotes less than half of his time to safety issues. The
audit team recommended that the facility should consider hiring a full-time health and
safety manager.
• The safety and environmental departments at a pesticide manufacturer share certain
duties. The audit team recommended that there should be more formal communication
and cooperation between the departments to meet their common responsibilities.
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• An oil refinery conducts safety meetings for its management employees. The audit team
recommended that the facility should involve operations and shift employees more directly
in the facility's safety meetings, even if on a rotating basis.
• The new ownership at an electronics manufacturing facility did not maintain the pre-
existing system of internal audits, safety goals and objectives, safety meetings, and formal
training and maintenance recordkeeping. The audit team recommended that these
elements of the former safety program be reinstituted.
Audit Activities
A regular schedule of audits will not only improve specific process unit conditions, but will also
support a consistent approach to health and safety issues throughout the facility. Several chemical safety
audit reports commented on auditing practices that support the goal of improving facility chemical process
safety. The following are some examples:
• A chemical manufacturer conducts a comprehensive audit of its facilities every 18 months
that generates a list of action items to be addressed by facility management.
• At a carbon black manufacturer, a plant safety team, consisting of two management and
three hourly employees, conduct monthly internal audits. Important results are then
discussed at monthly safety meetings, attended by all employees.
• A plastics manufacturer developed an annual internal auditing program to assess
industrial and chemical process safety, industrial hygiene, environmental protection, and
other issues. The program also includes a planning and tracking system for evaluating the
facility's achievement of health and safety goals.
There were a few concerns raised by the chemical safety audit teams with respect to internal audit
activities. These concerns focused on the lack of a comprehensive, regular internal auditing program to
evaluate the effectiveness of training, maintenance, and other health and safety programs. Specifically, the
audit team commented on the lack of a regular audit schedule, insufficient coverage of all units handling
hazardous substances, and the absence of formal facility procedures for implementing audit
recommendations. The following is an example of these concerns:
• An oil refinery has no formal procedures for follow-up on internal audit findings and
recommendations by management; thus, internal audit results may not be followed up on
and implementation of any recommendations may never occur. The audit team
recommended that the refinery should establish a tracking system to ensure that action is
taken on audit findings and recommendations.
Process Operation and Maintenance
Standard Operating Procedures
The existence of standard procedures for normal and emergency operations provides a basis for
coherent, safe facility operations by supporting safety in day-to-day activities as well as operator training
programs. Standard operating procedures (SOPs) provide an outline for routine and emergency
operations, as well as process start-ups and shutdowns, and should be immediately available in the
appropriate process areas. A chemical safety audit examines the breadth of operations covered by SOPs,
the regularity with which SOPs are reviewed and revised, and access to and familiarity with SOPs by
operators and supervisors.
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Several chemical safety audit reports commented on standard operating procedure policies that
support the goal of improving facility chemical process safety. The following are some examples:
• Before filling operations begin each day at a chlorine manufacturing facility, every
connector, valve, and flange is checked for chlorine leaks with aqueous ammonia.
• A lighting equipment manufacturer has developed concise task instruction lists written to
fit the non-technical educational background of the general production staff.
• An agricultural chemical manufacturer has prepared extensive documentation on
operating procedures, including detailed plant startup and shutdown procedures, operating
procedures, and technical operating profiles to assist the technical staff in daily operation.
The facility has a complete set of engineering documentation consisting of detailed
mechanical, process, and instrumentation drawings, specific equipment, and general
equipment specifications. In addition, there are operator training manuals ~ covering all
plant operation and integrating job definitions, roles, emergency response instructions, and
training information -- which are used as operator's reference manuals.
• A pesticide packaging facility has comprehensive and detailed job analysis guides for all
raw material unloading, process operations, and storage and shipping operations, in the
respective process areas. The guides, which include lists of required safety gear and
cautions for the specific tasks, are used for training purposes and are routinely evaluated.
There were a variety of concerns raised by the chemical safety audit teams with respect to standard
operating procedures. These concerns focused primarily on ensuring the availability of SOP manuals in
each process area, using checklists, process records, and operating logs to track daily activities, and
coordinating SOPs with training, hazard evaluation, and emergency planning programs. In addition,
several audit reports indicated that current SOPs do not necessarily reflect recent plant modifications or
are not located in appropriate areas of the plant. The following is an illustrative example of these
concerns and recommendations:
• A chemical facility had no log books, SOPs, emergency notification and fire procedures,
safety manuals, or other information. The audit team recommended that the facility
should use log books to support communication between supervisors and operators.
Training Practices
j
Training of supervisory and operations personnel provides the most immediate opportunity to
increase awareness of chemical health and safety issues, as well as working to ensure the competence of
employees in performing their responsibilities. Although training can be conducted in a classroom or on-
the-job setting, a training program is most effective when it involves learning evaluation (tests) as well as
regular refresher training. Chemical safety audits review the type and content of employee training
programs, the existence of refresher training, and provisions for evaluating the effectiveness of the training.
Several chemical safety audit reports commented on training practices that support the goal of improving
facility chemical process safety. The following are some examples:
• A chemical manufacturer has instituted a comprehensive training program for
maintenance employees requiring a passing grade on a written test and four practical tests
before a new employee is admitted to the department. Advancement depends upon
results from further tests.
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• An oil refinery employs a contractor safety coordinator to oversee contractor personnel
training by reviewing scheduled training programs and testing contractor employee
knowledge. In addition, managers are given extensive training in hazard evaluation and
accident prevention.
• A pesticide packaging facility conducts cross-training of plant personnel on all process
activities to produce a more comprehensive understanding among employees of all specific
process tasks.
• Employees at a semiconductor facility are required to complete 40 hours of "relevant job
training and education" each year according to corporate policy. Managers are responsible
for setting employee training requirements, and the training and human resource
department provides support in setting up and evaluating training courses. Worker safety
and hazardous materials waste handling are among the courses offered. Training is
tracked on computer and can be accessed by employee name, course number, or
department.
There were a variety of concerns raised by the chemical safety audit teams with respect to training
practices. These concerns primarily focused on specific areas that employee safety training should
encompass and the type of training that should be made available to specific groups of employees, as well
as the coordination of training with other health and safety programs. Specifically, the audit reports
recommended that safety training for facility contractor, management, and maintenance employees should
be expanded. Several audit teams also suggested the use of simulation exercises as a regular part of the
facility training program, the institution of a formal knowledge testing program, and the creation of safety
awareness programs for facility visitors such as tour groups, equipment vendors, and delivery personnel.
Two specific concerns and recommendations were:
• There is no formal classroom training, only on-the-job training, at a plastics facility. The
audit team recommended that a formal classroom training program should be established
to educate operators about hazardous materials, process design, and safety systems.
• A bleach manufacturer did not control or track contractor training. The audit team
recommended that the facility should oversee contractor training to increase contractor
familiarity with safety procedures and to improve the capacity of contract employees to
respond in an emergency situation.
Equipment Maintenance
Maintenance of chemical process equipment falls into two categories: predictive or preventive
maintenance, which is performed to avoid equipment failure or breakdown, and emergency maintenance,
which is performed in response to equipment failure. While the latter is an essential element of any
facility maintenance program, systems of predictive or preventive maintenance are essential to effective
chemical process safety. Key maintenance issues in a chemical safety audit are the written and informal
maintenance procedures at a facility, such as testing and inspection practices, equipment history records,
and maintenance scheduling systems. Several chemical safety audit reports commented on equipment
maintenance programs that support the goal of improving facility chemical process safety. The following
are some examples:
• The predictive maintenance program at a metal refinery includes ultrasonic thickness
testing, vibration analysis, and infrared video imaging to identify deteriorating equipment.
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• A chemical manufacturer inspects all safety valves and rupture discs on a rotating basis
each month, and has created a computer database to track maintenance records and
identify continuing trouble spots.
• Another chemical manufacturer uses a computer software to track and monitor preventive
maintenance, generate work schedules, track equipment history, issue work orders,
maintain spare parts control, and do cost reporting.
• Maintenance staff at a third chemical manufacturer are involved in a program to
continually test new materials and products that will help to increase the operating life
and safety of equipment at the facility.
• An oil refinery uses a conventional work-order system for maintenance tasks,
discriminating between normal, emergency, and preventive tasks. A system is in place
establishing preventive maintenance cycles, and subsequent planning and scheduling of
that maintenance work. Check lists and maintenance records and histories are kept on
equipment and check sheets are used for common, repetitive maintenance work.
There were a variety of concerns raised by the chemical safety audit teams with respect to
equipment maintenance. These concerns primarily addressed facilities without formal maintenance
procedures or informal "as-needed/ breakdown" maintenance procedures. Many recommendations focused
on conducting regular equipment inspections and instituting formal preventive maintenance programs. In
addition, a number of audit teams suggested that the facility should institute a more formal maintenance
record system and examine historical maintenance records to identify problematic equipment. A few of
the more specific concerns and recommendations were:
• The maintenance policy at a chemical manufacturer was to repair equipment when it fails.
The audit team recommended that the program should be upgraded to include routine
replacement of critical parts based on the history of failure, rather than on observation of
actual failure.
• Another chemical manufacturer did not consistently follow lock-out and tag-out
procedures for out-of-service equipment. The audit team recommended that the lock-out
and tag-out programs need to be formalized so that non-functional equipment is properly
marked.
• While a third chemical manufacturer was installing a computerized maintenance
management system to replace a system of handwritten records, the audit team
recommended that the facility should review the preventive maintenance schedule and the
history of unscheduled maintenance for each unit process and modify the preventive
maintenance schedule accordingly.
Instrument Maintenance
As with equipment maintenance, maintenance of instruments can be separated into two categories
- predictive/preventive and emergency maintenance; once again, programs of predictive or preventive
maintenance are key ingredients to a comprehensive chemical process safety management system.
Similarly, key instrument maintenance issues in a chemical safety audit are the written and informal
maintenance procedures at a facility, such as testing and inspection practices, instrument history records,
and maintenance scheduling systems. A few of the chemical safety audit reports commented on instrument
maintenance programs that support the goal of improving facility chemical process safety. For example:
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• A chemical manufacturer has its own instrument maintenance technicians, who are trained
at classes conducted by the instrument manufacturers and vendors.
There were a few concerns raised by the chemical safety audit teams with respect to instrument
maintenance. These concerns focused on the absence of regular preventive maintenance for instruments.
In addition, some audit teams suggested that the facility should institute a more formal instrument
maintenance record system and examine historical maintenance records to identify problematic
instrumentation. The following is an example of these concerns:
• An audit team concluded that the preventive maintenance for instruments at an oil
refinery is less effective due to a complex work order system, a possible shortage of
instrument technicians, the scheduling of instrument system inspections every three years,
and the numerous additional responsibilities of the instrument reliability engineer. The
audit team recommended that the instrument maintenance program be redesigned.
Hazard Evaluation and Modeling
The development of a facility hazard evaluation and modeling program, particularly in conjunction
with community planning efforts, supports both emergency preparedness and accident prevention
initiatives. Hazard evaluation and modeling can direct attention to the areas in most need of improvement
by providing a thorough analysis of the potential causes and consequences of accidents at the facility. A
chemical safety audit examines whether a formal hazard evaluation and modeling program is in place, who
participates in the process, and how the results are utilized by the facility to improve safety. Several
chemical safety audit reports commented on hazard evaluation and modeling programs that support the
goal of improving a facility's chemical process safety. The following are some examples:
• An oil refinery has organized a team of personnel, including personnel from the
engineering, operations, maintenance, and safety departments as well as management, to
evaluate hazards, discuss safety issues, and consider changes to the facility's design,
construction, and standard operating procedures.
• A chemical manufacturer routinely performs HAZOP studies to evaluate process safety
hazards for capital additions and process modifications, as well as on a scheduled basis
and after accidents or near-misses. They also use the CHARM software package for
dispersion modeling -- occasionally for real-time response data, but more often to run
worst-case release scenarios for emergency planning purposes.
• Another chemical manufacturer has participated in a voluntary initiative with twelve
nearby facilities to perform dispersion modeling analysis of ground-level concentrations
from emissions, considering each facility individually and then cumulatively.
• Hazards at an oil refinery have been evaluated in three separate studies; several types of
air models were used to estimate contaminant plume characteristics as part of these
hazard studies. Gaussian models were applied for normal operating conditions. Two
dispersion models, the "Hazardous Atmospheric Release Model" and the "Industrial
Source Complex" model were used to predict surface concentrations during upset
conditions.
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Hazard Evaluation
There were several concerns raised by the chemical safety audit teams with respect to hazard
evaluation practices. These concerns primarily focused on the development and regular updating of hazard
evaluations for specific process areas. Several of the audit teams were also concerned about the lack of
facility experience in conducting hazard evaluations. A few of the more specific concerns and
recommendations were:
• Employees at a fertilizer manufacturer do not have any understanding of hazard analysis
techniques, and the facility has no protocols for identifying specific hazards, the areas at
risk from a release, or the effects of exposure in the event of a release.
• Due to potential contamination of groundwater and soil, a chemical manufacturer should
review and evaluate the plant-wide sewer and drainage system.
• A metal refinery has no comprehensive risk management program based on hazard and
operability (HAZOP) studies and hazards analysis. The audit team recommended that the
facility should conduct a HAZOP study to systematically identify hazards or operability
problems for the facility, including hazards which may result in or be affected by an
uncontrolled acid release.
Modeling
There were several concerns raised by the chemical safety audit teams with respect to modeling
practices. These concerns primarily focused on the absence of any release modeling program at the facility
to identify vulnerable areas within the surrounding community or the failure of the facility to provide the
community with modeling information that had been developed. The following is an example of these
concerns:
• A metal manufacturer has not conducted modeling for evaluation of the consequences of
releases of sulfuric acid or other hazardous chemicals present at the facility.
Release Prevention Systems
There are a variety of often unrelated facility practices which can be identified as release
prevention systems -- the means by which the facility seeks to reduce the likelihood and/or severity of
accidental releases of hazardous chemicals. Chemical safety audits should review the types of systems in
place, design modifications, installation of new equipment, and changes in the type and quantity of
hazardous substances as potential methods of release prevention. Several chemical safety audit reports
commented on release prevention systems and equipment that support the goal of improving facility
chemical process safety. The following are some examples:
• The floor of the hazardous materials processing area at a payload processing facility is .
covered with vinyl tiles, impregnated with graphite, and bonded to the concrete with
conductive mastic. This floor construction dissipates static electricity to the building
grounding grids, thus reducing the threat of an electrostatic discharge igniting flammable
liquid propellants.
• An oil refinery redesigned its processes to replace chlorine with bromine, which is
significantly less toxic, and to use gaseous, rather than liquid ammonia to reduce high
pressure hazards.
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• Another refinery replaced chlorinated solvents with hydrocarbon solvents to reduce the
hazards of its cleaning operations, and intends to replace the hydrocarbon solvents with
steam cleaning apparatus to further reduce its chemical hazards.
• The ventilation system in the reactor room at a hazardous waste processing facility is shut
down in the event of a release to prevent the escape of nitric oxide or other contaminants.
This procedure allows all of the potentially contaminated air to be processed by a
scrubber system.
There were a variety of concerns raised by the chemical safety audit teams with respect to release
prevention. These concerns primarily focused on a wide variety of specific systems and equipment that
could be installed in individual process areas to reduce the potential for significant releases. The following
are illustrative examples of these concerns and recommendations:
• An audit team visiting a chlorine manufacturer recommended that the facility should
consider installing an electrical isolation valve at the chlorine tanks to stop the chlorine
flow in case of a failure in the piping system or the bulk loading rack.
• An audit team visiting a water treatment facility recommended that utility management
should continue to evaluate the use of alternate chemicals (i.e., sodium hypochlorite) that
may be safer than using chlorine.
Mitigation Systems
There are a variety of practices which can be grouped together as release mitigation systems -- the
means by which a facility seeks to reduce the impact or the severity of the impact of a hazardous chemical
release. The principal methods of mitigating accidents include systems to deploy foam, water, or other
chemicals, as well as containment devices (e.g., dikes or curbs) to halt or slow the spread of a release.
Several chemical safety audit reports commented on release mitigation systems and equipment that support
the goal of improving facility chemical process safety. The following are some examples:
• A payload processing facility has installed a computer-controlled fire suppression system
requiring two events for activation. First, the smoke and heat detectors must open the
sprinkler water valve; then there must be enough heat to melt the fusible link in the
sprinkler head. This prevents a false alarm from resulting in damage to sensitive payloads.
• A plastics manufacturer installed a new storm drainage system to control the flow of
liquid wastes toward the storm water drains. A culvert routes these wastes to several
waste water holding tanks for treatment.
• An oil refinery uses cone roofs on its major oil tanks to reduce evaporation, and
surrounds these tanks with earthen dikes or retaining walls. There is also a large ditch
that is designed to prevent spills escaping containment from reaching a nearby river.
• All storage tanks at a metal refinery are contained in concrete dikes that are designed to
hold more than the maximum contents of the tank to prevent overflow.
• The flammable storage area at a chemical warehouse has a separate, 18,000-gallon
flammable liquid recovery system that removes released flammables from the building via
a floor drain to an exterior storage tank. The emergency tank is situated in a bermed
swail so that any overflow from the tank will be contained.
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There were a variety of concerns raised by the chemical safety audit teams with respect to release
mitigation. These concerns primarily focused on installation and maintenance of diking and other
containment systems and water sprays and other suppressant systems. Many of the reports identifying
problematic containment practices were concerned with the segregation of incompatible chemicals and the
effectiveness of existing systems. A few of the more specific concerns and recommendations were:
• A chemical manufacturer has storage tanks and unloading areas that lack secondary
containment. Spill containment dikes should be installed on a priority basis for all
chemical storage tanks in light of the proximity of the nearby wetlands and river.
• At a chlorine manufacturing facility, containment dikes were old, breached, or appeared to
be of inadequate capacity to control a catastrophic release. The audit team recommended
that the containment systems be improved.
• A lighting equipment manufacturer has several process involving incompatible compounds
surrounded by a single containment system. The audit team recommended that separate
diking and sump systems should be constructed to segregate the individual process units
and any potential spills of incompatible substances.
• Due to the limited emergency response accessibility of the ammonia tanks at a jewelry
manufacturer, the audit team recommended that a water deluge system should be installed
to knock down released vapors, and that the facility should evaluate the disposition of any
contaminated run-off.
• A number of problematic containment practices were examined at a petroleum storage
terminal, including insufficient containment capacity; deteriorated earthen dikes; large
storage tanks adjacent to their containment dikes; dikes and berms compromised in
numerous places to allow passage of piping; tank farms not separately bermed; and the
limited capacity of a pair of oil/water separators, which control outflow into a nearby
waterway.
3.5 Accidental Release/Incident Investigation
This element of the CSA protocol addresses the history of accidental releases and incidents and
the resulting facility responses. In order to prevent future accidents, facility's should investigate their
training and work practices to identify the causes of accidents and assess the need for improvements in
equipment and operating procedures. Guidelines should be developed for documenting releases of
hazardous substances, including fires and explosions. Management must be knowledgeable of the accident
history of the facility so that trends among accidents can be identified and corrective action can be taken
as necessary. There are two sub-elements of accidental release/incident investigation:
• History of Accidental Releases/Incidents, describing the types of releases that have
occurred at the facility in the past and how the facility responded; and
• Facility Investigation Procedures, describing a facility's investigation policies, including:
types of releases investigated, personnel responsible for conducting investigations, and
corrective actions resulting from investigations.
The audits show that most facilities represented have a standard procedure for investigating
releases. The audit teams noted, however, that several of these facilities normally do not investigate "near
misses." The auditors suggested that facilities investigate releases of all sizes as well as "near misses" in
order to identify problems in operating procedures and equipment that could result in larger or more
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damaging releases in the future. Part of the investigation procedure should involve a review of training
practices in order to identify ways that accident prevention training could be improved. In addition, the
audit teams stressed that facilities should identify "follow-up" procedures for ensuring that appropriate
corrective actions are taken after a chemical incident.
Several chemical safety audits describe successful investigating and reporting procedures that
indicate management's goal to preventing future incidents. For example:
• A chemical facility investigates unidentifiable plant emissions. In the past, the facility has
made process and mechanical changes in response to these investigations to reduce the
likelihood of a reoccurrence.
• The environmental department at an agricultural chemicals manufacturer tracks all
releases, even if they are below the reportable quantity.
• The policy of another chemical company is to report accidental releases and "near misses"
to the Corporate Safety Officer. Reports are then reviewed by corporate headquarters
and recommendations are sent back to the facility.
• At an oil refinery, the system of release investigation includes an evaluation and review of
current training and work practices to identify the causes and factors involved in the
release. After investigations, findings are reported to management, safety committees, and
facility trainers.
• Another chemical manufacturer compiles the information generated from incident reports
and uses it to prepare corporate safety policy and design and operation modifications.
The company also disseminates the information to other Hercules facilities that use
similar processes or system designs.
• The policy of a metal refinery is to conduct a full "post mortem" investigation for any
significant spill to determine the true causes of the spill, the clean up costs involved, and
to implement preventive procedures.
In some cases, the audits reflect concerns about facilities that do not have standard procedures for
investigating and reporting releases or for investigating "near misses." The audit teams mentioned, in some
cases, that facilities need to incorporate conclusions from accident investigations into their training
programs. It was also noted that some facilities lack "follow-up" procedures to ensure that corrective
actions have been taken. For example:
• A plastics manufacturing facility had no written procedures for investigating chemical
incidents, sharing information about causes and prevention of spills with other parts of the
facility, or conducting follow-up investigations.
• At a petroleum refinery, the audit team observed that incident files did not provide
evidence of in-depth investigations of "near misses" or reportable releases.
• At a pulp products manufacturing facility, the audit team recommended that the facility
draft an SOP with guidelines for conducting investigations of incidents, releases, and near
misses to elicit maximum information for future accident prevention training.
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• At an organic chemicals manufacturing facility, the audit team observed that investigation
techniques did not fully assess system reliability, corrective technology, or the probability
of a recurring incident.
3.6 Facility Emergency Preparedness and Planning Activities
This element of the CSA protocol focuses on facility emergency preparedness and planning
activities including actions taken by plants to prepare for emergency incidents involving hazardous
substances. The protocol lists nine sub-elements of facility emergency preparedness and planning:
• Facility Emergency Response Plan -- facility emergency plans and procedures including
schedules for updates and key areas covered;
• Emergency Response Exercises and Simulations — description of types of drills, frequency
of occurrence, and use of findings;
• Fire, Evacuation, and Rescue Corridors - condition of fire and rescue corridors and detail
and location of facility and community maps;
• Emergency Equipment Provisions -- provisions used to maintain, test, and locate
equipment in the facility, and train personnel on its use;
• Emergency Response Chain of Authority -- chain of command describing the designation
of control during an emergency;
• Emergency Response Management Procedures -- management's role in response incidents;
• Emergency Communication Network within the Facility -- communication(s) systems and
backups including testing and training procedures;
• Emergency Response Personnel Training Requirements -- type and frequency of
emergency response training available; and
• Follow-up Release Procedures - clean-up and review of response with involved parties.
Facility Emergency Response Plan
Comprehensive facility emergency planning is the crucial element for effective and rapid response
to accidents. An all-inclusive response plan, followed by well-trained facility personnel and local
responders, can protect both facility employees and the surrounding community from a worsening release
situation. It is the effective plan that minimizes the consequences of a release. Several audit reports cited
a number of effective planning techniques, including the following:
• A chemical production plant developed a contingency plan which covers responses by two
designated facility emergency response teams.to any emergencies that may occur.
• One hardware manufacturer revises its contingency plan annually, and distributes the plan
to facility management personnel as well as the LEPC, the local fire department, the local
hazmat unit, and the local hospital.
• To develop a preparedness, prevention, and contingency plan, a plastics plant hired a
planning consultant to add expertise to the drafting process.
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There were a variety of concerns with respect to facility emergency response plans. The primary
concern of audit team members was that many of the facilities audited had emergency plans that lacked
key elements including site and area maps, evacuation routes, lists of chemicals in use at the facility,
information on possible plume dispersion pathways, and other elements. This lack of comprehensiveness
sometimes stemmed from a failure to recognize the potential hazards at a particular facility. Several audit
teams suggested that facilities with incomplete plans conduct a careful hazard evaluation to determine all
potential trouble areas that need to be addressed by the plan. Several facilities relied on multiple
incomplete documents for their emergency plans. To avoid any possible confusion, audit teams
recommended that critical elements of each of these plans be reflected in a single, comprehensive
emergency response plan. Use of computer modeling to determine off-site vulnerability was also cited as
an effective tool for enhancement of response planning. Audit teams recommended that emergency plans
cover all degrees of response from the smallest of spills to uncontrollable or catastrophic releases.
There were several other concerns about emergency response planning. Regulatory requirements,
including CERCLA and SARA reporting procedures and corresponding phone numbers, are another
crucial element not often included in the emergency plans. Audit teams noted that a number of facilities
listed phone numbers that had not been updated or were incorrect. A comprehensive plan should not also
be a confusing one; audit teams recommended that facilities take care in crafting their plans to be concise
and easy to understand and to implement. Emergency plans need to be revised regularly to prevent even
the most comprehensive of plans from becoming outdated. Plans need to be updated to reflect changing
process conditions, equipment, personnel, and procedures, and to be integrated with the community and
appropriate local and state responders. Several recommendations were made to facilities to establish a
schedule for updating their existing emergency response plans. A few of the more specific concerns and
recommendations were:
• An audit team recommended that a payload processing facility develop written guidelines
for sequencing and timing of emergency response activities following an "uncontrollable"
spill including a definition of initiating incidents, proper mitigation and evacuation
procedures, and steps and requirements for plant re-entry.
• An audit team suggested that the contingency plan at a swimming pool chemical company
be reviewed and rewritten with more emphasis toward those persons who are going to
have to read, understand, and place into operation its mandates. For instance, an
employee or a professional industrial writer could prepare a draft which the response
employees can exercise to evaluate its effectiveness as a planning and response tool.
Emergency Response Exercises and Simulations
Emergency response exercises and simulations are an integral part of a facility's emergency
preparedness and planning. Conducting drills, from table-top exercises to the most elaborate of accident
scenarios, is an integral way of ensuring that an emergency response plan is realistic, effective, and
understandable. If a facility gets into the habit of drilling different aspects of their response plans at
regular intervals each year, the employees will become increasingly familiar with correct emergency
response procedures. Exercises are most helpful when the conditions vary from drill to drill so that
employees learn appropriate procedures for each accident scenario. A number of audit reports highlighted
facilities' programs to regularly conduct emergency response exercises. The following are some examples:
• Emergency squads at an agricultural chemical manufacturer conduct monthly drills on
selected subjects. Each year, the plant conducts two drills with community involvement.
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• At a bleach manufacturing facility, emergency drills are held quarterly, including table-top,
walk through, and planned simulations. Drills are held during day shift working hours as
well as weekends and nights.
• A petroleum refinery has four emergency response teams which each conduct four
exercises annually. At least one exercise from each team is conducted on a plant-wide
level, the goal of which is to involve the local response community in a plant-wide
exercise.
• Following emergency response exercises at an ammonia and urea production plant, reports
are prepared by the participants, analyzed by the safety and environmental staff, and
discussed at the next safety meeting.
Most of the concerns with respect to emergency response exercises and simulations had to do with
the frequency of drills. A facility could have the most comprehensive of emergency plans, but unless the
facility conducts regular drills, the plan may not be followed properly. In many cases, either drills were not
conducted on a routine basis or simply not at all. Several CSA reports recommended that facilities
develop an exercise schedule in order to make drills a routine part of plant operations. Another concern
was in lack of attempts by facilities to vary the types of exercises conducted. In addition to facility-wide
drills, table-top exercises were suggested as well as exercises that highlight hazards to the surrounding
community. Audit teams also noted that mutual emergency response aid agreements between facilities had
often not been exercised. There were additional concerns that facilities failed to record the lessons learned
during an exercise in order to correct mistakes in response procedures prior to an actual emergency.
Because of this concern, audit teams suggested that facilities document formal critiques of their
drills/exercises to improve response procedures. A few of the more specific concerns and
recommendations were:
• A chlorine and alkali production plant has a comprehensive "Plant Emergency and RCRA
Contingency Plan" that addresses issues such as alert procedures, emergency shutdown
procedures, media responsibility, MSDS listings, and evacuation procedures, but has not
been routinely exercised.
• An agricultural chemicals manufacturer had conducted annual exercises and set a goal to
have quarterly exercises, but had not planned to vary the accident scenarios for each
exercise. To promote the development of a flexible response capability, the audit team
suggested that the facility consider holding several different types of exercises on a
rotating basis annually.
Fire. Evacuation, and Rescue Corridors
Well-marked fire, rescue, and evacuation pathways accomplish several things. First, these
pathways and corresponding facility and community maps can aid responders in identifying appropriate
rescue procedures. Concise evacuation plans also help to protect and account for all employees during an
evacuation. A number of audit reports focused on the adequacy of fire, evacuation, and rescue corridors.
The following are some examples:
• Measures have been taken at a bleach manufacturing facility to familiarize fire/police
department personnel with the plant layout, principal hazards, and fire protection
facilities.
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• There are ten major defined egress routes in one petroleum refinery, each marked with
distinctively colored signs leading to specified off-site staging areas. Large evacuation
maps are posted throughout the plant.
There were a variety of concerns with respect to facility fire, evacuation, and rescue corridors.
Some audit teams observed that evacuation plans lacked detailed facility and community maps, and
evacuation procedures, in some cases, were not posted in highly visible locations. An absence of maps and
posted procedures not only makes fire and rescue operations exceedingly difficult, especially for off-site
emergency responders unfamiliar with the layout of the plant, but also can cause a breakdown in the
evacuation of personnel from the building and surrounding area. Facility employees should be able to
evacuate through multiple escape routes to predesignated meeting areas at a minimum safe distance. To
aid in employee accountability after an evacuation, several audit teams suggested using a per-building head
count system. In addition, audit teams were concerned that facilities did not train personnel in flexible
evacuation procedures to suit changing situations or threats during an emergency. Audit teams suggested
that facilities be aware of, and plans account for, any unique topographical or meteorological conditions
that may hinder evacuation routes in a particular area. A few of the more specific concerns and
recommendations were:
• A detergent manufacturer had a single door as the only available escape route from the
building. Improved ventilation and additional escape routes were needed.
• A plastics plant was advised to develop additional evacuation plans for imminent danger
situations. The primary concern of such a plan would be immediate evacuation of all
personnel, to a minimum safe distance, by the most expedient means possible.
• One audit team determined that the confined and dark conditions in a food products
manufacturing plant could hinder efficient evacuation of operators in the event of a
release. The audit team recommended that the facility upgrade the area by improving
lighting.
Emergency Equipment Provisions
Having equipment available immediately to mitigate an emergency situation is essential to stem
the consequences of a release. If facilities were to depend on off-site response equipment alone, an easily
controlled release could lead to a catastrophic accident. Effective response equipment, used by trained
personnel, can prevent such consequences through timely containment and mitigation of the situation. A
number of audit reports indicated the presence of proper emergency equipment at some of the facilities.
The following are some examples:
• A twenty-company cooperative, spearheaded by a specific petroleum refinery, purchased
and stocked a semi-trailer with spill response equipment to more effectively respond to
spills in a nearby river.
• The Safety Department at an agricultural chemical manufacturer performs monthly
inspections and maintains written records on all safety equipment. Once a year, a private
contractor is brought in to check this equipment.
There were a variety of concerns with respect to facility emergency response equipment. In a
number of cases, facilities had some form of personal protective equipment (PPE) and emergency response
equipment, but did not strategically locate this equipment throughout the facility, particularly in areas
vulnerable to releases. In some cases, audit teams suggested location of such equipment in predesignated
and well stocked spill control cabinets or "disaster packs." In several cases, eyewash stations were not
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easily accessible. Suggestions were made that facilities acquire additional equipment, including cartridges
for acid vapors, neoprene boots, backup PPE, five minute escape masks, and other equipment.
Maintenance and regular testing of personal protective equipment to avoid deterioration had not been
performed at some facilities. Improvements could also be made on fire fighting capability, perhaps by
establishing a fire brigade. Procedures for such a brigade should be outlined, including a description of
the transfer of responsibility for fighting a fire from facility response teams to local fire department
personnel. A few of the more specific concerns and recommendations were:
• At a waste water treatment plant, workers wear ordinary clothing and do not have access
to totally encapsulated suits to protect themselves from exposure to chlorine. The audit
recommended that the facility make personal protective equipment available throughout
the facility.
• At a chemical manufacturing facility, firefighting water pumps were supplied by city water
rather than river water. In order to avoid any possible stoppage of water to the pumps
due to a failure in the city water supply, the facility should install a pumping system to
enable equipment to pump water from a nearby river to fight a major fire.
• An audit team recommended that a pesticide production plant provide sufficient numbers
of level A hazardous materials suits so that two emergency responders have an additional
two man backup.
Emergency Response Chain of Authority
Establishment of a chain of command can streamline a large-scale response by ensuring that all
responders receive authorized assignments in order to maximize safety. By specifying personnel in charge
of response situations, facility management can avoid confusion and implement emergency procedures
immediately. A number of the facilities audited had a formal emergency response chain of authority in
place. The following are some examples:
• During emergencies at a pesticide production facility, the shift supervisor for the half of
the plant involved in the incident serves as the on-scene coordinator. The other shift
supervisor becomes the emergency coordinator and also serves as the replacement for the
on-scene coordinator if he/she is unable to serve in that capacity.
• In case of an emergency at a plant that manufactures chlorine and alkalis, the control
room operator and the shift supervisor make the decision to shut-down operations. In the
event of a leak, the area operator and his assigned backup have responsibility for bringing
the situation under control.
Audit team members found that a number of facilities did not identify an emergency response
chain of authority or even an individual responsible in case of emergency. Some facilities did not
document a chain of authority because they assumed personnel knew whom to contact during an
emergency. In addition, several facilities that identified responsible personnel did not ensure that they
could be reached after normal working hours. Audit team members recommended that facilities establish
a formal chain of authority, and identify backup personnel, available during all shifts to manage
responders. A few of the more specific concerns and recommendations were:
• A fertilizer plant has outlined its emergency planning in broad terms and has no formal
chain of command for combatting fires, explosions, or releases. The facility should require
all shifts to have several personnel designated to initiate notification procedures in case of
emergencies.
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• One pesticide warehouse facility does not state in its spill response plan who is
responsible for differentiating between minor and reportable releases, or for assuring that
evacuation of the area and product identification are accomplished.
• The chain of authority at a hardware manufacturer was unclear. The plant manager acts
as emergency coordinator, but it was unclear who reports releases to the coordinator.
Emergency Response Management Procedures
Facility management not only needs to identify those in charge during an emergency, but also
should establish formal procedures for management to follow. These procedures should be included in
facility SOPs and emergency response plans. By indicating the procedures management will take in case of
an accident, a facility can ensure decisiveness in the initial stages of a response action. The following are a
couple of examples of an effective emergency management procedures in place at a facility:
• If an emergency occurs during daylight hours at a certain chlorine and alkali production
facility, procedures call for the plant manager and the safety manager to converge on the
central security station in order to coordinate emergency operations. In the event of a
night or weekend emergency, all management would report to the central security station
or (in case the central station is jeopardized by a hazardous release) to a predetermined
backup location.
• At one petroleum refining facility, the shift supervisor is responsible for emergency
response, including notification of the security department, the response team, and other
operating personnel. The shift supervisor is also responsible for categorizing emergencies
into one of three classes, depending on the nature of the response required.
There were a variety of concerns with respect to facility emergency response management
procedures. One concern was that facilities need to evaluate the feasibility of a centralized emergency
control center. Other concerns include a recommendation that facilities address safety shoe and contact
lens policies, and that safety glasses be required for employees in certain areas of the plant. An illustrative
example of these concerns follows:
• An audit team noted that an automobile air bag propellant manufacturer had not
formalized its emergency management procedures, and recommended that the facility
include such procedures in its standard operating procedures.
Emergency Communication Network within the Facility
To keep emergency response personnel abreast of changing conditions, a communication network
is essential. The ability to communicate the nature of an accident quickly to facility personnel and to off-
site responders helps to determine the initial success of a response operation. Color-coded signals as well
as various audible alarms are this first means of informative communication. Constant contact during a
response action and following an incident ensures that everyone involved remains informed as to the
nature and severity of the accident. Various backup systems, not including phone service, ensure that a
loss of electricity or other problem does not result in a breakdown in communication. Several CSA
reports cited several effective means of emergency communication, including the following:
• A chemical manufacturer has two distinct color-coded alarm systems. One system is
dedicated to fire incidents, and notifies the local fire department; the other system is for
incidents and emergencies under the plant's supervision, and notifies the facility's four-
member emergency service team.
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• The alarm system at a payload processing facility is automatically sent to the guardhouse
at the front gate via computer link for various parameters and systems at use in the plant.
The alarm panel indications displayed to the guard allow prompt identification of
potential problems and notification of appropriate personnel.
• An ammonia and urea production plant has an emergency fire phone call-up system tied
into a conference call circuit, which immediately rings emergency phones located in all the
control rooms and various supervisor's offices.
There were a number of concerns about the emergency communication networks within facilities.
Most of the concerns centered on the need for improvement of communication and alarm systems. In
some cases, word-of-mouth was the sole means of communication between operators. The audit teams
recommended installation of additional alarm systems or improvement of existing systems. Frequent
testing of such systems was also cited as a concern. Several suggestions were made to facilities to evaluate
and update telephone and radio systems. A few of the more specific concerns and recommendations were:
• At a lighting equipment production plant, an audit team made a number of
recommendations concerning emergency communication. Because the facility operates 40
hours per week, the facility should consider placing a lock box system containing
emergency information outside the building or surrounding fence. The team also
recommended that the facility install a visual alarm system (i.e., flashing lights) to
supplement the existing audible alarms due to the noise level inherent to the machinery
used.
• At an industrial chemical manufacturing plant, the audit team recommended that the •
facility upgrade its alarm system to communicate the specific nature and location of an
emergency to personnel. Such a measure would speed containment operations when the
alarm sounds.
• Plant emergencies at a paper manufacturing plant are indicated by a series of complicated
whistle signals to alert the entire complex or by telephone to alert a specific person or
group. Half of the workers questioned could not consistently and accurately interpret the
alarm signals. The audit team suggested that the facility simplify their alarm and
communications systems to eliminate employee identification and interpretation problems.
Emergency Response Personnel Training Requirements
Extensive training of response personnel and familiarization with equipment and procedures can
aid in streamlining an actual response incident, and in avoiding injury due to ignorance of proper
procedures. Facilities should ensure that experienced and certified personnel conduct response training at
regular intervals, and offer refresher courses to keep procedures fresh in the minds of responders. Several
CSA reports focused on commendable emergency response personnel training practices, including the
following:
• Visitors to one agricultural chemical manufacturer first report to a reception area where
the visitor must view a ten minute video of certain facility safety rules.
• At a bromide-based chemical production facility, fire brigade staff are sent to a university
fire academy for training. The facility also holds joint training programs with the local
hospital to review various types of medical problems such as bromine chemical burns and
inhalation.
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• One manufacturer of semiconductor materials requires the following courses for members
of the facility hazmat response team: hazardous materials training, confined space and
rope rescue training, coordination with police and fire departments, hazardous materials
exercises, emergency care attendant training, fire brigade training, first responder training,
and more.
There were a variety of concerns about emergency response personnel training requirements.
These concerns primarily focused on the need for facilities to improve existing training for response
personnel. Specific emergency response training is needed if response teams are to be effective. In
particular, some audit teams were concerned that facilities did not train response personnel on the proper
use of emergency response equipment, including PPEs. Incorrect use of such equipment during an actual
emergency could result in potential injury to response personnel. A number of audit team suggested that
facility emergency responders be trained in basic first aid and CPR techniques. Another concern of audit
personnel was that facilities with two or more distinct processes had not cross-trained employees on
emergency response procedures for each process. Confusion among facility personnel and waiting for
trained, off-site responders could cause response delays. Audit team recommended emergency response
personnel be made familiar with all operations. A few of the more specific concerns and recommendations
were:
• With recent cutback in operations and personnel at one manufacturer of printed circuit
boards, the facility lost members of its emergency response team. Although these
positions have been filled and new emergency response personnel briefed on their duties,
not all personnel had sufficiently trained.
• Safety and process training courses alone will not help an employee to help mitigate a
release. One plastics plant offered training in most areas but not in emergency response
procedures. During an accident in 1988, the workers did not know how to respond
properly.
• Formalized training is needed for the response team at a refrigeration facility to
familiarize them with personal protection equipment, emergency response procedures, and
to ensure compliance with worker protection standards.
Follow-up Release Procedures
A response action does not end with release containment and mitigation of the cause of the
accident. Clean-up need to be conducted by licensed personnel from the facility or private contractors.
The facility should also review the accomplishments and problems of the response action, and update
response procedures accordingly. One report focused on existing follow-up release procedures:
• Response plans at an aggregate mining and production facility include provisions for
containing and cleaning up hazardous materials releases.
Audit team members were concerned that a few facilities did not retain records of recovery
operations, and failed to specify contractors responsible for clean-up. An audit team also expressed
concern that a facility did not review its response actions following an incident. A couple of illustrative
examples of these concerns follows:
• A pesticides warehouse lists contractors for recovery and disposal for large spill situations,
but does not indicate if the contractor has either a license or the necessary training for
recovery operations. The audit team recommended that the facility document such
licensing and training.
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• One audit team noted that a facility that manufactured propellants used in automobile air
bags lacked formal procedures for release follow-up and investigation of chemical releases.
A recommendation was made to include such procedures within a formal response plan.
3.7 Community and Facility Emergency Response Planning Activities
The tenth element of the CSA protocol is community and facility emergency response planning
activities, a description of a facility's outreach efforts and activities associated with SARA Title III. There
are two sub-elements of community and facility emergency response planning activities:
• Facility Planning and Outreach Activities with the Community-awareness and
participation in LEPC and CAER activities, as well as open houses, joint training, and
educational programs;
• Local/Community Emergency Response Planning-plan status, degree of coordination with
community in plan preparation, exercise and response procedures, and facility role in non-
facility-related community responses.
Facility Planning and Outreach Activities with the Community
Facility planning and outreach activities with the community are essential elements of effective
emergency response. Facility outreach efforts give local emergency responders a better understanding of
facility activities, which increases local emergency responders' effectiveness in the event of an incident.
Moreover, outreach campaigns make the public more aware of a facility's operations, its potential hazards,
and its safety practices. As public awareness and community/facility interaction increase, so does the
likelihood of a coordinated community emergency plan that identifies each facility's hazards, as well as its
response capabilities and/or needs.
Several chemical safety audit reports commented on facility planning and outreach activities that
support the goal of improving community and facility coordination on emergency response planning.
Many facilities have worked with LEPCs and participated in the Community Awareness and Emergency
Response (CAER) program. In a few cases, facilities have contacted and coordinated emergency response
procedures with the area hospitals that would be providing emergency medical treatment in the event of an
accident. Some facilities have instituted joint training with local responders, while others publish
community newsletters which provide information on plant activities and safety issues. Auditors also
commented on facilities that hosted open houses, distributed information brochures to the surrounding
community, and regularly scheduled tours for visitors. In addition, auditors noted that a few facilities
provided their local fire departments with plant tours and information on chemicals stored. The following
are some illustrative examples:
• An industrial organic and inorganic chemical manufacturing company not only sponsors
the local volunteer fire department, but many of its employees are volunteers as well.
• A pesticide production plant is actively involved in the community through the LEPC.
Three of its representatives served on LEPC steering and public information
subcommittees, and the plant participates in the CAER program even though it is not a
member of the Chemical Manufacturers Association.
• A petroleum refinery plans to send two local fire fighters to an annual, university-
sponsored fire school.
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50
• A semiconductor manufacturer has purchased CAMEO software for the local fire
department and has equipped the fire trucks with Macintosh computers.
• One chemical manufacturer conducts an annual training program for the local volunteer
fire department. This company also has contractors come to the plant to train fire
departments, hazardous materials teams, and emergency management directors and
personnel from the surrounding cities and counties.
• A concrete block and brick manufacturer and a chemical manufacturer have provided the
local fire department with chemical foam, a foam cannon, a new fire truck, and an
asbestos fire suit that will enable responders to approach extremely hot fires.
While many facilities have taken steps to increase community/facility interaction, the chemical
safety audit teams did report a variety of concerns. Some facilities appeared to have little contact with
local emergency responders. Chemical safety auditors suggested that facilities send representatives to
LEPC meetings and increase the level of community/facility interaction through sponsoring community-
oriented events such as open houses. In addition, some auditor reports recommended that facilities invite
outside agencies to on-site visits so that these groups will be familiar with the facilities layouts and
operations. Additionally, auditors noted a few instances where facilities did not have any community
outreach programs and made no references in its emergency plan concerning the documentation and
reporting of spills to state and federal agencies. At certain facilities, the personnel responsible for
ensuring compliance with SARA Title III reporting requirements were not listed in the facility's SOPs.
More specifically, chemical safety auditors noted the following concerns:
• At a soap and detergent manufacturer, audit team members only met with staff level
personnel. Management did not appear to be interested in the audit or in their
responsibilities under SARA Title III. The audit team encouraged management to make
every effort to obtain a comprehensive knowledge of their responsibilities under SARA
Title III and suggested that the facility interact with their SERC and LEPC
representatives.
• Audit team members noted that a chemical manufacturing facility failed to resubmit its
section 312 chemical inventory forms. Furthermore, the same facility did not notify the
SERC and LEPC that extremely hazardous substances were being handled in amounts that
exceeded their threshold planning quantities as required under section 302.
• At an electricity-generating plant, the audit team recommended that the facility make
their CHEMSAFE database available to the SERC, LEPC, local fire departments, and
emergency management agencies since sharing information will help these groups in
planning and response activities.
Local/Community Emergency Response Planning
Without well-coordinated local/community response planning, even the best employee training
programs and operating procedures cannot assure effective, rapid emergency responses. Facilities must do
more than simply develop their own emergency response plans - these plans should be communicated to
and integrated with the appropriate local emergency responders. Ideally, emergency plans will be designed
in conjunction with local officials. Furthermore, simulated drills and exercises should be conducted
regularly with the responders from the community to ensure that emergency procedures are functioning
properly. Neither facilities nor their surrounding communities can afford to let emergency response
procedures become outdated.
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The following are examples of facility programs designed to facilitate a coordinated
facility/community emergency response:
• A soap and detergent manufacturer distributed its emergency plan to and arranged for
response assistance with local fire, police, and health departments, as well as the local
hospital and two emergency medical providers.
• An oil refinery conducted a full-scale simulation exercise in concert with its CAER group,
the LEPC, and the local mutual aid association. An annual community response drill is
planned by individuals representing both the community and industry.
• A pesticide warehouse facility consulted with both fire department inspectors and
hazardous materials specialists on their structural and systems designs. Furthermore, in
response to the most recent evaluation, the facility has revised and coordinated its
emergency response plans with state and local fire department hazardous materials team
and codes inspection personnel.
• An industrial organic chemical manufacturer has worked with outside agencies in
conducting simulated highway and rail transportation accidents involving hazardous
materials. These exercises were put to use when the facility's hazardous materials team
assisted local authorities with a recent railway incident in which several chemicals were
spilled two miles away from the plant.
• A petroleum refinery has formally agreed to assist local officials with developing
neighborhood evacuation plans.
However, a significant number of facilities were identified as needing to coordinate emergency
response plans with LEPCs, fire and police departments, and area hospitals. For certain facilities with
emergency plans already in place, the audit team recommended that plans either be revised or coordinated
with local emergency responders. Furthermore, chemical safety audit team members indicated that more
facilities need to conduct regular emergency exercises with local emergency responders. In several cases,
the audit team recommended a more rigorous analysis of the exercise results to assure that emergency
plans are functioning properly. Some facilities were identified as having significant chemical hazards and
were encouraged to assist LEPCs in conducting vulnerability, risk assessment, and BLEVE analyses. In
many instances, audit teams recommended that facilities periodically reevaluate emergency plans to assure
the immediate notification of the appropriate local authorities in the event of an incident. The following
are two illustrative concerns identified in the audit reports:
• Audit team members suggested that a pesticide and agricultural chemicals manufacturing
plant expand its existing modelling efforts and share the results with the LEPC. In
addition, auditors recommended that a hazard analysis be completed to improve in-plant
risk analysis.
• At a pesticide warehouse facility, the audit team noted that there were no provisions in
the spill emergency plan for releasing information to either state or federal agencies and
that the facility's plans were vague in establishing specific responsibilities for ensuring that
reporting requirement were met.
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3.8 Public Alert and Notification Procedures
The purpose of this element of the protocol is to identify unique procedures that a facility has
employed to alert the public when an accident occurs at a facility and to identify problems that facilities
may be having in establishing public alert and notification procedures. This information should also
indicate facility commitment to safety in the community. The following sub-elements of the protocol will
be addressed:
• Procedures for Public Notification of Releases, including alarm systems, communication
networks, and back-up systems;
• Schedule of Testing for Procedures, including frequency of tests and number and type of
individuals notified;
• History of Notification Procedures and Evaluation, including the type of incident, the
timeliness of public notification, and the number of individuals notified and methods of
public and private emergency notification;
• Community and Facility Contacts, including alternate contacts and telephone number
updates; and
• Facility and Media Interaction, including direct communication links and the history of
past interaction.
Several facilities have incorporated some uniquely comprehensive or effective methods for public
alert and notification. Designating media contacts and establishing procedures for communicating
effectively and quickly with the media during and after an emergency is one way many facilities plan to
notify the public of an emergency. Other facilities coordinate with fire and police personnel who go door
to door to notify nearby residents in the event of an emergency. In addition, many facilities made good
efforts to coordinate public alert and notification planning with Local Emergency Planning Committees
(LEPCs). The following examples illustrate innovative or particularly effective procedures that have been
developed by various facilities:
• Emergency procedures at a chemical manufacturer require that updates be made every
fifteen minutes to the local emergency communications center.
• An oil refinery has established procedures that provide for public notification to be made
over the radio, by telephone, and broadcast over the city's emergency broadcast system. In
addition, the facility set up a telephone hotline to make information about a release
accessible to the public.
• Another chemical manufacturer issues all employees wallet cards with listings of plant and
community emergency telephone numbers to notify in the event of an emergency.
• Another oil refinery has developed computer software to direct the emergency coordinator
to notify the appropriate state and local agencies.
• A third chemical manufacturer has installed an automatic-dial emergency dial notification
system for notifying nearby residents of an emergency situation.
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• A fertilizer manufacturer has access to a public warning system operated through local
radio stations, equipped with back-up electrical generators if primary power supplies are
disrupted, as well as high-powered voice and siren systems; in addition, the facility's
release prevention, control, and countermeasures plan outlines steps that should be taken
by the incident commander should evacuating some part of the surrounding community be
necessary.
• A third oil refinery is part of a two-way radio system between 21 industrial and six state,
local, and private parties; the system is tested daily and provides notification of upsets as
well as actual releases.
• A metal refinery works with the local fire department and sheriffs office to alert nearby
residents of an incident through a command conference phone system that all residents
have access to through their residential telephones; in addition, the fire department can
telephone all residents simultaneously to notify them of an incident.
• A water treatment facility keeps a two-way hand-held radio tuned to the local fire
department's frequency in the facility's control room; in addition, plans are in place to
initiate emergency broadcasts through a 24-hour local radio station as well as sending fax
transmissions to local radio and television stations; the emergency broadcast system is
tested weekly.
The reports examined for this analysis also indicated that many facilities do not have adequate
public alert and notification procedures in place. And, a few facilities rely strictly on federal, state, and
local government agencies and entities such as the local fire or police departments to alert the public of a
release, rather than developing additional alert and notification procedures for their own facility. In
general, therefore, it was recommended that some kind of public alert and notification procedures be
established for those facilities that do not have such procedures and especially for those that are located in
communities or areas that have no public alert mechanisms. The following are some examples:
• A facility at which synthetic resins are manufactured has designated a chain-of-command
and a list of agencies to contact in the event of an accident, but has no specific procedures
for public notification.
• A release that occurred at an electronics facility revealed a lack of coordination between
the facility and public information and response activities and public concern was
expressed over getting information about the release of an extremely hazardous substance .
before it reached its reportable quantity.
• During a release incident that occurred at an oil refinery, no initial notification was made
either by siren or through direct phone calls.
• At another facility where pulp and paper products are manufactured, the LEPC and
SERC expressed concern, prior to the audit, about the tardiness exhibited by the facility in
notifying the public about a release that had occurred.
Another problem evident at some facilities is that the equipment or methods that would be used
to alert the public could be made more effective. Several facilities rely solely on the 911 system but do not
have a warning siren, horn, or some other kind of audible warning system. A few facilities have audible
alarm systems that are only manually operated and no provisions have been made for an emergency
occurring after hours. In addition, back-up equipment is needed at many facilities to supplement an
equipment failure and response procedures for nearby residents should be published. For example:
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• Residents who live nearby a facility at which intermediate chemicals for use in bleach
products are manufactured reported being able to hear the warning siren or horn, but
because they were never informed of proper response procedures, they do not know what
to do when they hear it.
In general, it was recommended that some kind of public alert and notification procedures should
be established for those facilities that do not have them. Other suggestions included improving media
relations by designating a media spokesperson at the facility and a local media contact to notify concerning
an emergency, making public address systems such as sirens or horns more audible and less confusing,
ensuring that nearby residents know what to do if they hear a warning siren or horn, and regularly
conducting tests of warning systems to ensure their effectiveness. Comprehensive lists of the appropriate
response personnel, agencies, and industrial neighbors to contact during an emergency should also be
made readily available and posted outside facility buildings for easy access after-hours. Finally, it was often
recommended that appropriate facility personnel meet with local fire and police officials and other
emergency response personnel to define individual responsibilities as well as to communicate and
coordinate with LEPCs and SERCs and meet with nearby residents. The following are illustrative
examples of these concerns and recommendations:
• Testing procedures used by a facility at which gasoline is produced are confusing because
the loudspeakers for the warning siren lack clarity; this sometimes indicates that an actual
emergency is taking place when the system is only being tested.
• For one facility at which a release has already occurred while no public notification
systems were in place, it was recommended that a vulnerability zone be designated around
the facility and that nearby residents be informed of the parameters of this zone.
• For another facility, it was recommended that formal procedures be established for
relaying information from the incident scene to the media liaison in order to mitigate the
spread of rumors and to ensure that accurate, current information about an incident is
provided.
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4.0
STATUS OF CSA PROGRAM IMPLEMENTATION
This chapter focuses on the status of the CSA program as well as region-specific information
about unique CSA implementation and outreach activities. The progress of the program at the regional
level is measured by the number of audits performed and completed audit reports, as well as training and
workshop participation. Overall, there was a noticeable increase in the number of audits conducted and
audit reports completed in FY 91 over FY 89 and FY 90.
4.1 Regional Implementation
The following chart shows the status of the Chemical Safety Audit program from FY 89 through
FY 91. The columns indicate the number of audits conducted by each region, the number of final audit
reports received by CEPPO from each region as of September 30, 1991, and the number of EPA regional,
AARP, and TAT personnel who have attended the CSA training workshops, respectively.
CHART OF REGIONAL CSA ACHIEVEMENTS
REGION
AUDITS
REPORTS
TRAINING
1
11
11
7
2
8
5
20
3
12
11
30
4
25
19
64
5
11
4
19
6
14
14
25
7
4
3
9
8
13
13
21
9
12
11
15
10
13
10
11
For FY 89 and FY 90, EPA set identical CSA targets for each regional office. Each regional
office was to complete four audits in both FY 89 and FY 90. The Strategic Targeted Activities for Results
System (STARS) is used to track the regions' progress toward these targets. In FY 89, only five of the
regions accomplished their goal, although a total of 32 audits were conducted nationally. All but one of
the regions conducted at least four audits in FY 90, and Region 4, Region 5, and Region 6 surpassed their
targets. Only Region 7 did not conduct any audits in either FY 89 or FY 90; Region 7 did conduct four
audits in FY 91.
For FY 91, EPA changed its method for tracking chemical safety audits, making the targets
region-specific and requiring regions to conduct an audit and finalize the audit report. EPA set individual
targets for the number of audits and audit reports to be completed by each region to better reflect regional
priorities and capabilities. For the ten regions, a total of 40 audits was targeted for FY 91, with each
region required to complete from three to six audits. Six regional offices achieved or exceeded their
individual targets; Region 4 conducted audits and submitted audit reports for twelve facilities during FY
91. Regions 2, 5, 9, and 10 did not reach their targets during FY 91; in each case the Region conducted
enough audits, but has not yet submitted the final audit reports to headquarters.
The FY 1990 Status Report identified a number of concerns arising from the chemical safety audit
reports completed by the regions. In the last year, there has been an overall improvement in the report
preparation process, as a result of increased input from state and local officials participating in audits and
the dramatic increase in the percentage of audit reports completed for the audits conducted this year. In
addition, as documented in Chapter 3, the reports are identifying a number of unique and successful
facility safety practices, as well as documenting various trends in more problematic areas.
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Nevertheless, there remain several outstanding concerns about the audit reports completed to
First, many audit reports contain recommendations for the facility without providing any
documentation of why the recommendation was made. In doing so, the audit team makes
it more difficult for headquarters to identify problematic chemical process safety issues,
and for the facility, LEPCs, and SERCs to understand and address the specific concerns of
the audit team. As an example, one audit team recommended that the facility should
label and/or color-code all of its storage tanks and process piping, but the report did not
indicate whether the facility has any existing labeling or color-coding policy or whether
this policy is followed for some but not all tanks and piping at the facility. This type of
supporting information should be included in either the body of the report or the
conclusions section.
In a related concern, many of the audit reports comment on facility practices which appear
to be unsafe or improper, and yet the reports do not provide a recommendation to the
facility on this topic, or explain why such a recommendation was not made. Once again,
this makes it more difficult for headquarters to identify problematic chemical process
safety issues, and for the facility, LEPCs, and SERCs to understand and address the
specific concerns of the audit team.
In addition, some regional offices have been attaching a separate technical assistance team
report on the audit, discussing issues and practices that are not addressed in the body of
the report. This creates an opportunity for conflicting statements to appear in the report,
and as a result, headquarters recommends that all audit team members work together to
develop a single report.
Some of the regional offices have displayed a tendency to incorrectly focus their attention
on the accident(s) or release(s) that resulted in the facility's selection, rather than to
conduct a review of the facility's safety practices for the hazardous substances present.
Some of the regional offices have also been including an excessive amount of information
in attachments to their reports. This documentation should only be included in the final
report if it provides information on unique facility safety practices.
In addition, many of the reports reference industry-specific, technical terminology or
acronyms which would be unfamiliar to the general reader. Audit teams should remember
that the reports are available to the public, and define all such terms used in the audit
report.
Finally, while adherence to the structure of the CSA protocol, designed to simplify the
identification of important chemical process safety issues and practices by EPA, has been
improving, a number of audit teams continue to describe safety practices in unrelated
sections of the report. As an example, in one audit report a discussion of a facility's
emergency planning coordination with the community (element 10 of the protocol) was
improperly located in the section on chemical accident prevention (element 7 of the
protocol).
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4.2 Regional Activities
This section reviews the principal accomplishments of the CSA program at the regional level and
identifies notable successes in implementation. These accomplishments focus on publicizing the CSA
program, using the CSA program to enhance Title III activities, and supporting the development of state
CSA programs or capabilities. Publicizing CSA program activities has helped increase state and local
interest and participation. Most regional offices actively seek LEPC and SERC participation in audits. To
foster this participation, many regions have encouraged state and local officials to attend EPA's CSA
workshops. The following is a list of CSA-related activities initiated by the regional offices which go
beyond their necessary CSA program responsibilities:
• Region 4 is planning to encourage other program offices within the regional office to
require companies to conduct chemical safety audits as part of their enforcement
settlements. The regional CEPP staff will provide technical assistance in oversight of such
settlements. At the request of the South Carolina SERC, Region 4 held an EPA-
sponsored CSA workshop in Charleston in FY 91, rather than in Atlanta as originally
planned; over 30 state and local officials attended. Region 4 also plans to supplement
their CSA efforts by conducting its own chemical safety audit workshop in FY 92 at the
request of the North Carolina SERC. As resources will allow, Region 4 will present this
workshop in other states. Region 4 also issues press releases whenever its CSA team
conducts an audit or issues a final audit report.
• Region 5 initiated an audit component to its enforcement settlements. When one facility
could not afford the large penalty it was assessed due to a release, Region 5 approved a
reduced payment schedule and required the company to perform chemical safety audits for
all three of its facilities.
• Region 6 made a presentation on the CSA program at the Region 6 SERC conference.
The Region hopes to receive more facility referrals from local and state officials to
simplify the facility selection process. Under the auspices of the Integrated Border
Environment Plan with Mexico, the Region will be conducting two chemical safety audits
at maquiladora ("across the border") facilities. Region 6 is also considering incorporating
chemical safety audits into Title III enforcement settlements. As part of the settlement,
the facility would be required to conduct an audit and submit an audit report to the
Region using the CSA protocol as a guide. One regional CSA team member would
participate in the audit as an observer and to provide assistance, if necessary.
• Region 8 is currently assisting the Colorado SERC in providing a series of CSA
workshops to LEPC members throughout the state. They have also visited the Colorado
Chamber of Commerce, LEPCs, and SERCs throughout the Region to request state and
local participation on CSA audit teams. Additionally, Region 8 generates a questionnaire
asking the audited facility if recommendations from the CSA report have been
implemented six and twelve months after the audit. The regional contact noted an 80-85
percent response rate by facilities in implementing audit recommendations. Region 8 also
publishes a newsletter which advertises the CSA program and the new provisions of the
Clean Air Act in order to increase state and local interest.
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Region 9, with support from CEPPO, is providing assistance to Nevada in developing its
own chemical safety audit program, which will conduct audits under the authority of a new
state accident prevention law. The new law mandates an inspection of a facility that has a
chemical accident or near miss, or poses a threat to public health and safety. Region 9 is
also involved with pre-audit introductory meetings with local fire and police department
personnel, county and regional planners, and other members of LEPCs. The purpose of
these meetings is to introduce the community to the CSA program and to assess the level
of interaction between responders and the audited facility. In FY 91, at the request of
officials from San Diego County and the State of California, a CSA workshop was held in
San Diego. A one-day workshop on the implementation of California's Risk Management
Plan Program followed the CSA workshop.
Region 10 is acting as a referral center for facilities to contact with questions concerning
safety practices. For example, when a facility contacts the region with questions about a
particular element of the CSA protocol, Region 10 will refer it to another facility which
has been successful in the relevant areas of the protocol. Region 10 provides another
referral service concerning audit expectations. After initial audit notification, a facility can
prepare itself by contacting previously audited facilities. Also, Region 10 targets areas
where LEPCs are no longer active and uses the CSA process to recommend that the
LEPCs become more involved in emergency response exercises with the audited facility
within the next six months. Region 10 is also coordinating with states in the region in
developing state CSA programs.
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APPENDIX A
OUTLINE OF THE CHEMICAL SAFETY AUDIT PROTOCOL
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APPENDIX A
OUTLINE OF THE CHEMICAL SAFETY AUDIT PROTOCOL
1.0 INTRODUCTION
2.0 SUMMARY OF FINDINGS/CONCLUSIONS
3.0 BACKGROUND
3.1 General Facility and Audit Information
3.2 Purpose of the Audit and Facility Selection Process
3.3 Audit Methodology
4.0 FACILITY BACKGROUND INFORMATION
4.1 Site and Surrounding Area Description
4.1.1 Facility Profile
4.1.2 Site Topography and Meteorological Conditions
4.1.3 Site Access
4.1.4 Special/Sensitive Populations and Environments
4.1.5 Regional Demographics
4.1.6 Identification of Vulnerable Zones
5.0 CHEMICAL HAZARDS
5.1 Overview of Hazards for Chemical(s) Being Audited
5.2 Facility Management of Chemical Hazard Data
6.0 PROCESS INFORMATION FOR HAZARDOUS CHEMICALS
6.1 Storage and Handling
6.1.1 Storage Systems
6.1.2 Shipping/Receiving
6.1.3 Material Transfer
6.2 Process Description
6.2.1 Overview of Processing Steps and Operating
Procedures
6.2.2 General Description of Process Equipment
Capacity
6.2.3 Back-ups and Redundancy
6.2.4 Process Parameter Monitoring
6.2.5 Environmental Monitoring
6.3 Process Hazards
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7.0 CHEMICAL ACCIDENT PREVENTION
7.1 Management Activities
7.1.1 Corporate Role in Facility Process Safety
Management
7.1.2 Facility Role in Process Safety Management
7.1.3 Audit Activities and Procedures
7.2 Process Operation and Maintenance
7.2.1 Standard Operating Procedures
7.2.2 Training Practices
7.2.3 Equipment Maintenance Procedures
7.2.4 Instrument Maintenance
7.3 Hazard Evaluation and Modeling
7.3.1 Hazard Evaluation
7.3.2 Modeling
7.4 Release Prevention Systems
7.5 Mitigation Systems
8.0 ACCIDENT RELEASE INCIDENT INVESTIGATION
8.1 History of Accidental Releases/Incidents
8.2 Facility Investigation Procedures
9.0 FACILITY EMERGENCY PREPAREDNESS AND PLANNING ACTIVITIES
9.1 Facility Emergency Response Plan
9.2 Emergency Response Exercises and Simulations
9.3 Fire, Evacuation, and Rescue Corridors
9.4 Emergency Equipment Provisions
9.5 Emergency Response Chain of Authority
9.6 Emergency Response Management Procedures
9.7 Emergency Communication Network within the Facility
9.8 Emergency Response Personnel Training Requirements
9.9 Follow-up Release Procedures
10.0 COMMUNITY AND FACILITY EMERGENCY RESPONSE PLANNING ACTIVITIES
10.1 Facility Planning and Outreach Activities with Community
10.2 Local/Community Emergency Response Planning
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11.0 PUBLIC ALERT AND NOTIFICATION PROCEDURES
11.1 Procedures for Public Notification of Releases
11.2 Schedule for Testing Procedures
11.3 History of Notification Procedures and Evaluation
11.4 Community and Facility Contacts
11.5 Facility and Media Interaction
12.0 CONCLUSIONS
13.0 RECOMMENDATIONS
APPENDICES
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APPENDIX B
LIST OF CHEMICAL SAFETY AUDITS
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APPENDIX B
LIST OF CHEMICAL SAFETY AUDITS
as of September 30,1991
REGION
DATE OF AUDIT
03/22/89
04/10-14/89
08/03/89
08/07-11/89
11/29/89
03/20/90
06/20-21/90
09/12-13/90
12/17-18/90
05/13-14/91
07/24-25/91
08/21-24/89
09/11/89
01/09-10/90
01/11-12/90
07/31 - 08/01/90
09/10-11/90
03/11-13/91
06/03-05/91
08/05-07/91
07/30-08/03/89
08/14-16/89
09/11-12/89
09/25-26/89
01/31 & 02/02/90
02/12-16/90
03/26-28/90
08/20-22/90
01/07-10/91
04/15-16/91
04/23-25/91
05/21-23/91
REPORT STATUS NAME OF FACILITY
X1
X
X
X
X
X
X
X
X
X-D2
X-D
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X-D
X-D
Polysar, Inc., Indian Orchard, MA
W.R. Grace, Nashua, NH
Fall River Treatment Plant, Fall River, MA
Upjohn Co., North Haven, CT
Bradford Soap Works, W. Warwick, RI
Jones Chemicals, Merrimac, NH
Monet Crystal Brands, Pawtucket, RI
LCP Chemicals, Orrington, ME
Hercules, Inc., Chicopee, MA
Pacific Anchor, Cumberland, RI
Rising Paper Co., Housatonic, MA
BASF, Rensselaer, NY
Xerox Corporation, Webster, NY
Du Pont Agrichemicals, Manati, PR
Bacardi Rum, San Juan, PR
Goodyear, Niagara Falls, NY
BASF, Washington, NJ
C.P. Chemicals, Sewaren, NJ
3M/O-Cel-O, Tonawanda, NY
Schenectady Chemicals, Schenectady, NY
Rhone-Poulenc, Charleston, WV
LCP Chemicals, Inc., Moundsville, WV
Purolite Co., Philadelphia, PA
Carl Falkenstein, Inc., Philadelphia, PA
Automata, Sterling, VA
Mobay Chemical, New Martinsville, WV
Olin Chemical, Charleston, WV
Occidental Chemicals, Delaware City, DE
Rohm & Haas, Bristol, PA
Anzon Lead, Philadelphia, PA
DuPont Textile Fibers, Waynesboro, VA
SCM Chemicals, Baltimore, MD
1 An "X" indicates that the final report has been received and a profile has been completed.
2An "X-D" indicates that the final report for this audit was received by EPA Headquarters after August
31, 1991, and the results are not included in the 1991 Chemical Safety Audit Program Status Report.
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REGION DATE OF AUDIT
REPORT STATUS NAME OF FACILITY
03/20-24/89 X
05/01-05/89 X
07/11/89 & 08/03-04/89 X-D
07/18-20/89 X-D
08/17/89 & 09/11-15/89
02/12-13/90 X
02/26-03/02/90 X-D
04/04-05/90 X
05/08-11/90
09/11-13/90
10/26/90 X
11/29/90 X
12/4-5/90 X
12/4-5/90 X
12/12/90 X
01/07-10/91 X-D
01/22-25/91 X-D
01/30-31/91 X
02/20-21/91 X
02/25-26/91 X
03/04-08/91
03/18-22/91
03/27/91 X
04/02/91 X-D
08/26-30/91
07/25-28/89 X
08/08-11/89 X
09/15/89
03/05/90
03/26-30/90
04/14-18/90 X
06/11-15/90
07/16-19/90
03/18-20/91
05/20-22/91
08/12-14/91 X-D
06/13/89 X
08/30-31/89 X
08/15-16/89 X
09/12-13/89 X
10/16-17/89 X
11/06-07/89 X
11/14/89 X
01/17-18/90 X
04/17-19/90 X
03/05-06/91 X
03/20-22/91 X-D
05/01-03/91 X
07/09-11/91 X-D
08/27-29/91 X-D
Royster Phosphate, Piney Point, FL
Olin Corporation, Charleston, TN
Armco Steel, Ashland, KY
Kerr McGee, Hamilton, MS
Texas Gulf, Aurora, NC
Photocircuits, Atlanta, Peachtree City, GA
Kemira, Inc., Savannah, GA
Astrotech, Titusville, FL
Cardinal Chemical Co., Columbia, SC
Tennessee Chemical Co., Copper Hill, TN
Kason Industries, Newnan, GA
C & S Chemical Company, Austell, GA
Carolina Solite, Norwood, NC
Oldover Corporation, Albemarle, NC
Tull Chemical Company, Oxford, AL
Peridot Chemical Company, Augusta, GA
Aqua Tech/Groce Labs, Duncan, SC
Virtex Chemicals, Bristol, TN
Water Treatment Plant, Cape Coral, FL
Canal Pumping Station, Cape Coral, FL
Kentucky American Water, Lexington, KY
Drexel Chemical Co., Tunica County, MS
Columbia Organics, Camden, SC
Armstrong Glass, Atlanta, GA
B. F. Goodrich, Calvert City, KY
Koppers, Cicero, IL
Best Foods, Chicago, IL
Shell Oil, Wood River, IL
Eli Lilly, Clinton, IN
Anderson Development, Adrian, MI
General Electric Plastics, Mt. Vernon, IN
Tremco, Inc., Cleveland, OH
Flexel, Inc., Covington, IN
Detroit Edison, River Rouge, MI
Nalco Chemical Company, IL
SCM Chemicals, Astabula, OH
Western Extrusion, Carrollton, TX
Great Lakes Chemical Co., El Dorado, AR
Farmland Industries, Enid, OK
Fermenta ASC Corporation, Houston, TX
Chief Supply, Haskell, OK
Phillips Petroleum, Pasadena, TX
Texas Instruments, Dallas, TX
Exxon Refinery, Baton Rouge, LA
Olin Chemicals, Lake Charles, LA
Sid Richardson Carbon Co., Borger, TX
ARCO Chemical, Channelview, TX
Citgo Refinery, Lake Charles, LA
International Paper, Pine Bluff, AR
Agricultural Minerals, Catoosa, OK
-------
REGION
7
10
DATE OF AUDIT
10/25/90
11/20/90
05/01/91
07/31/91
05/02-04/89
06/13-15/89
08/15-17/89
03/27/90
05/15-17/90
06/26-29/90
08/27-31/90
11/01/90
02/06-07/91
02/19-21-91
04/30-05/03/91
05/29-31/91
09/29-30/91
05/12-13/89
07/25-27/89
08/16-17/89
09/07-08/89
04/17-20/90
06/19-22/90
07/17-20/90
09/10-16/90
04/09-12/91
07/16-19/91
08/20/91
08/21-23/91
07/27/89
08-10/893
09/12-15/89
03/19-23/90
04/23-27/90
05/14-18/90
09/24-28/90
01/08/91
01/15-18/91
03/18-22/91
04/22-26/91
07/24-26/91
08/05-09/91
REPORT STATUS NAME OF FACILITY
X
X
X-D
X
X
X
X
X
X
X
X
X
X
X
X
X-D
X
X
X
X
X
X
X
X
X
X-D
X-D
X
X
X
X
X-D
X
X
X-D
X
X-D
ICI Americas, Omaha, NE
Jacobson Warehouse, Des Moines, LA.
ABB Power Transformers, St. Louis, MO
Hydrozo, Inc., Lincoln, NE
Phillips Refinery, West Bountiful, UT
Chevron Chemical, Rock Springs, WY
Western Forge, Colorado Springs, CO
Koppers Industries, Denver, CO
Amoco Production Company, Powell, WY
Amoco Casper Refinery, Casper, WY
Western Zirconium, Ogden, UT
Jemm Plating, Co., Denver, CO
SAS Circuits, Littleton, CO
Kodak-Colorado Division, Windsor, CO
Col. Falls Aluminum, Columbia Falls, MT
Syncom Techologies, Mitchell, SD
LaRoche Industries, Inc., Orem, UT
Nunes Cooling Inc., Salinas, CA
Unocal Chemical, Brea, CA
Eticam of Nevada, Fernley, NV
Coronado Generator, St. Johns, AZ
Ultramar, Inc., Wilmington, CA
Magma Copper, Inc., San Manuel, AZ
Pioneer Chlor Alkalai, Henderson, NV
Dole Packaged Foods, Honolulu, HI
Motorola, Phoenix, AZ
Dow Chemicals, Pittsburg, CA
Pioneer Chlor Alkalai, Henderson, NV
Timet Corporation, Henderson, NV
All Pure Chemical Company, Kalama, WA
ITT Rayonier, Port Angeles, WA
McWhorter Northwest, Portland, OR
BP Oil Company, Ferndale, WA
FMC Corporation, Pocatello, ID
Neste Resins, Springield, OR
Unocal Chemicals, Kenai, AK
Occidental Chemicals, Tacoma, WA
Chevron USA, Richmond Beach, WA
James River Corporation, Clatskanie, OR
Potlatch Corporation, Lewiston, ID
Great Western Chemical Co., Nampa, ID
Boise Cascade Mill, Wallula, WA
The audit at ITT Rayonier consisted of three separate visits during a three month period.
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APPENDIX C
HAZARDOUS SUBSTANCES EXAMINED IN CHEMICAL SAFETY AUDITS
-------
APPENDIX C
Acetic Acid:
64-19-7
HAZARDOUS SUBSTANCES EXAMINED IN CHEMICAL SAFETY AUDITS
(including Chemical Abstract Service Numbers)
Best Foods, Region 5
Acetone:
67-64-1
Carolina Solite, Region 4
General Electric Plastics, Region 5
Western Forge, Region 8
Adipic Acid:
124-04-9
Hercules Chemicals, Region 1
Aluminum Sulfate:
10043-01-3
C & S Chemicals, Region 4
Ammonia:
7664-41-7
Hercules Chemicals, Region 1
Monet, Region 1
Original Bradford Soap Works, Region 1
Upjohn, Region 1
W.R. Grace, Region 1
Olin, Region 3
Royster Phosphates, Region 4
Best Foods, Region 5
Citgo Refinery, Region 6
Farmland Industries, Region 6
Fermenta ASC, Region 6
Chevron, Region 8
Western Zirconium, Region 8
Dole Packaged Food, Region 9
Nunes Cooling, Region 9
Unocal Chemicals, Region 9
ITT Rayonier, Region 10
Unocal Chemicals, Region 10
Ammonium Hydroxide:
1336-21-6
Jones Chemical, Region 1
Automata, Region 3
Carl Falkenstein, Region 3
SAS Circuits, Region 8
Antimony:
7440-36-0
Monet, Region 1
Arsenic Trioxide:
1327-53-3
Fermenta ASC, Region 6
-------
Benzene:
71-43-2
Upjohn, Region 1
Exxon Refinery, Region 6
Amoco Refinery, Region 8
Bromine:
7726-95-6
Purolite, Region 3
Great Lakes Chemical, Region 6
1,3-Butadiene:
106-99-0
Phillips 66 Houston, Region 6
Butyl Acetate:
123-86-4
Western Forge, Region 8
Cadmium:
7440-43-9
Monet, Region 1
Carbaryl:
63-25-2
Jacobson Warehouse, Region 7
Carbon Tetrachloride:
56-23-5
Oxychem, Region 3
Chlorine:
7782-50-5
Fall River Waste Treatment, Region 1
Jones Chemical, Region 1
LCP Chemicals, Region 1
Bacardi Rum, Region 2
Du Pont Agrichemicals, Region 2
LCP Chemicals, Region 3
Mobay, Region 3
Olin, Region 3
Oxychem, Region 3
Cape Coral Pumping Station, Region 4
Cape Coral Water Treatment, Region 4
Columbia Organic Chemicals, Region 4
Olin, Region 4
Photocircuits, Region 4
Best Foods, Region 5
Citgo Refinery, Region 6
Farmland Industries, Region 6
Fermenta ASC, Region 6
Great Lakes Chemical, Region 6
Olin, Region 6
Phillips 66, Region 6
Sid Richardson Carbon, Region 6
Chevron, Region 8
Columbia Falls Aluminum, Region 8
-------
Chlorine (cont'd):
Phillips 66, Region 8
Western Zirconium, Region 8
Coronado Generating Station, Region 9
Dole Packaged Food, Region 9
Pioneer Chlor Alkali, Region 9
All Pure Chemical, Region 10
BP Oil, Region 10
ITT Rayonier, Region 10
Chloroform:
67-66-3
Rhone-Poulenc, Region 3
Chromic Acid:
11115-74-5
Kason Industries, Region 4
Phillips 66, Region 8
Copper Cyanide:
544-92-3
Carl Falkenstein, Region 3
Kason Industries, Region 4
Creosote:
8001-58-9
Koppers, Region 5
Koppers, Region 8
Cumene Hydroperoxide:
80-15-9
General Electric Plastics, Region 5
Cyclohexane:
110-82-7
Phillips 66, Region 6
Cyclohexanone:
108-94-1
Syncom Technologies, Region 8
o-Dichlorobenzene:
95-50-1
Mobay, Region 3
Dinitrotoluene (mixed isomers):
25321-14-6
Mobay, Region 6
Epichlorohydrin:
106-89-8
Hercules Chemicals, Region 1
Ethyl Acrylate:
140-88-5
Rohm & Haas, Region 3
McWhorter, Region 10
-------
Ethylene Dichloride:
107-06-2
BASF (NY), Region 2
Kodak, Region 8
Ethylene Oxide:
75-21-8
BASF (NJ), Region 2
Ferric Chloride:
7705-08-0
Jones Chemical, Region 1
Chevron, Region 10
Formaldehyde:
50-00-0
Hercules Chemicals, Region 1
Farmland Industries, Region 6
Neste Resins, Region 10
Formic Acid:
64-18-6
Hercules Chemicals, Region 1
Hydrazine:
302-01-2
Astrotech, Region 4
Virtex Chemical, Region 4
Hydrochloric Acid:
7647-01-0
Jones Chemical, Region 1
LCP Chemicals, Region 1
Monet, Region 1
Original Bradford Soap Works, Region 1
Upjohn, Region 1
BASF (NY), Region 2
Automata, Region 3
Carl Falkenstein, Region 3
LCP Chemicals, Region 3
Mobay, Region 3
Purolite, Region 3
Rhone-Poulenc, Region 3
Olin, Region 4
Photocircuits, Region 4
Fermenta ASC, Region 6
Phillips 66, Region 8
Western Extrusion, Region 6
JEMM Plating, Region 8
SAS Circuits, Region 8
Western Forge, Region 8
Pioneer Chlor Alkali, Region 9
Chevron, Region 10
Hydrogen Cyanide:
74-90-8
W.R. Grace, Region 1
-------
Hydrogen Fluoride:
7664-39-3
Columbia Falls Aluminum, Region
Phillips 66, Region 8
Motorola, Region 9
Ultramar, Region 9
BP Oil, Region 10
Hydrogen Peroxide:
7722-84-1
Olin, Region 3
ITT Rayonier, Region 10
Hydrogen Sulfide:
7783-06-4
Royster Phosphates, Region 4
Citgo Refinery, Region 6
Sid Richardson Carbon, Region 6
Amoco Production, Region 8
Amoco Refinery, Region 8
Hydroquinone:
123-31-9
Du Pont Agrichemicals, Region 2
Rohm & Haas, Region 3
Lead:
7439-92-1
Monet, Region 1
Maleic Anhydride:
108-31-6
McWhorter, Region 10
Mercury:
7439-97-6
LCP Chemicals, Region 1
LCP Chemicals, Region 3
Oxychem, Region 3
Olin, Region 4
Methanol:
67-56-1
Du Pont Agrichemicals, Region 2
Mobay, Region 3
Tull Chemicals, Region 4
General Electric Plastics, Region 5
Fermenta ASC, Region 6
Neste Resins, Region 10
Methomyl:
16752-77-5
Jacobson Warehouse, Region 7
Methyl Chloride:
74-87-3
Fermenta ASC, Region 6
-------
Methylene Chloride:
75-09-2
Chief Supply, Region 6
Great Lakes Chemical, Region 6
SAS Circuits, Region 8
Western Forge, Region 8
Methyl Ethyl Ketone:
78-93-3
Carolina Solite, Region 4
SAS Circuits, Region 8
Syncom Technologies, Region 8
Western Forge, Region 8
Methyl Isobutyl Ketone
108-10-1
Western Zirconium, Region 8
Methyl Isocyanate:
624-83-9
Rhone-Poulenc, Region 3
Methyl Methacrylate
80-62-6
Rohm & Haas, Region 3
Monomethylamine:
74-89-5
Rhone-Poulenc, Region 3
Monomethyl Hydrazine:
60-34-4
Astrotech, Region 4
Naphthalene:
91-20-3
Koppers, Region 5
Exxon Refinery, Region 6
Nickel:
7440-02-0
Monet, Region 1
Nickel Chloride:
7718-54-9
Monet, Region 1
Kason Industries, Region 4
Nickel Sultate:
7786-81-4
Monet, Region 1
Kason Industries, Region 4
-------
Nitric Acid:
7697-37-2
Jones Chemical, Region 1
Bacardi Rum, Region 2
Automata, Region 3
Mobay, Region 3
Kason Industries, Region 4
Western Extrusion, Region 6
JEMM Plating, Region 8
Kodak, Region 8
Western Forge, Region 8
Nitric Oxide:
10102-43-9
Eticam, Region 9
Nitrogen Dioxide:
10102-44-0
Mobay, Region 3
Eticam, Region 9
Perchloroethylene:
127-18-4
Phenol:
108-95-2
Western Forge, Region 8
General Electric Plastics, Region 5
Neste Resins, Region 10
bis-Phenol:
4418-66-0
General Electric Plastics, Region 5
Phosgene:
75-44-5
Upjohn, Region 1
Mobay, Region 3
Rhone-Poulenc, Region 3
General Electric Plastics, Region 5
Great Lakes Chemical, Region 6
Olin, Region 6
Phosphine:
7803-51-2
Jacobson Warehouse, Region 7
Phosphoric Acid:
7664-38-2
Royster Phosphates, Region 4
Western Extrusion, Region 6
Chevron, Region 8
Kodak, Region 8
Phosphorus Pentoxide:
1314-56-3
Columbia Organic Chemicals, Region 4
-------
Phosphorus Trichloride:
7719-12-2
W.R. Grace, Region 1
Phthalic Anhydride:
85-44-9
Koppers, Region 5
Potassium Cyanide:
151-50-8
Monet, Region 1
Kason Industries, Region 4
JEMM Plating, Region 8
Potassium Hydroxide:
1310-58-3
Carl Falkenstein, Region 3
Oxychem, Region 3
Kason Industries, Region 4
Propylene Oxide:
75-56-9
BASF (NJ), Region 2
Sodium Azide:
26628-22-8
Virtex Chemical, Region 4
Sodium Cyanide:
143-33-9
W.R. Grace, Region 1
Carl Falkenstein, Region 3
Columbia Organic Chemicals, Region 4
JEMM Plating, Region 8
Sodium Fluoroacetate:
62-74-8
Tull Chemicals, Region 4
Sodium Hydroxide:
1310-73-2
Fall River Waste Treatment, Region 1
Hercules Chemicals, Region 1
Jones Chemical, Region 1
LCP Chemicals, Region 1
Monet, Region 1
Original Bradford Soap Works, Region 1
Bacardi Rum, Region 2
Du Pont Agrichemicals, Region 2
Automata, Region 3
Carl Falkenstein, Region 3
LCP Chemicals, Region 3
Olin, Region 3
Oxychem, Region 3
Purolite, Region 3
Cape Coral Water Treatment, Region 4
Kason Industries, Region 4
Olin, Region 4
-------
Sodium Hydroxide (cont'd):
Photocircuits, Region 4
Tull Chemicals, Region 4
Virtex Chemical, Region 4
Best Foods, Region 5
Koppers, Region 5
Exxon Refinery, Region 6
Fermenta ASC, Region 6
Great Lakes Chemical, Region 6
Olin, Region 6
Kodak, Region 8
Phillips 66, Region 8
Dole Packaged Food, Region 9
Pioneer Chlor Alkali, Region 9
All Pure Chemical, Region 10
ITT Rayonier, Region 10
Sodium Hypochlorite:
10022-70-5
Jones Chemical, Region 1
LCP Chemicals, Region 1
Du Pont Agrichemicals, Region 2
LCP Chemicals, Region 3
Fermenta ASC, Region 6
All Pure Chemical, Region 10
Sodium Nitrite:
7632-00-0
Virtex Chemical, Region 4
Styrene:
100-42-5
Polysar, Region 1
Purolite, Region 3
. Phillips 66, Region 6
Sulfur Dioxide:
7446-09-5
Jones Chemical, Region 1
Olin, Region 4
Royster Phosphates, Region 4
Great Lakes Chemical, Region 6
Amoco Production, Region 8
Chevron, Region 8
Ultramar, Region 9
BP Oil, Region 10
ITT Rayonier, Region 10
-------
Sulfuric Acid:
7664-93-9
Hercules Chemicals, Region 1
Jones Chemical, Region 1
LCP Chemicals, Region 1
Monet, Region 1
Upjohn, Region 1
Bacardi Rum, Region 2
BASF (NY), Region 2
Du Pont Agrichemicals, Region 2
Automata, Region 3
LCP Chemicals, Region 3
Mobay, Region 3
Olin, Region 3
Oxychem, Region 3
Purolite, Region 3
C & S Chemicals, Region 4
Cape Coral Water Treatment, Region 4
Kason Industries, Region 4
Olin, Region 4
Photocircuits, Region 4
Royster Phosphates, Region 4
Virtex Chemical, Region 4
Best Foods, Region 5
Koppers, Region 5
Citgo Refinery, Region 6
Exxon Refinery, Region 6
Great Lakes Chemical, Region 6
Sid Richardson Carbon, Region 6
Western Extrusion, Region 6
Chevron, Region 8
JEMM Plating, Region 8
Kodak, Region 8
Koppers, Region 8
Phillips 66, Region 8
SAS Circuits, Region 8
Western Forge, Region 8
Coronado Generating Station, Region 9
Dole Packaged Food, Region 9
Magma Copper, Region 9
Pioneer Chlor Alkali, Region 9
ITT Rayonier, Region 10
Sulfuric Acid (Fuming):
8014-95-7
Bacardi Rum, Region 2
BASF (NY), Region 2
Sulfur Trioxide:
7446-11-9
Royster Phosphates, Region 4
Toluene:
108-88-3
BASF (NY), Region 2
Du Pont Agrichemicals, Region 2
Carolina Solite, Region 4
General Electric Plastics, Region 5
Western Forge, Region 8
-------
Toluenediamine:
25376-45-8
Mobay, Region 3
Toluene Diisocyanate:
91-08-7
Mobay, Region 3
Olin, Region 6
Syncom Technologies, Region 8
1,1,1-Trichloroethane:
71-55-6
Chief Supply, Region 6
SAS Circuits, Region 8
Vanadium Pentoxide:
1314-62-1
Royster Phosphates, Region 4
XyJene (mixed isomers):
1330-20-7
Du Pont Agrichemicals, Region 2
Carolina Solite, Region 4
Fermenta ASC, Region 6
Syncom Technologies, Region 8
Western Forge, Region 8
o-Xylene:
95-47-6
Koppers, Region 5
Exxon Refinery, Region 6
Zinc Cyanide:
557-21-1
Carl Falkenstein, Region 3
------- |