THE CHEMICAL SAFETY AUDIT PROGRAM:
FY 1998 STATUS REPORT
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TABLE OF CONTENTS
EXECUTIVE SUMMARY i
1.0 CHEMICAL SAFETY AUDIT PROGRAM: HISTORY AND FUTURE 1
1.1 Program Background 1
1.2 Relationship to the CEPPO Prevention Strategy 3
1.3 Future Role of the CSA Program 5
1.4 CSA Training Workshop 6
1.5 CSA Database 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 13
2.4 CSA Training Workshops 13
3.0 OVERVIEW OF CSA REPORT FINDINGS 18
3.1 Corporate and Facility Management 19
3.2 Process Hazard Analysis (Hazard Evaluation) 20
3.3 Offsite Consequence Analysis 21
3.4 Process Safety Information 22
3.5 Standard Operating Procedures 23
3.6 Equipment and Instrument Maintenance 24
3.7 Training 26
3.8 Safety Audits 27
3.9 Accident Investigation 28
3.10 Management of Change 29
3.11 Pre-Startup Review 30
3.12 Hot Work Permits 31
3.13 Employee Participation 31
3.14 Contractors 32
3.15 Release Prevention and Mitigation Measures 32
3.16 Facility Emergency Preparedness and Response 33
3.17 Community Emergency Response Coordination 38
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APPENDICES
Appendix A:
Appendix B:
EXHIBITS
Exhibit 1:
Exhibit 2:
Exhibit 3:
Exhibit 4:
Exhibit 5:
Exhibit 6:
Exhibit 7:
Outline of the Chemical Safety Audit Protocol
List of Chemical Safety Audits
Summary of Chemical Safety Audits and Final Reports by Year and Region
Summary of Chemical Safety Audits and Final Reports Completed by Region
Breakdown of Audited Facilities by SIC Code
Hazardous Substances Examined, FY 89 through FY 98
Chemical Safety Audit Workshop Attendees by Affiliation, FY 89 through FY 98
Chemical Safety Audit Workshop Attendees by Affiliation
Chemical Safety Audit Workshops: Number of Persons Trained by EPA Region
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EXECUTIVE SUMMARY
This is a comprehensive report on the status of the U.S. Environmental Protection Agency's
Chemical Emergency Preparedness and Prevention Office's (CEPPO) Chemical Safety Audit (CSA)
program since its inception in fiscal year (FY) 89, a review of the successful and problematic trends of
CSA program implementation in FY 98, and a discussion of the current and future role of the CSA
program in the CEPPO Prevention Strategy.
In these ten years, the CSA program has encompassed the review of the chemical process safety
management systems of 372 facilities and the training of over 1100 federal, state, and local officials. In
addition, the CSA program has developed a database of chemical safety audit information and supported
numerous other related chemical accident prevention activities, including outreach and technical
assistance for both the public and private sector.
Chemical accident prevention involves identifying the causes of accidental releases of hazardous
substances and the means to prevent them from occurring, promoting industry initiatives in these areas,
and sharing the results with the community, industry, and other interested groups. EPA established the
CSA program to:
• Heighten awareness of and promote chemical safety among facilities handling hazardous
substances, as well as in communities where chemicals are located;
• Build cooperation among facilities, EPA, and others by conducting joint audits;
• Gather information on safety practices and technologies from facilities handling
hazardous substances; and
• Establish a 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 sections 104(b) and 104(e)
of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). 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, available to the public, that identifies 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 how the program is being implemented both at headquarters and in the regions,
the purpose and goals of the audit program, and the type of information being generated and its uses.
The following four topics are the focus of this report — program activities, program results, regional
program implementation, and analysis of audit results.
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Regional Implementation Status
In addition, the CSA program has provided the opportunity for greater cooperation and
communication with state and local officials as a result of their participation in the audit process and
associated training and outreach activities. State and local audit participants stress the beneficial aspects
of the program from increased government-industry coordination to enhanced understanding of chemical
process safety issues in the community. In addition, as the CSA program has developed, the regional
offices have initiated new programs and activities and introduced modifications to audit procedures that
take advantage of the program's flexibility. Initiatives such as mini-audit programs and accident
investigations, as well as greater pre-audit planning, coordination with other environmental and health
and safety programs, and outreach to industry, have also been the products of the evolution of the CSA
program. For example, in FY 98, Region 3 conducted 58 mini-audits and Region 8 conducted 24 mini-
audits of water treatment operations, ammonia refrigeration systems, and other facilities with toxic and
flammable chemicals.
Program Activities/Results
The achievements of the audit program, outlined in Chapter 2, are based on the number of full-
scale 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 participation in training workshops offered by EPA headquarters is also
included.
As of the close of FY 98, the regions had submitted a total of 363 final reports to EPA.
Information from the 14 most recently submitted reports was examined for this status report, including a
number of reports from audits conducted in FY 97 that were not submitted to EPA headquarters in time
to be included in the FY 97 Status Report.
CEPPO has designed a four-day chemical safety audit workshop that gives potential audit team
members the training to conduct an audit; beginning in FY 93, these courses have been presented by
EPA's Environmental Response Team as part of their training curriculum. From 1989 through 1998, a
total of 68 workshops, attended by over 1700 individuals throughout all ten regions, have been
conducted; 179 individuals attended the eight workshops held in FY 98. The most noteworthy trend in
these workshops has been the increased involvement of state and local officials, who account for
approximately 51 percent of the overall attendance, but 73 percent of the attendees in the past year. This
represents a concerted effort within the CSA program to increase awareness and participation by these
individuals in combination with increasing state and local interest in chemical process safety issues. In
addition, with the applicability of the new Risk Management Program regulations to operations at federal
facilities, 13 percent of workshop attendees during FY 98 were federal officials and their contractors.
To realize the goals of the CSA program to collect and disseminate information on chemical
process safety issues and to improve program coordination, CEPPO has assembled a computerized
database to provide EPA regions and headquarters (as well as state and local government agencies) with
information gathered from chemical safety audit reports in a format consistent with the CSA protocol.
Through analysis of the database, the user can identify successful and problematic techniques or
practices employed to manage process safety at facilities handling hazardous substances. The database is
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being used by CEPPO to develop guidance and technical assistance documents that will be distributed to
individuals and organizations involved in chemical accident prevention. In addition, the database has
been given to federal, state, and local officials attending the training workshops, who use the audit report
information to increase their familiarity with chemical process safety issues and to support their own
inspection and auditing activities.
FY 98 Audit Analysis
Chapter 3 presents an overview of conclusions and recommendations taken from recent EPA
chemical safety audits, based on the latest 14 final CSA reports received by EPA headquarters as of
September 30, 1998. Once again, the results have been organized according to the major elements of
generally accepted chemical process safety management practices, which form the basis for the facility
risk management programs specified under Clean Air Act (CAA) section 112(r). Seventeen major
chemical process safety elements are examined in this chapter: corporate and facility management,
process hazard analysis (hazard evaluation), offsite consequence analysis, process safety information,
standard operating procedures, equipment and instrument maintenance, training, safety audits, accident
investigation, management of change, pre-startup review, hot work permits, employee participation,
contractors, release prevention and mitigation measures, facility emergency preparedness and response,
and community emergency response coordination.
Each section of Chapter 3 reviews the key features in the implementation of one of these
chemical process safety elements, as well as the role each element plays in maintaining a safe facility.
After an overview of general trends in audit team observations and conclusions from the last several
years, each section highlights notable facility practices taken from the latest 14 audit reports. For
example, most of the audited facilities have developed procedures for conducting investigations of
certain accidental releases of hazardous substances. However, the audit teams visiting these facilities
noted very significant differences in the range of releases that were investigated, the scope of the
investigation, the process of implementing corrective action and follow-up procedures.
Conclusion
EPA views the CSA program as an integral component of its overall chemical safety program
and an ongoing means of stimulating chemical accident prevention initiatives. The voluntary nature of
the audits encourages facilities to work with EPA and allows industry to feel comfortable in sharing their
audit experiences and recommendations with other industry partners. Another important factor is the
close coordination of resources and focus at the regional level with other CEPPO prevention efforts.
Current benefits from the CSA program include the following:
• CSA training workshops and audit participation provide EPA, state emergency response
commissions (SERCs), local emergency planning committees (LEPCs), and other federal
agencies with a better understanding of chemical process safety management and facility
practices to prevent and mitigate chemical releases;
• Audit activities foster a more cooperative attitude between government and industry on
chemical process safety issues; and
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• Jointly conducted audits and training support cooperation and coordination on chemical
safety programs among federal, state, and local government agencies.
On May 24, 1996, EPA's Administrator signed the final rule for the risk management planning
requirements mandated under Clean Air Act (CAA) section 112(r). The rule requires certain facilities
("sources") handling regulated substances in a process above specific quantities to develop and
implement a risk management program consisting of a hazard assessment, a prevention program, and an
emergency response program. Sources will summarize their risk management program in a risk
management plan (RMP), which will be made available electronically to state and local government and
the public. Sources with processes covered by the RMP rule must have complied with these
requirements by June 21, 1999. EPA and the other agencies responsible for implementing these
regulations are required to conduct audits of RMPs and will also conduct site inspections to oversee and
enforce compliance with the rule by evaluating actual practices.
Thus, chemical accident prevention practices, which the CSA program encourages, are now
mandatory for certain processes at sources covered by the RMP rule. EPA is encouraging state
governments to take responsibility for implementing the RMP program, and several states have indicated
that they will apply for delegation of the program. The CSA program will continue to play a key role in
assisting these states with guidance, training, and technical assistance on chemical process safety issues
and the audit process. Although the number of chemical safety audits has declined in the last four years,
training workshop attendance has remained strong and increased in many states. In addition, analysis of
CSA program results across industry sectors will give RMP auditors and inspectors a basis on which to
evaluate the efficacy of facility chemical safety policies and practices.
In addition, it is expected that CSA team members will be involved in implementation of these
regulations at the regional level (for facilities in states that do not take delegation of the program) by
providing compliance assistance, auditing facility RMPs, and inspecting facility risk management
programs. RMP auditors and site inspectors will be able to draw on their CSA training and experience
in selecting, planning, and conducting site visits. At the same time, there will still be many facilities
handling extremely hazardous substances that are either not included on the RMP list, or below threshold
quantities, or in concentrations that are not covered by the RMP requirements. Even at large facilities
with processes covered by RMP, often there will be many additional processes taking place that use
hazardous substances which are not covered by RMP. Thus, the CSA program will continue to have an
important role in accident prevention through audits of these facilities.
The CSA program, the Risk Management Program, and the Clean Air Act General Duty Clause
are components of EPA's integrated chemical safety program. Depending on the circumstances at a
particular facility, EPA may choose to apply one or more of these elements to achieve greater protection
of human health and the environment.
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1.0 CHEMICAL SAFETY AUDIT PROGRAM: HISTORY AND FUTURE
In the ten years since EPA initiated the Chemical Safety Audit (CSA) program in 1988, over 372
full-scale chemical safety audits and approximately 180 mini-audits have been conducted by EPA
regional offices. In addition, an extensive training program has been established and a CSA program
database has been developed. The CSA program also has prompted a growing interest among state and
local officials in the audit process and in the underlying concepts of chemical process safety
management. With the publication of the final risk management planning regulations mandated under
section 112(r) of the Clean Air Act (CAA), the CSA program has assumed a critical support role in the
development of the national chemical accident prevention effort spearheaded by EPA's Chemical
Emergency Preparedness and Prevention Office (CEPPO).
For the 372 full-scale chemical safety audits conducted over the ten years ending September 30,
1998, 363 final audit reports have been prepared (see Appendix B). To compile information for this
report, the final audit reports have been summarized in a standard format consistent with the CSA
protocol. These profiles present a summary of audit observations and include the audit team's
conclusions and recommendations. The profiles also contain information on 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.
The remainder of this chapter describes the future of the CSA program and the primary features
of the existing CSA program, including its history and purpose, and key program activities — CSA
training workshops and the CSA database. Chapter 2 presents a statistical overview of the results of
CSA program activities and achievements. Lastly, Chapter 3 reviews facility chemical process safety
practices identified in the final CSA reports submitted to CEPPO since the publication of the FY 97 CSA
Status Report.
1.1 Program Background
History
The CSA program is part of a broad EPA initiative designed to accomplish four chemical
accident prevention goals:
• Learn about and understand problematic and successful practices and technologies for
preventing and mitigating releases from facilities handling hazardous substances;
• Heighten awareness of 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 database for the assembly and distribution of chemical safety information
obtained from facility audits and from other sources.
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Following the 1984 release of methyl isocyanate in Bhopal, India, and subsequent incidents in
the United States, awareness of the 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 SARA Title III, which establishes a
chemical emergency preparedness infrastructure within each state, territory, and Tribal land.
Recognizing accident prevention as the next step after instituting local emergency preparedness
efforts, EPA sought to identify causes of accidental releases of hazardous substances and the means to
prevent them from occurring, to promote accident prevention practices 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 needed to prepare this study, a number of facility audits were conducted 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 contained in
CERCLA sections 104(b) and 104(e). 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 may use a
variety of legal authorities to address them.
Audit Team
An EPA audit team consists primarily of EPA employees and other designated representatives,
including contractors and AARP members. Other federal, state, and local government personnel,
particularly representatives of State Emergency Response Commissions (SERCs) and Local Emergency
Planning Committee (LEPCs) established under EPCRA, are encouraged to participate in audits as team
members or 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 throughout the audit process.
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 history of releases, the
facility's proximity to a sensitive population or area of high population density, its accident prevention
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technologies, or the industry's concentration in the area. The regional office may review 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; and other sources.
Currently, most facilities selected have been identified based on their history of accidental releases, using
ARIP, the Emergency Response Notification System (ERNS), and other release information sources.
At present, EPA regional offices are not required to follow any formal procedures when selecting
a facility for an audit, as long as 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. 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 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, to follow 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 establishes 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 ensure continuity and consistency in report preparation.
1.2 Relationship to the CEPPO Prevention Strategy
The CSA program is one component of CEPPO's overall chemical accident prevention strategy.
The key to the success of the CSA program in supporting accident prevention is the cooperation built
between industry and EPA through the voluntary audit participation. The voluntary nature of the audits
encourages facilities to work with EPA and allows industry to feel comfortable in sharing their audit
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experiences and recommendations with other industry partners. Another important factor is the ongoing
coordination of the CSA program with other CEPPO prevention efforts including the Accidental Release
Information Program (ARIP), the Risk Management Plan (RMP) program, and the chemical accident
investigation (CAI) program:
• In 1986, the ARIP program began to collect accident information through surveys issued
to certain facilities experiencing accidental releases. The ARIP database, consisting of
information taken from the ARIP survey, is used to identify candidate facilities for
chemical safety audits and other prevention-related outreach programs.
• With the passage of the Clean Air Act Amendments of 1990, EPA began development of
the RMP rule, in part using the information provided by ARIP and CSA. Since
promulgating the RMP rule in 1996, CEPPO has been working to implement the RMP
program. Regional chemical safety audit team members are involved in all the facets of
the RMP program, including assisting CEPPO in developing guidance documents,
providing assistance to personnel from state and local implementing agencies, and
working directly to help facilities understand the requirements.
• EPA's statutory responsibility for the prevention and mitigation of accidental releases
necessitates action by the Agency to investigate and understand the chemical accidents
that occur. These investigations, conducted by EPA's Chemical Accident Investigation
Team (CAIT), may lead to issuance of new guidance or regulations relating to accident
prevention. Chemical safety audit team members provide critical support to the CAIT.
Team members are involved in conducting accident investigations; developing safety
alerts where an unrecognized hazard is identified; and developing reports on the facts,
circumstances, and root causes of accidents.
The regional offices have substantial flexibility in implementing the CSA program. The regions
have used this flexibility to model the CSA program into a vehicle for meeting regional priorities for
accident prevention. Specific features of the CSA program (e.g., followup activities) have served as the
basis for the development of new regional initiatives. In addition, several regions have begun separate
chemical-specific initiatives to address commonly used hazardous chemicals that pose the greatest risk in
an accident, such as mini-audits.
FY 98, Region 3 conducted 58 "mini" chemical safety audits and Region 8 conducted 24 "mini"
audits. By performing "mini" audits, the regions were able to reach a larger number of facilities at a
reduced cost to the government. In general, these audits focused on smaller facilities or a specific
operation at larger facility, including two dozen visits to water treatment plants using chlorine and sulfur
dioxide, two dozen visits to food processors and cold storage facilities with ammonia refrigeration
systems, as well as a variety of other operations involving toxic and flammable chemicals, such as
propane distributors. Following their site visit, Region 3 sent a followup letter to the facility highlighting
notable practices and recommendations for potential improvements.
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1.3 Future Role of the CSA Program
On May 24, 1996, EPA's Administrator signed the final rule for the risk management planning
requirements mandated under Clean Air Act (CAA) section 112(r). The rule requires certain facilities
("sources") handling regulated substances in a process above specific quantities to develop and
implement a risk management program consisting of a hazard assessment, a prevention program, and an
emergency response program. Sources will summarize their risk management program in a risk
management plan (RMP), which will be made available electronically to state and local government and
the public. Sources with processes covered by the RMP rule must have complied with these
requirements by June 21, 1999. EPA and the other agencies responsible for implementing these
regulations are required to conduct audits of RMPs and will also conduct site inspections to oversee and
enforce compliance with the rule by evaluating actual practices.
Thus, chemical accident prevention practices, which the CSA program encourages, are
mandatory for certain processes at facilities covered by the RMP rule. EPA is encouraging state
governments to take responsibility for implementing the RMP program, and several states have indicated
that they will apply for delegation of the program. The CSA program will continue to play a key role in
assisting these states with guidance, training, and technical assistance on chemical process safety issues
and the audit process. Although the number of chemical safety audits has declined in the last three years,
training workshop attendance has remained strong and increased in many states. In addition, analysis of
CSA program results across industry sectors will give RMP auditors and inspectors a basis on which to
evaluate the efficacy of facility chemical safety policies and practices.
In addition, it is expected that CSA team members will be involved in implementation of these
regulations at the regional level (for facilities in states that do not take delegation of the program) by
providing compliance assistance, auditing facility RMPs, and inspecting facility risk management
programs. Voluntary compliance assistance (with EPA and OSHA rules, in particular) has always been a
component of chemical safety audits, and RMP auditors and site inspectors will be able to draw on their
CSA training and experience in interacting with these facilities.
However, it is important to recognize that there will still be many facilities handling hazardous
substances and not covered by the RMP rule. The RMP rule applies to only 77 toxics and 63
flammables. The list of chemicals is further curbed by various exemptions. Among the toxics,
hydrochloric acid with less than 37% HC1 is exempt; so are hydrofluoric acid with less than 50% HF,
nitric acid with less than 80% HN03, and ammonia solutions with less than 20% NH3. When in a
mixture, if the concentration of the toxic is less than 1%, it is also exempt. Ammonia of any
concentration used by farmers as a fertilizer is also exempted.
For the flammables, the US Court of Appeals has placed a stay for LP gas, principally propane at
any threshold. The EPA Administrator has issued an administrative stay for all flammable hydrocarbons
no greater than 67,000 pounds. There are two bills in Congress that would exempt all flammable fuels
and liquefied petroleum from the RMP rule.
When the short list of substances is taken with the exemptions and stays, the number of facilities
and processes that will be affected becomes fairly limited when compared with other environmental
regulations such as EPCRA and CERCLA. Even at large facilities with processes covered by RMP,
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often there will be many additional processes that use hazardous substances which are not covered by
RMP. As such, the Chemical Safety Audit program will continue to have an important role in accident
prevention through audits of facilities.
1.4 CSA Training Workshop
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 designed the Chemical Safety
Audit program workshop. In FY 98, eight workshops were held in six regions. Training workshops were
held in Boston, MA; Cheektowaga, NY; Philadelphia, PA; Louisville, KY; Jacksonville, FL; Springfield,
IL; Little Rock, AR; and Kansas City, KS. A total of 179 attendees participated. A variety of groups
was represented at the workshops including 13 regional personnel, 76 state officials, 54 local officials,
and 8 representatives from other federal agencies, including staff from the U.S. Department of Labor, the
U.S. Department of Defense, the U.S. Veterans Administration, the Federal Emergency Management
Agency, the Army Corps of Engineers, and officials from the U.S. Navy.
For FY 99, the Environmental Response Training Program plans to present 11 additional four-
day CSA courses. These workshops are designed for presentation to a combination of regional, AARP,
contractor, and state and local government personnel who are or will be involved in conducting chemical
safety audits. The topics addressed during the current four-day workshop include:
• Chemical process hazards
• Process safety management
• Computer modeling
• Process safety: equipment
• Process safety: operations
• Hazard and release mitigation
• Maintenance procedures and training requirements
• Conducting interviews
• Incident investigation
• Hazard evaluation
• Hazard evaluation techniques
• Emergency response
Process inspection techniques
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• Audit report writing
• Guidance Manual for EPA Chemical Safety Audit Team Members
• Chemical Safety Audit Program Resource Guide
In addition, a series of sequential group exercises is held during the workshop to provide participants
with the opportunity to apply theoretical knowledge to scenarios that simulate all phases of conducting a
chemical safety audit, including interviewing facility personnel.
1.5 CSA Database
To collect and disseminate information on chemical process safety issues and improve program
coordination, CEPPO has assembled a computerized database to provide EPA regions and headquarters
(as well as state and local government agencies) with information gathered from chemical safety audit
reports in a format consistent with the CSA protocol. The profiles present a summary of audit
observations and include the audit team's conclusions and recommendations. The profiles also contain
information on 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. The
information in the database is useful to EPA regional offices for a variety of purposes, such as identifying
field experts and comparing processes and safety practices at different facilities for the same chemicals.
Although the database is not directly available to the public and industry, EPA will use it to develop
guidance and technical assistance documents that will be distributed to individuals and organizations
involved in chemical accident prevention.
The database has been given to interested federal, state, and local officials who have attended
CSA training workshops. These individuals are using the database as a source of background
information on chemical hazards, process hazards, and successful and problematic facility practices in
preparation for their own inspection and auditing activities. For example, by reviewing the information
on typical operating hazards and release prevention practices at the paper mills contained in the CSA
database, these officials have been better prepared to conduct inspections of similar paper mills under
their own jurisdiction.
The CSA database makes it possible to examine audit information about specific facilities
quickly. For example, the database user can 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 EPA region. Users can search the database for different types of information, such as
chemical names or Chemical Abstract Service (CAS) numbers, 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 (as well as other federal and state and local
officials implementing similar programs) can also use the database to:
• Identify field experts for auditing advice or participation in an audit;
• Identify facilities with similar processes or practices to support an ongoing audit;
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• 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; and
• Assemble information on a specific chemical safety process management practice.
The current version of the CSA database, distributed in July 1996, contains profiles of 312 chemical
safety audits.
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2.0 OVERVIEW OF CSA PROGRAM RESULTS
This chapter presents an overall summary of the achievements of the Chemical Safety Audit
program focusing on the following subjects:
• Chemical safety audits and audit reports completed in each fiscal year;
• Breakdown of the audited facilities by Standard Industrial Classification (SIC) code;
• Hazardous substances examined by the audit teams; and
• Chemical safety audit training workshops conducted.
2.1 Chemical Safety Audits and Reports Completed
As of the close of FY 98, the regional offices have finalized a total of 363 audit reports for the
372 full-scale chemical safety audits, including several follow-up audits for which no audit report profile
was prepared. Exhibit 1 displays 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 full-scale chemical safety audits were completed in FY 89, 39 in
FY 90, 53 in FY 91, 41 in FY 92, 57 in FY 93, 57 in FY 94, 44 in FY 95, 27 in FY 96, 13 in FY 97, and 9
in FY 98. Exhibit 2 summarizes the chemical safety audits and final reports completed by region. In
addition, note that these totals do not include the mini-audits conducted by the regional offices in the last
three years; in FY 98, Region 3 conducted 58 mini-audits and Region 8 conducted 24 mini-audits.
2.2 Chemical Safety Audits by SIC Code
Approximately half of the chemical safety audits conducted by the regional offices involved
chemical manufacturing operations (SIC code 28). Exhibit 3 presents a breakdown by SIC code of the
363 audited facilities for which this information is available. (Some facilities' operations are categorized
in more than one SIC code, a characteristic that is reflected in the exhibit.) Within SIC code 28, the vast
majority of the processes examined were further classified under SIC codes 281, 282, 286, and 287.
Other manufacturing operations at which a number of audits were conducted are paper and pulp mills —
SIC code 26 (29), petroleum refineries — SIC code 29 (26), food processors — SIC code 20 (25),
primary metal manufacturing — SIC code 33 (15), and electronic and electrical equipment manufacturing
— SIC code 36 (15).
Non-manufacturing operations at audited facilities comprise one-seventh of the total number of
audits and are classified in a variety of SIC codes. The major categories among these operations are
nondurable goods wholesalers handling hazardous substances — SIC code 51 (22); electric, gas, and
sanitary services — SIC code 49 (10); and public water treatment facilities — SIC code 95 (8).
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10
Exhibit 1
Number of Chemical Safety Audits and Chemical Safety Audit Reports by Year and by Region
FY 89 through FY 98
Region
FY89
Audits
FY90
Audits
FY91
Audits
FY92
Audits
FY93
Audits
FY94
Audits
FY95
Audits
FY96
Audits
FY97
Audits
FY98
Audits
Total
Audits
Final
Reports
1
4
4
3
3
3
3
0
0
0
0
20
20
2
2
4
3
3
4
3
2
4
4
0
29
26
3
4
4
4
5
6
6
4
2
0
0
35
35
4
5
5
15
6
10
8
8
6
5
5
73
72
5
3
5
3
3
4
4
4
3
0
0
29
24
6
4
5
5
4
4
4
4
0
0
0
30
30
7
0
0
4
6
14
18
14
4
4
4
68
68
8
3
4
6
4
5
4
3
0
0
0
29
29
9
4
4
4
4
3
3
1
3
0
0
26
26
10
3
4
6
3
4
4
4
5
0
0
33
33
Total
32
39
53
41
57
57
44
27
13
9
372
363
Note: These totals do not include regional chemical accident investigations and mini-audits
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Exhibit 2
Summary of Chemical Safety Audits and Final Reports Completed by Region
FY 89 through FY 98
80 -|
70
60
50
40
30
20
10
5 6
Regions
10
~ Number of Chemical Safety Audits Completed ¦ Number of Chemical Safety Audit Reports Completed
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Exhibit 3
Breakdown of Audited Facilities by SIC Code
FY 89 through FY 98
Other Non-Manufacturing SIC Code 20
Facilities 6%
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13
2.3 Chemical Safety Audits by Hazardous Substance
A total of 194 different hazardous substances were examined by audit teams at the 339 audited
facilities for which this information was available, including 172 classified as CERCLA hazardous
substances and 77 listed as EPCRA extremely hazardous substances. Exhibit 4 presents a breakdown of
the CERCLA hazardous substances and EPCRA extremely hazardous substances examined during the
audits. On average, processes involving four hazardous and/or extremely hazardous substances were
examined at each facility. The five most commonly examined substances were chlorine (131 audits),
sulfuric acid (125), sodium hydroxide (105), ammonia (102), and hydrochloric acid (85).
2.4 CSA Training Workshops
As of the close of FY 98, 68 CSA workshops had been conducted in the EPA regions. Since FY
90, the host regions have been co-sponsors of the CSA workshops and provided valuable assistance in
organizing and conducting the workshops. Hosting the workshop in cities near the locations of the
regional office has allowed other EPA program offices and other federal agencies to attend. In addition,
for the last seven years the regional offices have been coordinating with the states to identify workshop
locations to encourage attendance by state and local officials.
This year, eight workshops were held in seven regions. Training workshops were held in Boston,
MA (Region 1); Cheektowaga, NY (Region 2); Philadelphia, PA (Region 3); Louisville, KY (Region 4);
Jacksonville, FL (Region 4); Springfield, IL (Region 5); Little Rock, AR (Region 6); and Kansas City,
KS (Region 7). A total of 179 attendees participated in the eight workshops. A variety of groups was
represented at the workshops including 13 regional personnel, 76 state officials, 54 local officials, and 8
representatives from other federal agencies, including staff from the U.S. Department of Labor, the U.S.
Department of Defense, the U.S. Veterans Administration, the Federal Emergency Management Agency,
the Army Corps of Engineers, and officials from the U.S. Navy. Exhibit 5 presents a breakdown of CSA
workshop attendees by affiliation. Since FY 93, there has been a concerted effort within the CSA
program to increase awareness and participation by state and local government representatives in the
program. As is demonstrated in Exhibit 6, which compares the percentage of attendees by affiliation
from FY 89 to FY 97 to that in FY 98, 73 percent of the FY 98 attendees represented state, local, and
tribal governments, as compared to 50 percent in the previous years.
Exhibit 7 is a breakdown by region of the number of audit team members who have received
training. State and local officials, EPA headquarters personnel, EPA headquarters contractors, industry
and academia, and other federal agency representatives are not included in these figures. The largest
number of personnel attending a workshop were from Region 4 (87), Region 3 (72), and Region 2 (58).
Note that this exhibit does not include data for TAT workshop attendance since FY 94 because the
technical assistance team contractors now support multiple regional offices.
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Exhibit 4
Hazardous Substances Examined
FY 89 through FY 98
Other Hazardous and
Extremely Hazardous
Substances
48%
Ammonia
8%
Chlorine
10%
Hydrochloric Acid
7%
Hydrofluoric Acid
3%
Nitric Acid
3%
Sodium Hydroxide
8%
Sulfur Dioxide
3%
Sulfuric Acid
10%
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Exhibit 5
Chemical Safety Audit Workshop Attendees by Affiliation
FY 89 through FY 98
Other Federal Agencies
12%
TAT and Other Contractors
11%
Academia ^
r\
EPA Regional Personnel
14%
AARP
2%
Headquarters EPA
and Contractors
2%
Industry/Consultants
5%
State Officials
28%
Local Officials
23%
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16
Exhibit 6
Chemical Safety Audit Workshop Attendees by Affiliation
FY 89 through FY 98
FY 89 through FY 97
FY 98
TAT & Other
Contractors
13%
Academia
3% A
EPA Regional
Personnel
16%
Other Federal
Agencies
4%
Academia
2%
Other Fedei
Agencies
11%
HQ EPA and
Contractors
3%
r\
AARP
2%
Industry/
Consultants
12%
EPA Regional
Personnel
7%
Industry/
Consultants
5%
Local Officials
22%
State Officials
28%
Local Officials
30%
State Officials
43%
TAT and Other
Contractors
2%
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Exhibit 7
Chemical Safety Audit Workshops:
Number of Persons Trained by EPA Region
FY 89 through FY 98
100
90 -
80 -
70 -
60 -
50 -
40 -
30 -
20 -
10 -
~ AARP
HTAT & Other Contractors
~ EPA Regional Staff
5 6
EPA Regions
10
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3.0 OVERVIEW OF CSA REPORT FINDINGS
This chapter presents a review of conclusions and recommendations taken from recent EPA
chemical safety audits, based on the latest 14 final CSA reports received by EPA headquarters as of
September 30, 1998. The results are organized according to the generally recognized elements of
chemical process safety management practices, which form the basis for the risk management program
regulations issued under CAA section 112(r) (see 40 CFR part 68), and OSHA's Process Safety
Management (PSM) Standard (29 CFR 1910.119). These principles are specifically applicable to
facilities with complex operations and chemical-based hazards, and, thus, in their detail may not be
appropriate for simpler operations that do not involve chemical processing.
These chemical process safety elements are closely related to those of the CSA protocol, an
outline of which can be found in Appendix A. The following 17 chemical process safety management
elements are examined in this chapter of the report:
• Corporate and facility management
• Process hazard analysis (hazard evaluation)
• Offsite consequence analysis
• Process safety information
• Standard operating procedures
• Equipment and instrument maintenance
• Training
• Safety audits
• Accident investigation
• Management of change
• Pre-startup review
• Contractors
• Employee participation
• Hot work permits
• Release prevention and mitigation measures
• Facility emergency preparedness and response
• Community emergency response coordination
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Each section of this chapter begins with an italicized overview of the key components of the
corresponding chemical process safety management element, followed by an overview of audit team
observations in the last three years and a discussion of facility practices described in the latest chemical
safety audit reports. 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, although audit teams do examine facility practices that are
directly related to the components of existing federal regulatory programs (e.g., emergency response
plans).
3.1 Corporate and Facility Management
Corporate and facility management play an integral role in ensuring a coherent and consistent
approach to chemical safety and health issues at a facility. Corporate management has the unique role
offostering communication among and providing guidance to operations within the corporation, while
facility management is better suited for addressing site-specific issues. The degree of support and
resources dedicated by corporate and facility management has a direct impact on the effectiveness of all
aspects of chemical process safety programs. Identification of responsible personnel is also a key step
for ensuring effective process safety management.
Corporate management can play an important role in ensuring that all facilities in a corporation
have access to process safety lessons learned. This is especially critical when a single corporation
maintains numerous facilities conducting similar processes. For instance, in a previous year, the
corporate management of one facility required that all spill reports be submitted to the corporate office,
which then produced a quarterly spill summary documenting incidents and actions to be taken. The
corporate headquarters for a network of 32 refrigeration facilities promoted information-sharing and
lessons learned between similar facilities by disseminating similar information.
Corporate management can also play a role in monitoring regulatory changes and providing other
skills and services that could not be maintained or developed cost-effectively at each facility. Corporate
management of a cleaning and sanitation products manufacturer has contracted for two audits of its fire
safety systems and is audited every two years by its corporate environmental health and safety
department. Several local audit procedures are also in place at a chemical manufacturing facility. The
facility conducts an internal audit of about 60 safety and housekeeping subjects as part of a weekly
"safety climate index," which is calculated from assessing 10 rating criteria the facility believes influence
safety. Additionally, the personnel at a scientific research center displayed a management philosophy
committed to safety and environmental concerns. The laboratory director is responsible for health and
safety within the facility, which conducts safety audits at various levels throughout out the year.
Emergency preparedness plans are well-written and comprehensive, and each facility has its own
personnel responsible for the emergency preparedness program. The plan also encompasses special
provisions for the disabled and personnel with language barriers.
Audit teams encouraged corporate management for several facilities to take a more active role in
developing standards for emergency scenarios. For instance, although facility personnel of a frozen food
products manufacturer routinely review Tanner Industries OSHA 200 logs to ensure that suppliers
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maintain an acceptable safety record, facility personnel have not conducted any modeling using release
scenarios to predict potential consequences of hazardous chemical releases. Audit teams suggested that
modeling activities be organized with the local HazMat Coordinator to identify potential vulnerable
zones in each scenario, and that the results be used to evaluate the facility emergency action plan to
ensure that it addresses problems associated with each release scenario and model result. Similarly, in a
previous year, corporate management of a brewery, although active in other areas of process safety
management, was prompted to make computer modeling results of hypothetical ammonia releases at one
of its facilities available to other facilities where ammonia is used.
Audited facilities use a variety of management techniques to disseminate process safety
information within the facility. For example, the corporate office at a chemical manufacturing facility
has established written guidelines to address safety, health, and environmental issues at the facility level.
The facility is expected to develop and amplify these guidelines into applicable local policies and
procedures. The plant manager has responsibility for all local safety, health, and environmental matters;
safety and health issues have been delegated to the safety-emergency response specialist; and
environmental matters have been delegated to the environmental manager. The unit manager and
operations engineer serve as the OSHA process safety coordinators. Additionally, the facility is a
member of the Chemical Manufacturers Association (CMA) and has an active Responsible Care
program, and facility personnel are also active in the LEPC. The facility is ISO 9000 certified, and
facility processes are subject to the OSHA Process Safety Management Program (PSM) Standard. In
previous years, a typical facility established a safety committee consisting of both staff and management
and uses monthly safety meetings with all personnel to share company memoranda and review any safety
literature. The format includes a presentation, open discussion, and then a quiz. This same facility
ensures that a single individual is responsible for ensuring effective process safety management, with the
plant manager's annual appraisal dependent, in part, on achieving specific environmental and safety
objectives.
3.2 Process Hazard Analysis
Process hazard analysis (PHA), also known as hazard evaluation, is a key factor in the
prevention of chemical accidents and, generally, in the management of safety at a facility. A process
hazard analysis identifies the hazards at the facility, helps assess the risk posed by the hazards, evaluates
the consequences of the hazards, and identifies ways in which the hazards can be controlled or
mitigated, thus directing facility attention to areas in most need of improvement. In conjunction with the
management of change, this analysis serves as a foundation for the ongoing revision of a facility's
accident prevention efforts. Although there are several methods for performing this analysis, each
approach will provide the facility with information on identifying potential accidental release scenarios
and, thus, support the preparation of an offsite consequence analysis.
For more complex chemical processing operations, facilities conducting a process hazard
analysis should use one of the generally recognized formal techniques (e.g., What If, Checklist, What
If/Checklist, Hazard and Operability study (HAZOP), Fault Tree Analysis, or Failure Mode and Effect
Analysis); less formal approaches may be sufficient for simpler operations. Depending upon the
complexity of the process(es) being examined, facilities may find that a review of the hazards posed by a
process, rather than a detailed PHA, may be sufficient to carry out the aim of effective process safety
management. Facilities should implement the results of the analysis; this process should be tracked to
determine whether recommendations are implemented in a timely manner. Finally, the evaluation should
be updated periodically or whenever a process modification is introduced.
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Although most facilities have at least an informal program to evaluate hazards, a number of
audited facilities have formal hazard analysis programs that are designed to enhance process safety
management and identify areas for improvement in facility practices. In previous years many audited
facilities had used the HAZOP methodology for evaluating hazards in their processing operations. A
similar trend continues this year. For instance, one medical manufacturing facility had a consulting firm
conduct extensive HAZOP studies of the major processes at the plant. The facility evaluated the findings
of the HAZOP studies and made appropriations in the 1998 budget to address the most critical changes.
Another facility has recently secured, but not installed, software for use in conducting PHAs. The
facility plans to use this program to track recommendations for all HSE-related programs.
In some cases, the audit teams noted that PHA programs at facilities were incomplete or needed
improvement. For example, one frozen foods manufacturer is still in the process of developing a list of
possible problem scenarios that would lead to operating and maintenance procedures; also the facility has
not conducted any ammonia modeling using the release scenarios that are under development based on
informal PHAs. The audit team encouraged the facility to develop a more structured approach to
identifying problem scenarios, and suggested that the facility should develop at a minimum, a "what-if
analysis" approach to this process. At a chemical facility, the audit team observed that maintenance
activities are not included in the PHAs, and suggested that PHAs should at least be conducted for
non-routine activities. The audit team also urged the facility to consider incorporating the requirements
of 40 CFR Part 68 when updating existing PHAs. In another audited chemical facility, the audit team
recommended that the facility could use the "Event Tree Analysis" approach to provide additional
information that would prove useful in emergency scenario development.
Among the 14 audit reported completed this fiscal year, the audit team noted that one facility had
performed no hazard evaluation. In addition, the audit team found that the facility does not use any
dispersion or release modeling to predict the path of airborne release.
3.3 Offsite Consequence Analysis
An offsite consequence analysis is designed to assess the potential impacts of a release of a
hazardous chemical on the populations and environments surrounding a facility. Based on the potential
hazards identified in the process hazard analysis, facilities should examine a range of potential
accidental release scenarios to identify the potential offsite consequences and evaluate the likelihood of
the release occurring. As a result, the offsite consequence analysis will help facilities establish
emergency response needs and priorities in the case of a release (and the implementation of measures to
prevent or mitigate such events) based on both their potential impact and their likelihood of occurrence.
As was the case in last years audit report findings, only a few audit teams found that facilities
were using offsite consequence analysis to evaluate potential hazards. At one of these facilities, a
medical manufacturer, an internal risk survey conducted by plant personnel several years ago identified
the chlorine and hydrochloric acid handling systems as having the greatest potential for significant offsite
impacts. Based on this finding, a quantitative risk assessment was conducted for the facility in 1991.
However, audit teams also observed that since this effort, a regional prison with 1,000 inmates has also
been established adjacent to this plant. One scientific research facility uses modeling to evaluate
atmospheric non-radiological releases of hazardous substances with the utilization of meteorological,
source term and site-specific data. At another chemical facility, the audit team noted that probably the
greatest deterrent to a significant off-site release is the presence of a large buffer zone surrounding the
process area.
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Audit teams in a few instances noted that facilities are not implementing offsite consequence
analyses. Last year, one of the audit teams had noted how one facility, located near two elementary
schools, a hospital, and two public parks, does not perform any modeling to track releases into air,
surface water, or groundwater, and also noted problems with the vulnerability zones identified for
chlorine and ammonia releases at the facility. This year, the audit team at a frozen foods processor noted
the absence of a structured approach to the offsite analysis modeling; the audit team suggested that the
facility should coordinate release modeling activities with the HAZMAT coordinator from the city to
identify vulnerable zones of different scenarios. In addition, the audit team also recommended that the
facility provide modeling information to the local fire department for use during an off site release.
3.4 Process Safety Information
Documentation of process safety information (including chemical hazards and process
technologies and equipment) is important because a facility's accident prevention program must be
based on up-to-date information on chemical hazards, processes and equipment. Data on chemical
hazards ensure that a facility's employees understand the inherent toxicity of a substance, as well as the
potential for fire, explosion, corrosivity, or reactions with other chemicals. Current data on processes
are imperative to conduct a hazard evaluation and to implement effective standard operating
procedures, training, and maintenance. Equipment information-piping and instrument diagrams,
materials of construction, electrical classification, relief system design and design basis, ventilation
system design, design codes and standards employed, material and energy balances, and safety systems -
should be documented and kept current.
In many of the facilities that were audited, audit teams made specific mention of and commended
facilities who made Material Safety Data Sheets (MSDS) information readily available and
understandable to employees. In previous years, audit teams had noted instances of facilities maintaining
electronic versions of MSDSs of different chemicals in the facility. Once again among the facilities
audited this year, a significant number of the facilities maintained computerized copies of MSDS
information. For example, at a large chemical facility a file of MSDSs for the chemicals used in each
area is kept in the control room and at the main gate. MSDSs are also on computer file, and the
environmental area managers are responsible for updating the information. In addition, all employees are
responsible for updating this information. One refinery has made hard copies of MSDSs available
throughout the facility and is currently transferring these files to the facility intranet.
In some cases, audits also revealed facilities whose chemical hazards were not formally
identified or were poorly documented. At a scientific research laboratory, the audit team found that
updated hazardous waste inventory information is not readily available to the local fire department,
especially after business hours. One of the buildings in the facility was found to lack a mechanism to
access information regarding hazardous waste inventory on a day-to-day basis.
Other audits revealed the need to take further steps to make chemical hazard information more
readily accessible to employees. At a frozen foods processing facility, the audit team suggested that as
the facility continues to develop its PSM program, refrigeration system procedures should include
information on the consequences of parameter deviations. At another facility, the audit team
recommended that the facility personnel should review their own MSDSs to ensure that each MSDS
contains all the required information, that the information is easily read, and that consistent language or
abbreviations are used for information that is not known or available.
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3.5 Standard Operating Procedures
Standard operating procedures (SOPs) provide the basis for coherent, safe facility operations by
supporting safety in day-to-day activities and in operator training programs. SOPs describe site access,
process startups and shutdowns during routine and emergency operations, lockout and tagout, confined
space entry, opening process equipment or piping, storage, handling, loading, and unloading. SOPs
addressing operating parameters should include operating instructions about pressure limits,
temperature ranges, flow rates, and steps on how to handle process deviations. Furthermore, SOPs
should be reviewed as necessary to ensure that they reflect current operating practices (including
changes that result from alterations in process chemicals, technology, equipment, and modifications of
the facility) and that current information is transmitted as part of employee training.
Most large facilities audited had extensive SOPs for their processes. Audit teams cited many
examples of thorough SOPs that were formally documented and implemented by employees. One such
facility, a specialty anesthesia inhalation gas manufacturer, had systematic, established accident and
incident investigation and reporting procedures codified in a bilingual SOP. The investigation and
reporting SOP covers near-miss accidents, as well as all incidents involving fires, environmental property
damage, and product losses. The facility's investigation approach goes beyond the immediate cause to
include the basic cause: the underlying procedures or practices that created the conditions in which the
immediate cause occurred. Procedures for conducting, documenting, and reporting of incidents and
follow-up are defined. Additionally, the SOP further establishes responsibilities for individuals and the
investigation team, sets time frames depending on the severity of the incident, and establishes follow-up
procedures and accountability for remedial procedures that may have to be implemented.
Audit teams frequently made suggestions regarding potential improvements to the SOPs even at
facilities that maintain detailed SOPs. A multi-disciplinary scientific research center had written SOPs
pertaining to radiological and toxic emergencies. These procedures are outlined in the lab's emergency
plan and are maintained by each emergency response unit. However, lightning protection was not
addressed in the SOPs. The auditors stated that lightning protection should be addressed in the fire
department's SOPs on fire safety and should include mitigation measures to minimize exposure during
firefighting, including personal protection training for all firefighters. In addition, each facility should
establish provisions to identify potential lightning hazards during evacuations and establishing alternate
evacuation locations in the event of lightning situations. Another facility, which manufactures bleach-
based cleaning products, maintained written health and safety SOPs for most of its processes. Through
interviews with employees and observations, the audit team determined that the personnel understand the
direct consequences of not following SOPs, one of which can include termination of employment.
However, the auditors recommended that the facility consider revising its SOP which currently requires
only one emergency responder for each action to be inside the plant in the event of an emergency. The
buddy system should be implemented to ensure the safety of responders.
Typical problems with SOPs observed by the audit teams ranged from a lack of formal written
procedures to insufficient documentation and failure to cover all operations. In a previous year, for
example, a manufacturer that receives and stores corrosive acids maintained SOPs for loading and
unloading procedures. However, the audit team found that the SOP was not sufficiently detailed and
recommended that the facility prepare a more detailed SOP for the loading and unloading of hazardous
chemicals, including emergency response considerations. Other facilities were encouraged to make
changes in their SOPs to make them easier to read and reference. For example, a chemical
manufacturing facility had SOPs that the auditors found to be very detailed, but with no distinction
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between action items and general information. In addition, start-up, shutdown, and emergency
procedures are not provided in a checklist form. Although the training specialist generally updates and
maintains the procedures, not all operating steps required by the PSM standard are addressed; only those
steps the facility believes to be applicable are covered. The audit team recommended that facility
personnel continue to revise its SOPs and separate action items from general information.
Several audit teams found that facilities' SOPs were not reviewed with sufficient frequency or
that revisions were not clearly documented. For example, in previous years, several audited facilities
recognized the need to update their SOPs more regularly, but had not yet begun this process. One poultry
processor was organizing their SOPs at the time of the audit. The facility reported that, when this
process is complete, SOPs will be reviewed annually. The audit team recommended that the date of the
review and the reviewing person(s) should be recorded on the document whenever an SOP is revised or
updated.
Several facilities are voluntarily participating in programs to verify or improve environmental
and safety processes. However, even these facilities frequently were found to limit their SOP
development or review to the levels required for such programs. For instance, in a previous year, a
chemical corporation has completed an ISO 9002 registration audit and received certification; all SOPs
and other documents are prepared and controlled in accordance with ISO 9000 requirements. However,
the audit team recommended that the facility generate and implement a schedule to update its SOPs.
Another facility in a previous year, a paper processing plant, developed SOPs in accordance with ISO
9002 standards, as well, and has expanded its SOPs to include OSHA PSM requirements for covered
processes only. The audit team recommended that the facility consider standardizing its SOPs in the
OSHA PSM format.
3.6 Equipment and Instrument Maintenance
Equipment and instrument maintenance falls into two categories: predictive/preventive
maintenance, which is performed to avoid equipment failure or breakdown, and emergency maintenance,
which is performed in response to equipment failure. While emergency maintenance is an essential
element of any facility safety program, systems ofpredictive or preventive maintenance are essential to
the prevention of equipment failure and subsequent releases. The purpose of a maintenance program is
to ensure that equipment is regularly monitored and serviced so that emergency situations do not occur;
this can help not only to prevent releases, but also to decrease facility downtime and increase overall
efficiency. To be effective, maintenance programs should cover chemical process and handling
equipment, instruments, and emergency response equipment.
For larger, chemical processing operations, generally accepted practices for a comprehensive
maintenance program include developing a list of critical equipment and controls; designing a
maintenance program that includes procedures and schedules; training employees in maintenance
procedures; and ensuring that maintenance supplies are suitable for the facility's purposes. Most
successful programs for large or complex facilities include the use of computer databases or other
systems to track maintenance activities. Smaller or less complex facilities may, however, find that a less
formal process can also result in an effective preventive maintenance program.
Many audited facilities use computerized tracking systems to run their preventative maintenance
programs. For example, a chemical manufacturer tracks its maintenance on a corporate-wide
computerized system from which work orders are generated using the NEXUS Manufacturing
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Information System. Collected maintenance work history is then used for preventive and predictive
scheduling where possible. However, maintenance activities are not included in the facility's PHAs.
Work that may involve change, as defined by PSM, is evaluated using a management of change
procedure. Work orders for inspecting critical equipment, as required by the OSHA PSM, are generated
automatically. While considerable work has been done, the facility recognizes that additional work is
needed in the mechanical integrity area. Written permits are required before any hazardous maintenance
work is performed, and special permits are required before doing hot work, excavation, confined space
entry, fire protection water system modifications, asbestos removal, high altitude work, and exhaust
system modifications. A "lock and tag" procedure is used when any piece of equipment with the
potential to release energy is shut down for maintenance or cleaning.
Many of the facilities do not have outstanding preventive maintenance practices or elaborate
systems to track and predict maintenance needs. However, many performed systematic preventive
maintenance nonetheless. At an electronics component manufacturer, maintenance is scheduled for some
machines and instruments, but most repairs are done on an as-needed basis. An audit team recommends
that the facility implement a preventative maintenance schedule for all machines and instruments.
Other facilities do not conduct thorough preventive maintenance programs. For example, a food
manufacturer does not have a working maintenance procedure and documentation program in place, but
is in the process of developing one. An audit team stated that facility personnel should consider
including the following elements from 29 CFR 1910.119 in its written training documentation program:
information on the hazards of the chemicals in the process (29 CFR 1910.119[d] [ 1]), information on the
technology of the process (29 CFR 110.119[d][2]), and information on the equipment used in the process
(29 CFR 1910.119[d][3]). In a previous year, at a chemical manufacturer, a manual maintenance work
order system was used, and additional work was needed to complete the facility's mechanical integrity
program. The audit team recommended that this facility evaluate the benefits of using computerized
systems for the work order system, complete a mechanical integrity program, and consider implementing
a preventive maintenance program.
In previous years, although some audited facilities incorporated emergency equipment into their
regular maintenance programs, and others conduct these activities in conjunction with drills and
exercises, other facilities did not have procedures to maintain their emergency equipment. For example,
a chemical manufacturer inspected its emergency equipment weekly. Documentation of these
inspections was maintained in a binder located in the environmental health and safety department, but
was not included in the facility's contingency plan. At a refinery, the audit team recommended that the
facility begin regular maintenance of its emergency equipment stations. However, other facilities had
thorough emergency equipment maintenance and inspection procedures. For example, a brewery
inspected and inventoried its emergency equipment cage monthly, and restricted access to this equipment
to authorized personnel by a keypad security code. The encapsulating suits and other equipment with
specified shelf lives at this facility are checked during each inventory to ensure that they are still within
their manufacturer's recommendations.
The depth and quality of the training afforded to maintenance workers can also affect the quality
of a facility's maintenance program. For example, in a previous year, an audit team observed that a
chemical manufacturer did not have a formal training program for maintenance personnel. However, the
new maintenance manager at this facility received permission to allow personnel to attend trade shows as
well as classes at equipment vendor schools and on programmable logic controllers. There are no
equipment history records for the time prior to the hiring of the new maintenance manager. However,
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this new manager is now instituting a system to support both preventive and predictive maintenance
programs.
3.7 Training
Training of supervisory and operations personnel provides the most immediate opportunity to
increase awareness of chemical health and safety issues and ensures the competence of employees in
performing their responsibilities. Training programs are the key to ensuring the effectiveness of SOPs,
maintenance programs, pre-startup reviews, and emergency response. Refresher training ensures that
established employees are reminded of appropriate procedures periodically and of alterations that have
occurred. To minimize the risk of accidents occurring because employees are unfamiliar with their
assigned tasks, a successful training program for a facility with complex, chemical processing operations
should include the following: initial and refresher training for all employees; procedures to confirm that
all employees are competent to do their jobs safely; additional training after any change is made to the
process or to the facility overall; and formal documentation. Smaller operations, and those with more
limited chemical handling activities, may find a less formal program sufficient to fill their health and
safety needs.
Many of the facilities audited had implemented the basic components of a training program,
including training policies and schedules, refresher courses, and incorporation of management of change
procedures. For instance, a multi-disciplinary scientific research center trains its new employees on
general emergency response procedures, including emergency operations and shutdown procedures, as
well as safety rules. Further general training is provided in hazard communication and laboratory
procedures, and job-specific and advanced training is then provided by each department, including
HAZWOPER training for all applicable staff.
A manufacturer of various bleach-based cleaning agents trains its employees in all areas of
operations including emergency response, health and safety, equipment operation, and general worker
safety. Types of training include general safety, first aid/CPR, Right-to-Know, Lock Out/Tag Out,
Confined Space, Respiratory Protection, Self-Contained Breathing Apparatus (SCBA), HAZMAT,
Emergency Response, Scrubber, InterScan, Draguer, Sensors Calibration, Chlorine Alarm, and Fire
Alarm.
Audit teams did suggest specific improvements to round out training programs at several
facilities. One chemical manufacturer has developed training courses for its employees on hazard
communication, emergency response, and chemical hazards, which is given using video presentations and
question and answer sessions. The audit team encouraged the facility to continue to improve the hazard
communication, emergency response, and chemical hazards training programs and increase chemical
safety awareness in the facility by updating all programs in light of any new regulatory requirements.
Another audit team encouraged a refinery to develop an electronic tracking system to readily show that
employees are current in required training.
One or two audited facilities had no formal training programs. For example, one audit team
recommended that a sanitation products manufacturer institute a formal centralized training program
administered by qualified and certified health and safety professionals in addition to its current training
in which new employees work alongside experienced employees. Other facilities had training
requirements, but no formal training procedures. For instance, an audit team encouraged an agricultural
chemical manufacturing facility to consider the development of a written operator training program,
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complete with job descriptions, training requirements, testing procedures, and competency
documentation for both classroom and hands-on training.
3.8 Safety Audits
A schedule of regular audits not only improves specific process unit conditions, but also supports
a consistent approach to health and safety issues throughout the facility. The safety audit has two
purposes. First, it serves as a tool for management to ensure that covered processes are in compliance
with the chemical accident prevention regulations, as well as other environmental regulations. In
addition, the audit allows management to perform a "real-time " check on the safety of its operations. A
safety audit should include at least one person knowledgeable in the process, a written report with
recommendations, and a management response. The size of the safety audit team, and the formality of
the follow-up process, can be scaled to suit the complexity of the process being audited. To be effective,
management should document actions taken to address and correct deficiencies identified in the report.
Many of the audited facilities conducted safety audits, both internal (i.e., conducted by facility
employees) and external (i.e., conducted by other individuals). For example, at an electronics
manufacturing facility, corporate management conducts internal environmental, health and safety (EHS)
compliance audits annually. Corporate management at this facility also hires an insurance company to
conduct annual safety and risk management based audits. One chemical manufacturing facility performs
internal hazardous materials safety audits and hires an insurance company to inspect its fire protection
systems. The audit team observed that during an internal audit conducted at this facility, a safety shower
in the tank room was identified as not having adequate water pressure, and noted that this problem is now
being addressed.
Similar to the trend in previous years, some of the larger facilities dedicated substantial resources
to audit programs. At a chemical manufacturer, corporate management has detailed audit procedures in
place; the facility conducts an internal audit of about 60 safety and housekeeping subjects as part of a
weekly "safety climate index," which is calculated based on 10 safety rating criteria. At a scientific
research laboratory, safety audits are conducted internally by different facility departments and safety
divisions, and externally by the U.S. Department of Energy, throughout the year.
Unlike in previous years, audit teams did not have any comments this year regarding the specific
facilities at which safety audits were not conducted, or were not conducted regularly. In earlier audit
reports, audit teams had made specific recommendations to facilities for tracking their internal audit
findings and developing written check lists and documentation procedures. This year, in most instances,
the audit teams only noted the types of audits conducted at facilities, and did not elaborate on the extent
of documentation of audit findings, or the nature of follow-up processes in place. Audit teams also did
not offer any specific recommendations to improve the internal safety audits at different facilities.
3.9 Accident Investigation
Facilities should investigate the root causes of accidents to prevent repeated or similar accidents
and to assess the need for improvements in equipment, maintenance, training, and operating procedures.
The concept of root cause involves identifying management system inadequacies or failures, such as poor
design or lack of training, that allow leaks to occur, when, for example, an operator turns the wrong
valve in a process line. To address the root cause would be to design a fail-safe process, or make
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operators more aware of proper procedures, rather than focusing on the initiating cause and assigning
blame.
There are four generally recognized components of a comprehensive accident investigation
program. First, the facility should establish procedures to investigate accidental releases or near misses
and develop a system to promptly address and resolve accident report findings and recommendations.
When a release occurs, the facility should promptly initiate an investigation by a formal accident
investigation team to find the facts and root causes of the incident. Next, the team should prepare a
summary investigation report that includes key data about the incident and any recommendations for
remedying the root cause(s). Finally, the facility should document any resolutions and corrective actions
taken and review the accident report with personnel whose job tasks are relevant to the investigation's
findings.
Audit teams found that many of the audited facilities had explicit accident investigation
procedures requiring follow-up reports or actions. For example, at a chemical manufacturing facility, the
facility's Safety Office maintains computerized and hard copy records of injuries, illnesses, and serious
accidents. Computerized versions of incident reports at this facility are tracked through a Corrective
Action Request (CAR) system. Other features at this facility include:
• Written procedures for accidental releases and incident investigations;
• Formation of an incident committee following an incident, and issuance of final area incident
reports to the Safety Office within 21 days of the occurrence of the incident;
• Tracking of recommendations made by the investigation committee on the CAR system; and
• Completion of an Occurrence Closing Report by the investigation area, and submission to the
Safety Office for filing with the respective incident report.
While several facilities had elaborate written procedures for investigating accidental releases,
audit team members observed that, in many of these facilities, incidents of a reportable release were very
rare or had not occurred at all. For instance, at a chemical manufacturing facility, the audit team noted
that in the past 12 years, there was only one instance of a reportable release. Some facilities initiated
procedures on a case-by-case basis, depending on the severity of the release. For example, at a scientific
research laboratory, the more extensive emergencies are investigated by the facility and DOE, and a
report is generated from the investigation outlining steps to prevent future releases. In one notable case
of a frozen foods processing facility, audit team members noted the absence of any procedures for
accident investigation.
In previous years, audit teams had made specific recommendations to encourage facilities
to develop more complete accident investigation programs and to more thoroughly investigate the
underlying causes of incidents. For instance, at a chemical handling facility audited last year, the audit
team had suggested that the facility should develop a formal written investigation procedure, and clearly
outline the composition and responsibilities of the investigation team. In general, in previous audits,
audit teams had noted that the following elements were commonly observed in the case of incomplete
accident investigation programs (1) absence of clearly specified responsibilities for following-up on
recommendations from accident investigations, (2) lack of proper documentation of investigation
procedures, and (3) no investigation of near-miss incidents. Once again, audit teams made similar
recommendations at this year's audited facilities. For example, the audit team at a refinery suggested
that the different investigation programs should be consolidated into one comprehensive system that
covers all types of incidents, including near misses and also recommended that the facility develop an
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incident and corrective action tracking system. At a chemical manufacturing facility, the audit team
recommended that the facility document requests for extensions of accident release investigations and
amend due dates within the Corrective Action Request System developed at this facility.
3.10 Management of Change
Chemical processes are integrated systems; changes in one part of the process can have
unintended effects in other parts of the system. For example, installation of better seals may increase the
pressure in vessels and, thus, the opportunity for excess pressure situations to develop. It is, therefore,
important that all changes in processes, chemicals, and procedures be reviewed prior to their
implementation to identify any potential hazards that may be created by the modification. Chemical
processing facilities should develop written procedures to review and manage changes in processes,
chemicals, and procedures prior to their implementation. A facility should identify potential hazards
that may be created by such changes and ensure that facility procedures, process safety information,
training, and process hazards analysis reflect changes and are kept up-to-date. At smaller facilities with
less complex chemicals operations, however, such a thorough, formal approach may not be necessary.
Audit teams found many audited facilities had well-developed management of change (MOC)
programs. As was the case in previous years, some of the larger facilities had explicit and documented
MOC procedures. For example, a chemical manufacturing facility's management of change program
applies to most of the OSHA PSM-regulated processes within the facility. At a refinery, the spill
prevention control and countermeasures plans are reviewed and updated when any substantive change
occurs. These plans are reviewed every three years and a record of change is maintained for two years.
Several of the audited facilities had more informal management of change programs. For
example, one chemical manufacturer uses a "three signature approval procedure" to authorize any
mechanical changes within the plant. However, the MOC investigations are conducted informally and
generally not documented for these types of changes. In a frozen food processing facility, a verbal
training program is the only type of training employees receive on new or revised SOPs prior to the
introduction of a new or modified process.
In general, audit teams noted that many of the facilities audited this year had implemented MOC
procedures; however, audit teams still found that MOC programs were incomplete at some facilities.
Audit teams suggested specific improvements to the MOC programs at these facilities. One audit team at
a chemical facility encouraged the management to develop a checklist of policies and procedures that
contain overlapping information for future use to ensure that changes in procedures are updated
throughout facility and corporate documentation. At an electronics manufacturing facility, the
engineering service request procedure is designed to allow evaluation of all changes, modifications, and
additions to equipment, processes, and materials in the facility. However, repairs and changes are
performed on an as-needed basis. The facility does not have a formalized preventive or predictive
maintenance program. In this case, the audit team recommended that the facility keep active records of
equipment history.
3.11 Pre-Start Up Review
The pre-startup review serves as a final check on management of change. It ensures that all
issues have been addressed and all systems have been checked prior to startup of a new or substantially
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modified process or after emergency shutdowns for routine processes. Startup of a new or modified
system can be a particularly hazardous time, especially for complex processes and those that require
high temperatures, high pressures, or exothermic reactions. However, even simple facilities need to
conduct such reviews. The basic elements of the pre-startup review involve ensuring that construction
and equipment is in accordance with design specifications; safety, operation, maintenance, and
emergency procedures are in place; appropriate hazard evaluation activities have been completed;
management of change has been followed; and updated training for each employee involved in operation
or maintaining a process has been completed.
In line with the trend from previous years, a number of audited facilities exhibited pre-startup
review procedures, generally in response to the requirements of OSHA's PSM Standard. Last year, audit
team members noted that facilities with the thorough SOPs also had pre-start up review procedures. For
example, audit team members at a brewery audited last year, noted that the SOPs clearly specified normal
operating ranges, correction of devices, normal operations and shutdown. Once again among the
facilities audited this year, audit team members observed that facilities with the most detailed SOP
procedures also had pre-start up review procedures. For example, at an agro-chemical manufacturer, the
facility personnel are required to review and update the plant SOPs to include guidance on what
constitutes short versus long plant shutdowns, correct and detect sensitized conditions during operations
and shutdown, and alert staff to the presence of any sensitizing material or condition. As part of the
initial training at a research laboratory, employees are provided instruction in emergency operations and
shutdown procedures, and safety rules.
Some facilities had pre-start up review procedures, but the audit team noted room for
improvement. For example, at a chemical manufacturer, the audit team noted that maintenance is
performed during an annual shutdown and on as-needed basis; however, the facility does not document
these procedures or record their frequency. At a frozen foods manufacturer, the audit team suggested
that the refrigeration system procedures should be reviewed to ensure continuity between different
procedures. Currently emergency shutdown procedures at this facility refer to the same control by
different identifiers. At one chemical manufacturing facility, the audit team recommended that the
facility consider computerizing the checklist for start-up, shutdown, and emergency shutdown
procedures. Specifically, the audit team suggested upgrading the current manual system to a system
which would prompt the user to check off or enter initials for each item before allowing the user to move
to the next item.
3.12 Hot Work Permits
Non-routine work that is conducted in process areas needs to be controlled by the facility in a
consistent manner. The relevant hazards should be communicated to those doing the work as well as
those operating personnel whose work could be affected. A system of "hot work permits" protects
employees and others from potentially hazardous situations resulting from non-routine, "hot work"
operations (e.g., welding) that may take place in process areas. Hot work permits should document that
the required fire prevention and protection measures have been implemented and should indicate the
date(s) authorized for hot work and the object on which the hot work is to be performed.
In past years, audit teams have noted certain common problems in the development and
implementation of hot work permits, as a few facilities were specifically identified by audit teams as not
having hot work permit programs, and other facilities that did have hot work permit programs were not
fully implementing these procedures. These hot work procedures were not covered in many audits.
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However, at a chemical manufacturer, audit team members specifically noted that written permits are
required before any hazardous maintenance work is performed. Special permits are required before
doing hot work, excavation, confined space entry, fire protection, water system modifications, high
altitude work, and exhaust system modifications. In addition, a "lock and tag" procedure is used when
any piece of equipment with the potential to release energy is shut down for maintenance or cleaning.
3.13 Employee Participation
An important component of a successful process safety management program is active and
informed participation by employees. Employees have uniquely informed perspectives on facility
processes and situations. Accordingly, employers need to consult with their employees as they develop
and implement a process safety management program and hazard assessments. Ideally, safety
information should flow both from the employer (e.g., training and education for employees, informing
affected employees of the findings from incident investigations, and publicizing company-wide
initiatives) and from the employee (e.g., through participation in safety committees, use of anonymous
comment boxes, and through membership on safety investigation teams).
Some facilities appeared to have programs in place to encourage employee participation in safety
issues. In previous years, audit teams noted that many facilities had programs providing incentives to
employees for participating in safety management. For example, at a chemical facility audited last year,
the audit team noted that safety awards are given to employees on an ad hoc basis for reaching safety
milestones. This year, the audit teams found that facilities adopted various other mechanisms to
encourage employee participation. For example, at a chemical facility, individual safety and other
performance awards are generally not distributed to personnel. Instead, emphasis is placed on improving
performance through behaviourial modification and reinforcement.
A few facilities have safety meetings to promote employee participation. One research
laboratory organizes safety meetings on a monthly basis to discuss any special issues and to review safety
systems. The meetings at this facility are conducted informally, and there are no records of attendance or
meeting minutes. At a chemical manufacturer, the maintenance department conducts weekly working
"tool box" safety meetings for all personnel on site. However, the audit team noted that employee
involvement in its safety program left room for some improvement. The safety program at this facility is
principally driven by the management, with little or no employee involvement. The audit team
recommended that the maintenance department should consider providing "tool box" safety meetings for
production personnel, similar to those provided for company and contractor personnel.
3.14 Contractors
Facilities that use contractors to perform work in and around processes that involve hazardous
chemicals need to include their contractors in the facility process safety management chain. Special
efforts must be made to screen contractors appropriately and to assure that contractor employees
receive up-to-date training and emergency procedures information. The following activities should be
conducted, as appropriate: informing contractors ofpotential fire, explosion, or toxic release hazards;
explaining to contractors the applicable provisions of the facility emergency plan; developing work
practices to control the entrance, presence, and exit of contractors in process areas; providing and
documenting contract employee training; and evaluating the performance of contractors in fulfilling
their obligations.
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In audits performed in previous years, audit teams had noted instances where facilities took extra
precautions to ensure that contractors were well-informed and trained on facility process safety. For
example, at a chemical manufacturing facility audited last year, all outside contractors were required to
be fully trained in company health and safety procedures, and contracted drivers were required to pass
the minimum training requirements for health and safety. In a few of the facilities audited this year, audit
teams specifically noted the role of outside consultants/contractors. For example, at a chemical facility ,
audit teams observed that an outside consultant was hired to develop a Spill Prevention Control and
Countermeasures Plan (SPCC), and in a frozen foods manufacturer, audit teams noted that the facility
uses the services of two mechanical and refrigeration engineering consultants to evaluate changes in the
refrigeration system. However, in both cases the audit teams did not comment on the specific
precautions or measures taken to educate these consultants about safety issues at the facility. In some
facilities safety meetings are mandatory for all personnel on site. For example, at a chemical
manufacturer, the weekly safety meetings conducted by the maintenance department are attended by all
personnel, including contractors.
3.15 Release Prevention and Mitigation Measures
Release prevention and mitigation measures are the practices and equipment implemented by a
facility to address the potential for accidental releases of hazardous chemicals. Because each operation
is unique, they are by nature site-specific. Prevention systems seek to reduce the likelihood, or severity,
of accidental releases of hazardous chemicals. Examples include monitors, detectors, sensors, and
alarms for early detection of accidental releases, and backup equipment and redundancy features to
protect against sudden accidents or failures. Containment structures, flares, scrubbers, quench systems,
and surge or dump tanks, can also act to prevent an abnormal occurrence (e.g., overpressurization) from
producing a release. Substitution of hazardous chemicals with less hazardous substances, inventory
reduction, and other process design changes can lessen the potential for accidental releases of
hazardous chemicals. Finally, practices that may reduce the severity of the impact of a hazardous
chemical release (e.g., by containing its spread and neutralizing volatility) can be grouped together as
release mitigation systems.
Facilities have implemented technological or procedural solutions to increase their ability to
increase their ability to detect and prevent releases. A number of the audited facilities have implemented
accident prevention through major efforts to reduce the hazardous and toxic chemicals they use, either
across the site or at a single unit that could be involved in a release event. As was the case in previous
years audits, the facilities audited this year exhibited a variety of release prevention measures. Many of
the facilities have secondary containment systems and high-level alarms on process and storage vessels.
For example, at one chemical manufacturing facility, the freon reactors in the process area are double
walled with detectors to alert personnel if the inner wall fails. Furthermore, much of the piping
containing hydrogen fluoride is also double walled with similar detection alarms.
Some facilities have initiated measures to ensure that operators can spot and correct potentially
hazardous situations. One chemical manufacturer ensures that the facility does not accept more than
7,500 gallons of chemicals at any one time. In addition, high level alarms have been installed on tanks to
prevent accidental overfilling. Finally, the facility implemented a system where the operator uses a
sign-in sheet to allow another operator to know what has been completed in the bleach making process at
the facility. Another facility has constructed containment areas to prevent spills from the sulfuric acid
tanks located within the facility.
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In some specific cases, audit teams noted that there was room for improvement in the release
prevention and mitigation measures. At a chemical manufacturing facility, the audit team observed that
the containment system at the facility may be inadequate in containing all of the material in the event of a
maximum release. The audit team also pointed out the absence of any containment system in the mixing
area inside the facility, and in the truck unloading area. At one chemical facility, the audit team noted the
absence of ammonia sensors in the process area; the audit team suggested that the facility should install
overflow alarm and high-level sensors on the aqueous ammonia holding tank. In addition, the audit team
recommended that audible alarms should be activated in the building behind the chlorine process
structure.
3.16 Facility Emergency Preparedness and Response
Comprehensive facility emergency planning is a crucial element in effective and rapid response
to accidents. An emergency response program prepares a facility to respond to and mitigate accidental
releases, thereby limiting the severity of such releases and their impact on public health and the
environment. Generally accepted practices with regard to emergency response programs can be
grouped into five activities: developing an emergency response plan; training employees in relevant
emergency procedures; acquiring equipment to support response efforts; conducting drills and exercises
to test the plan and evaluate its effectiveness; and coordinating with the surrounding community. The
first four of these activities are dealt with in this section; coordination with the community, a focus of the
Emergency Planning and Community Right-to-Know Act (EPCRA), is discussed in the following section.
Although there is a common understanding of these key components of an emergency response program,
emergency preparedness and response activities nonetheless can vary significantly for facilities of
varying size and complexity. Facilities that are small, or where the likelihood of a release is minimal,
may choose not to (or be unable to) respond to an incident with their own employees. Such a facility
might choose to maintain evacuation procedures and procedures to contact outside parties (e.g., local
response agencies, contractors), rather than developing extensive emergency response plans.
Emergency Response Plan
A facility's emergency response plan is a critical element in the auditing process because, in
many respects, the plan reflects a cross-cutting set of facility activities and procedures. The plan also
demonstrates the facility's commitment to minimizing harm to its own employees and the surrounding
community if an emergency situation occurs. During an audit, the team reviews the organization of a
facility's emergency response plan, its utility in the potential emergencies that a facility may experience,
and its comprehensiveness. An emergency response plan should be comprehensive in two senses: plan
elements are addressed in a site-specific, rather than generic fashion, and the plan contains all the
critical elements necessary to a successful response effort.
In many cases, audit teams noted that facility emergency response plans appeared to be written to
fulfill regulatory requirements, rather than for use in an actual response, although response and
evacuation procedures were often included within the plan. Audit teams commented on the presence of
multiple emergency plans in some facilities, leading to overlaps and inconsistencies. For example, one
refinery maintains multiple plans associated with emergency preparedness, planning and response. This
facility maintains a Facilities Response Plan, an Emergency Response Action Plan (developed for smaller
spills), and a comprehensive Emergency Response Plan (developed for nonspill-type incidents such as
fires, hazardous material spills etc.) In 1996, EPA, in conjunction with the National Response Team,
issued the Integrated Contingency Plan Guidance to provide a mechanism for facilities to consolidate
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multiple plans into a single, functional emergency plan. This document was intended to increase the
functionality of emergency response plans examined in future audits. It is noteworthy that a few of the
facilities have already developed integrated contingency plans (ICPs). For instance, the ICP at an
electronics manufacturing facility covers the chain of command and each individual's responsibilities,
along with procedures for discovery, initial response, notification, evacuation, assessment, mitigation,
termination, and follow-up of an incident. The ICP at this facility also provides maps displaying
evacuation routes and assembly points throughout the plant.
Audit teams found that many of the facilities have designed their response plans to address
site-specific factors that are unique to the plant. In particular, some of the larger facilities have
developed comprehensive emergency response plans, systems of review of procedures, and trained and
equipped HAZMAT teams to carry out responses. For instance, at one chemical manufacturing facility,
the emergency procedures manual is formally reviewed by the Emergency Preparedness Committee on
even years. Documentation of the revisions are maintained on a cover sheet for the plan, and the review
date, revision date, and personnel responsible for the revision are noted. Another facility manufacturing
medical products maintains a hurricane contingency plan written in Spanish and English; the plan
follows a phased approach that bases specific actions on the anticipated strike time of the hurricane.
Although a number of the audited facilities have specific elements in their response plans that
are site-specific, there are certain standard components that can be found in most of the plans. The
majority of the facilities have evacuation procedures and have marked escape routes on maps posted
around the facility. In most cases, the facilities have evacuation procedures that are well-written and
comprehensive, and clear evacuation instructions that are posted throughout the complex. However, in
some instances the audit teams noted that the evacuation procedures contained in the response plans were
insufficient to ensure employee safety. At one frozen foods processing facility, the audit team found the
evacuation instructions in the response plan for ammonia releases to be inadequate; the audit team
suggested that the response plan should be amended to require NRC and LEPC notification of a release,
and that the instructions should provide for more than one meeting point so that the evacuees will
assemble in the same location upwind. At another facility manufacturing medical products, the audit
team encouraged the facility to revise the evacuation procedures to account for release location, wind
direction and related safety concerns. Sheltering in place was also recommended as an option for
specific release scenarios. In one instance (at a chemical manufacturer), the audit team noted that while
the facility had written emergency procedures, the procedures did not cover notification or evacuation of
adjacent facilities in the event of an emergency. In addition, the audit team also observed that there was
no way of determining wind direction in the event of a release within the facility.
Many audited facilities had plans that were insufficiently detailed or were missing information
that would be critical in an emergency. One facility's emergency response plan includes an explanation
of response command and authority based on a customized version of the National Incident Management
System for emergency management; however, the audit team noted that this facility's unified command
structure needs to be updated to include interfacing with state and federal environmental and response
personnel during emergency and recovery phases of an incident. In another instance, the audit team
noted that the lack of clarity in the procedures about the specific responsibilities of different facility
personnel in the event of an emergency. The audit team suggested that the management at the facility
develop a simplified emergency command and flow chart that summarizes command and control
responsibilities for both facility and corporate personnel.
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Training
Emergency response training must meet the needs of a facility in addition to complying with all
federal requirements; specific training needs may include procedures for spill or vapor containment and
fire fighting, or decision-making on the need for response, evacuation, or in-place sheltering.
Comprehensive emergency response training programs can cover a wide range of site-specific activities,
including evacuation and sheltering procedures, incident command systems, release notification, and fire
fighting.
In line with the trend from previous years, audit teams found that a significant number of
facilities are taking advantage of offsite training opportunities to allow for a mix of site-specific training
and more general response and rescue training in various fields. In addition, many of the facilities are
also taking steps to ensure that facility personnel and management are familiar with emergency response
procedures and to ensure that a qualified manager is on site whenever an incident occurs. For instance, at
a scientific research facility, the facility fire department maintains a comprehensive maintenance and
training program. In addition, personnel are required to have eight hours of hazardous materials
emergency response training and a total of 17 one-hour modules pertaining to emergency notification,
communication, and field monitoring.
However, in some instances audit teams noted that commitment to emergency response training
was inadequate or lacking. At one chemical manufacturing facility, audit teams found that employees are
not provided emergency fire training, although the facility has an "internal fire brigade."; the audit team
encouraged the facility to provide personnel with appropriate training, in accordance with OSHA
regulations. At another facility, the audit team found room for improvement in the training of employees
on the use of SCBA. Facility personnel were encouraged to increase the frequency of the training (they
are currently an annual feature), and ensure that employees don the SCBA and breath a cylinder of air
while performing a task in order to acclimate themselves with the equipment.
Emergency Equipment
Emergency equipment, ranging from safety gear to response vehicles to communications
apparatus, must be available to implement the emergency activities designated in the plan. However,
with the exception of OSHA fire prevention regulations, there are no detailed federal requirements on
what equipment must be available to respond to a hazardous materials emergency. As a result, each
facility must decide which equipment is necessary to address likely accident scenarios and develop a
system for maintaining it. In addition, to be effective, response equipment should be staged in areas not
likely to be affected by an incident, but close enough to be quickly accessed by response personnel.
Facilities often need a range of equipment that can include personal protective equipment,
SCBA, safety showers, and eye-wash stations; absorbents, neutralizing agents, and booms; portable
pumps and hoses and fire monitors; response vehicles; and monitoring instruments, as well as backup
equipment. Some audited facilities keep a significant amounts of response equipment and maintain it on
a regular basis. For example, emergency equipment at one large chemical manufacturer includes a fire
truck, ambulance, and an emergency response vehicle. In addition to these response vehicles, the
facility's inventory of response equipment includes air monitoring equipment, tools, personal protection
equipment, tank repair kits, pumps and compressor hoses, and tank entry equipment. At a chemical
facility in Puerto Rico, the audit team observed that the facility did not have any signs on its storage
cabinets (SCBA storage cabinets) to identify its contents to emergency providers. Furthermore, there are
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36
no signs to distinguish between the empty and the full breathing air tanks used for emergency responses
and personal protection. The audit team recommended that all SCBA tanks that are out of service should
be tagged and placed in an area away from full bottles. Identification of service status was also
recommended for all storage cabinets. At an electronics manufacturer, audit teams noted the presence of
extensive communications apparatus designed to aid in the event of an emergency; the facility has fire
alarms and closed circuit television surveillance cameras which provide security for hazardous material
and waste storage areas, telephones throughout the plant, a beeping system, a paging system, and
walkie-talkie radios to provide communication.
Some facilities, however, either did not have certain emergency response equipment that would
be needed in a response or did not ensure that it was accessible when needed. For example, audit teams
at a scientific research facility found that the facility did not have any wind direction devices (i.e. wind
socks) noted on the site. As a result, during an emergency, responders may be unable to determine wind
direction and could possibly encounter a plume.
In other cases, response equipment was present, but was difficult to locate or reach. For
instance, at a scientific research facility, audit teams observed that the eyewash stations, emergency
stations, emergency showers, and fire extinguisher areas were not clearly visible due to lack of color
contrast or labeling. In addition, fire extinguishers throughout some areas audited were obstructed or not
readily visible, and in other cases were blocked by large objects that would impede access. At a
chemical manufacturer, audit teams found that safety equipment, spill prevention, and fire suppression
systems were not easily discernible due to the lack of contrasting background colors. The audit team
suggested that the facility should ensure that all chemical containers, tanks, and storage areas should be
labeled legibly, with lettering visible from 50 feet, and also recommended that containers received and
shipped by the facility should be appropriately labeled with required hazard communication markings
and proper DOT shipping labels. At another facility, audit teams encouraged the facility personnel to
verify that all fire hoses are serviced, tested, and marked as required by NFPA Standard 1962, and to
ensure that background areas around all fire fighting equipment are painted red in accordance with the
ANSI Standard Safety Color Code.
Some facilities were found lacking with regard to fire protection and other safety equipment. At
one facility fire doors were noted to be chained, closed, or choked open. Furthermore, the audit team
found that one of the doors is constructed of a chain link fence, which is not a fire retardant barrier . At
another facility, the audit team observed locations where safety shower and eye wash stations were
located in close proximity to electrical equipment. The audit team suggested that the facility should
inspect the safety shower and eye wash stations to ensure that in their use water would not spray or
run onto electrical outlets, switches, or other energized devices.
Drills and Exercises
Drills and exercises supplement training and allow each employee to understand more clearly
what steps to take in the event of an emergency. Testing emergency procedures, such as evacuation
routes, internal/external alert systems, and community coordination, enhances response time and
demonstrates whether the procedures are viable in an emergency. Drills and exercises generally cover
evacuations, fire fighting, and medical and rescue operations; field response to a hazardous materials
event may also be addressed, although generally with somewhat lesser frequency.
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37
Almost all the audited facilities conduct drills and exercises, although some facilities did not
have a regular schedule for conducting such activities. Most facilities conduct drills and activities
generally on an annual basis. The schedules were found to be more structured in some facilities
compared to others. For instance, the Emergency Preparedness Committee at a large chemical
manufacturing facility manages the drill schedule by coordinating activities between facility areas and
departments, assigning the drill team and issuing critique reports. The Fire Protection Supervisor
coordinates fire brigade activities in scheduled drills, manages fire brigade training, and manages drill
functions specific to fire protection. Each facility area conducts annual tabletop drills that address
emergency responses requiring only area response. An annual plant wide emergency response exercise
that mobilizes community responders is also performed. This exercise is designed to involve the local fire
department as well as the LEPC. At another medical manufacturing plant, facility wide evacuation drills
are conducted twice a year on each shift. In addition, the fire brigade conducts joint drills with the local
fire department during both day and night shifts.
Depending on the facility, these efforts involve local response organizations and neighboring
facilities in varying degrees. At one chemical facility, the audit team noted that during the audit the
facility management had mentioned a plan to conduct a mock emergency response drill that would
involve all local emergency personnel and the surrounding community as well as the EPA. In some
instances, the audit teams noted that the notification procedures could be improved. For instance, at one
facility, the audit team suggested that the facility should perform an evaluation of the notification
procedures in drill exercises, and specifically suggested that the facility should consider providing a list
of facility personnel names and phone numbers in descending order of the highest ranking official.
Other facilities conduct joint exercises much less frequently, or not all. In some instances, audit
teams encouraged facilities to begin conducting drills and exercises with the LEPC, fire department or
other response organizations, and to take advantage of regularly scheduled drills and exercises being
conducted in their areas. Audit teams did not specifically discuss whether follow-up on drills and
exercises were conducted by facilities.
3.17 Community Emergency Response Coordination
Working with local response organizations and the LEPC on emergency planning initiatives,
drills and exercises, mutual aid arrangements, and other response issues completes the circle of
preparedness begun with facility emergency preparedness activities. Although many facilities initially
respond to and contain an emergency themselves, local first responders are normally involved in
responding to those release events that threaten public health and safety. Coordination with public
officials is of special importance to those facilities that depend on local responders for response to any
onsite incident; appropriate responses to their hazards should be addressed in the community emergency
response plan developed under EPCRA.
Almost all of the audited facilities work with the community to some extent with regard to
emergency preparedness. For many facilities, this consists primarily of fire prevention and pre-planning
with local officials during fire inspections. However, some audited facilities are LEPC members,
participate regularly in the local planning process, and distribute copies of their emergency response plan
to affected parties within the community. As discussed in the preceding section, a number of facilities
also are taking advantage of opportunities to increase emergency preparedness by conducting drills and
exercises with LEPCs and local response organizations.
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38
Many of the audited facilities have adopted a proactive approach to working with the community
to improve emergency response coordination. For instance, one chemical facility works closely with the
LEPC and nearby residents for awareness, training and emergency preparedness purposes. The facility
held an open house for residents in the area, and also performs a yearly walk-through with the local
emergency responders. In addition, the facility also cooperates with the local fire department, civil
defense, and the area hospital, to provide them with an understanding of the chemicals used at the
facility. Another refinery has adopted a unique strategy for demonstrating its commitment to the
communities in which it operates; this facility has developed partnerships with local high schools in the
area and also sponsors a Junior Achievement Program in the area. These features are in addition to the
facility's continued involvement with the Mobile County Fire Department (MCFD) and LEPC in the
area.
A number of the facilities have also undertaken extensive efforts to develop notification and
communication systems for interacting with the local community in the event of an incident, while some
of the others depend on local police and fire departments. At one of the audited facilities (a medical
manufacturing plant), the facility nurse visits all local hospitals to educate their staff on treatment
methods for chemical burns, and the plant manager is identified as being in charge of external
notifications. However, the audit team noted the facility has not established any notification procedures
or lines of procedures with the prison that is located adjacent to it. In certain instances, audit teams
observed that the facility does not have any communication systems in place for interacting with the local
communities. For instance, one facility does not participate in any outreach programs with the
surrounding community, and does not participate in any joint training activities with the adjoining
hospitals or emergency medical services.
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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
7.0 CHEMICAL ACCIDENT PREVENTION
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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 PREPAREDNES S 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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LIST OF CHEMICAL SAFETY AUDITS
as of September 30, 1998
REGION DATE OF AUDIT
1 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
12/18/91
01/27-30/92
06/25-26/92
10/28-30/92
05/11-14/93
08/24-25/93
03/23-25/94
06/14-15/94
07/19-22/94
2 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
03/25-26/92
06/22/92
06/23/92
06/24/92
11/11-12/92
6/21-23/93
Unknown
07/19-21/93
10/12-13/93
06/28-30/94
02/01-02/95
07/07/95
09/26/96
05/06/96
05/07/96
09/12/96
06/09/97
06/24/97
REPORT STATUS NAME OF FACILITY
X
Polysar, Inc., Indian Orchard, MA
X
W.R. Grace, Nashua, NH
X
Fall River Treatment Plant, Fall River, MA
X
Upjohn Co., North Haven, CT
X
Bradford Soap Works, W. Warwick, RI
X
Jones Chemicals, Merrimac, NH
X
Monet Crystal Brands, Pawtucket, RI
X
LCP Chemicals, Orrington, ME
X
Hercules, Inc., Chicopee, MA
X
Pacific Anchor, Cumberland, RI
X
Rising Paper Company, Housatonic, MA
X
Johnson Controls, Benington, VT
X
Hoechst Celanese, Coventry, RI
X
Pratt & Whitney, Southington, CT
X
James River, Old Town, ME
X
Monsanto, Springfield, MA
X
Davol, Cranston, RI
X
H.C. Starck, Newton, MA
X
Cambridge Plating Company, Belmont, MA
X
Georgia-Pacific, Woodland, ME
X
BASF, Rensselaer, NY
Xerox Corporation, Webster, NY
X
Du Pont Agrichemicals, Manati, PR
X
Bacardi Rum, San Juan, PR
X
Goodyear, Niagara Falls, NY
X
BASF, Washington, NJ
X
C.P. Chemicals, Sewaren, NJ
X
3M/0-Cell-0, Tonawanda, NY
X
Schenectady Chemicals, Schenectady, NY
X
CPS Chemical Company, Old Bridge, NJ
X
Caguas WWTP, Caguas, PR
X
Puerto Nuevo WWTP, San Juan, PR
X
Bayamon WWTP, Catano, PR
X
Witco Corporation, Brooklyn, NY
X
ArsynCo, Carlstadt, NJ
PRASA
X
International Paper, Ticonderoga, NY
X
Pfizer, Barceloneta, PR
X
Occidental Chemicals, Niagara Falls, NY
X
Hoffman-LaRoche, Nutley, NJ
Middlesex County WWTP, Sayreville, NJ
X-D
Patclin Chemicals, Yonkers, NY
X-D
PNC, Nutley, NJ
X-D
Elan Chemicals, Newark, NJ
X-D
Dexter Chemical Company, Bronx, N
X-D
Ecolab, Avenel, NJ
X-D
Clorox Company, Caguas, PR
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REGION DATE OF AUDIT
REPORT STATUS NAME OF FACILITY
06/25/97 X-D
09/08-09/97 X-D
3 07/30-08/03/89 X
08/14-16/89 X
09/11-12/89 X
09/25-26/89 X
01/31 & 02/02/90 X
02/12-16/90 X
03/26-28/90 X
08/20-22/90 X
01/07-10/91 X
04/15-16/91 X
04/23-25/91 X
05/21-23/91 X
11/19-22/91 X
02/03-07/92 X
04/27-29/92 X
07/07-10/92 X
07/28-29/92 X
11/09-11/92 X
01/12-14/93 X
03/09-11/93 X
05/18-20/93 X
06/22-23 & 07/14 1993 X
09/27-29/93 X
11/03-05/93 X
02/23-24/94 X
04/06-08/94 X
04/20-22/94 X
05/11-13/94 X
06/01-03/94 X
09/19-21/94 X
11/11-13/94 X
01/10-11/95 X
02/06-08/95 X-D
02/14-16/95 X
07/11-13/95 X-D
4 03/20-24/89 X
05/01-05/89 X
07/11/89 & 08/03-04/89 X
07/18-20/89 X
08/17/89 & 09/11-15/89 X
02/12-13/90 X
02/26-03/02/90 X
04/04-05/90 X
05/08-11/90
09/11-13 & 24-27/90 X
10/26/90 X
Ohmeda Caribe, Guayama, PR
Brookhaven National Lab, Upton, NY
Rhone-Poulenc, Charleston, WV
LCP Chemicals, Inc., Moundsville, WV
Purolite Company, Philadelphia, PA
Carl Falkenstein, 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
Vista Chemicals, Baltimore, MD
Allied-Signal, Hopewell, VA
BP Oil Refinery, Marcus Hook, PA
Huntsman Chemical Corp., Chesapeake, VA
Beatrice Cheese, Whitehall, PA
Allied-Signal, Philadelphia, PA
Weirton Steel, Weirton, WV
Koppers Industries, Follansbee, WV
Merck and Company, Riverside, PA
Konsyl/Trinity, Easton/Salisbury, MD
Allied-Signal BF3 Plant, Marcus Hook, PA
Hoechst Celanese, Narrows, VA
Jones Chemicals, Milford, VA
GE Specialty Chemicals, Morgantown, WV
PPG Industries, New Martinsville, WV
Armstrong World Industries, Lancaster, PA
Carpenter Technology, Reading, PA
Union Camp, Franklin, VA
Air Products and Chemicals, Hometown, PA
Standard Chlorine, Delaware City, DE
Sunoco Girard Point, Philadelphia, PA
Blue Plains WWTP, Washington, DC
Cytec Industries, Willow Island, WV
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, Savannah, GA
Astrotech, Titusville, FL
Cardinal Chemical Co., Columbia, SC
Tennessee Chemical Co., Copper Hill, TN
Kason Industries, Newnan, GA
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REGION DATE OF AUDIT
REPORT STATUS NAME OF FACILITY
11/29/90 X
12/4-5/90 X
12/4-5/90 X
12/12/90 X
01/07-10/91 X
01/22-25/91 X
01/30-31/91 X
02/20-21/91 X
02/25-26/91 X
03/04-08/91 X
03/19/91 X
03/27/91 X
04/02/91 X
08/26-29/91 X
11/12-14/91 X
01/21-24/92 X-ND
03/24-26/92 X
04/28-05/01/92 X
07/20-21/92 X
08/25-26/92 X-ND
08/03-07/92 X
11/16-20/92 X
01/04-08/93 X
02/01-02/93 X
02/02-03/93 X
02/04-05/93 X
03/29-04/02/93 X
03/29-04/02/93 X
07/12-13/93 X
08/02-06/93 X
11/29-12/02/93 X
12/07-08/93 X
01/11-13/94 X
02/07-11/94 X
04/05-06/94 X
04/15-29/94 X
04/26-28/94 X
07/11-15/94 X
10/17/94 X
11/01-03/94 X
11/14-18/94 X
12/12-15/95 X
01/24-27/95 X
01/30-02/03/95 X
04/17-21/95 X
06/04-09/95 X
06/19-23/95 X
11/27-12/01/95 X
02/12-16/96 X-R
02/13-15/96 X-R
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
West Lake Monomers, Calvert City, KY
Piney Point Phosphates, Piney Point, FL
Reichold Chemicals, Kensington, GA
G.E. Lighting Systems, Hendersonville, NC
Jones Chemicals, Charlotte, NC
Peridot Chemical Company, Augusta, GA
Velsicol Chemicals, Chattanooga, TN
Mississippi Chemicals, Yazoo City, MS
DuPont, Louisville, KY
IMC Fertilizer, Tampa, FL
Seminole Fertilizer, Tampa, FL
CF Industries, Tampa, FL
Jones Chemicals, Mobile, AL
Occidental Chemicals, Mobile, AL
Trojan Battery, Lithonia, GA
Ciba-Geigy, Mclnstosh, AL
High Point Chemicals, High Point, NC
Grady Hospital, Atlanta, GA
Albright and Wilson, Charleston, SC
Sherwin-Williams, Richmond, KY
Allied Universal, Leesburg, FL
First Chemical Corporation, Pascagoula, MS
Witco Corporation, Memphis, TN
General Electric, Burkville, AL
Ashland Petroleum, Ashland, KY
Holox Limited, Union City, GA
Tennessee Eastman, Kingsport, TN
Union Carbide Corporation, Tucker, GA
PCR, Gainesville, FL
Scott Paper Company, Mobile, AL
Henkel Corporation, Charlotte, NC
Arcadian Fertilizer, Augusta, GA
American Synthetic Rubber, Louisville, KY
Degussa Corporation, Theodore, AL
Vicksburg Chemical Company, Vicksburg, MS
Gilman Paper Company, St. Marys, GA
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REGION DATE OF AUDIT
REPORT STATUS NAME OF FACILITY
04/15-19/96 X-R
07/15-19/96 X-R
11/18-22/96 X-R
02/10-14/97 X-R
03/17-21/97 X-R
05/05-09/97 X-R
09/22-26/97 X-R
11/03-07/97 X-R
11/14/97 X-R
01/12-16/98 X-R
02/09-13/98 X-R
07/20-23/98 X-R
5 07/25-28/89 X
08/08-11/89 X
09/15/89 X-D
03/05/90 X-D
03/26-30/90 X-D
04/14-18/90 X
06/11-15/90 X-D
07/16-19/90 X-D
03/18-20/91 X
05/20-22/91 X
08/12-14/91 X
03/10-12/92 X
04/21-23/92 X
06/02-04/92 X
11/03-05/92 X
12/15-17/92 X
04/13-15/93 X
06/15-17/93 X
07/20-21/93 X
08/17-18/93 X
03/29-31/94 X
08/31-09/01/94 X
10/11-12/94 X
02/21-23/95 X
05/02-04/95 X
06/06-08/95 X
08/15-17/95 X
07/09-11/96 X-D
09/22-24/96 X-D
6 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
CONDEA Vista, Aberdeen, MS
Vinings Industries, Marietta, GA
Great Lakes Chemical, Newport, TN
Riverwood International, Macon, GA
Platte Chemical Corporation, Greenville, MS
MAPCO, Memphis, TN
Halocarbon Products, North Augusta, SC
DuPont Fluoroproducts, Louisville, KY
Sony Music, Carrollton, GA
NIPA Hardwicke, Elgin, SC
Shell Chemical, Mobile, AL
Eastman Chemicals, Eastman, South Carolina
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, Ashtabula, OH
Elf Atochem, Riverview, MI
BASF Corporation, Wyandotte, MI
G.E. Superabrasives, Worthington, OH
Yenkin-Majestic Paints, Columbus, OH
Allison Gas Turbine, Indianapolis, IN
Lomac Corporation, Muskegon, MI
Specialty Chem, Marinette, WI
Witco, Chicago, IL
Interplastic, Minneapolis, MN
Upjohn Company, Portage, MI
Stepan Company, Elwood, IL
Farley Company, Brimfield, OH
Capital Resin Corporation, Columbus, OH
Clark Refining and Marketing, Blue Island, IL
Spectrulite Consortium, Madison, IL
Waldorf Corporation, St. Paul, MN
Hydrite Chemical, Oshkosh, WI
ISP Fine Chemicals, Columbus, 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
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REGION DATE OF AUDIT
REPORT STATUS NAME OF FACILITY
01/17-18/90 X
04/17-19/90 X
03/05-06/91 X
03/20-22/91 X
05/01-03/91 X
07/09-11/91 X
08/27-29/91 X
02/25-26/92 X
06/09-10/92 X
08/17-18/92 X
08/24/92 X
11/17-18/92 X
03/16-17/93 X
08/31-09/03/93 X
09/08-09/93 X
10/05-07/93 X
12/14-15/93 X
06/07-09/94 X
08/23-25/94 X
11/01/94 X
11/02/94 X
11/15-17/94 X
08/22-25/95 X-D
7 10/25/90 X
11/20/90 X
05/01/91 X
07/31/91 X
12/04/91 X
05/06-07/92 X
06/15-16/92 X
06/22-23/92 X
07/15/92 X
08/17-18/92 X
08/31/92 X
09/03/92 X
09/30/92 X
12/16/92 X
12/18/92 X
04/26/93 X
05/13/93 X
05/11/93 X
06/03/93 X
06/29/93 X
07/08/93 X
07/21/93 X
07/29/93 X
08/05/93 X
10/11/93 X
10/12/93 X
11/09/93 X
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
Safety-Kleen Corporation, Denton, TX
Halliburton Services, Caldwell, TX
Houston Woodtech, Houston, TX
Allied-Signal, Geismar, LA
CPS Chemicals, West Memphis, AR
Labbco, Inc., Slidell, LA
Chevron USA, El Paso, TX
Harcros Chemicals, Dallas, TX
Ethyl Corporation, Magnolia, AR
Champion Technologies, Odessa, TX
Phillips 66, Borger, TX
Sterling Chemicals, Texas City, TX
Creamland Dairies, Albuquerque, NM
DPC Industries, Albuquerque, NM
Navajo Refining Company, Artesia, NM
Formosa Plastic, Point Comfort, TX
ICI Americas, Omaha, NE
Jacobson Warehouse, Des Moines, IA
ABB Power Transformers, St. Louis, MO
Hydrozo, Inc., Lincoln, NE
Rhone-Poulenc, Sedalia, MO
American Cyanamid, Hannibal, MO
Proctor and Gamble, Kansas City, KS
Hercules Aqualon Company, Louisiana, MO
Cotter and Company, Kansas City, MO
Cornbelt Chemical Company, McCook, NE
Eagle Lithographing, Kansas City, MO
Independence WWTP, Sugar Creek, MO
Flexel, Inc., Tecumseh, KS
Arcadian Fertilizer, Clinton, IA
Rock Creek WWTP, Independence, MO
Rhone-Poulenc AG, St. Louis, MO
LaRoche Industries, Crystal City, MO
Golden Valley Cheese, Clinton, MO
Total Petroleum, Arkansas City, KS
Farmland Petroleum, Coffeyville, KS
AG Processing, Eagle Grove, IA
Farmland Industries, Lawrence, KS
Beech Aircraft, Wichita, KS
Ralph Green Plant, Pleasant Hill, MO
Whitmire Research Lab, Valley Park, MO
Doe Run Company, Herculaneum, MO
Ecolab Pest Elimination, Kansas City, MO
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REGION DATE OF AUDIT
REPORT STATUS NAME OF FACILITY
11/30/93
X
Carmar Group, Carthage, MO
01/13/94
X
Cook Composites, N. Kansas City, MO
02-05/94
X
Van Waters and Rogers, St. Louis, MO
02/11/94
X
Wells' Dairy, Le Mars, IA
02/15-07/18/94
X
3M, Springfield, MO
02/17/94
X
Armour Swift-Eckrich Plant, Kansas City, MO
02/28/94
X
Terra International, Sergeant Bluff, IA
04/19/94
X
Seitz Foods, St. Joseph, MO
04/28/94
X
Fleming Foods, Sikeston, MO
05/04-06/94
X
Mallinckrodt Chemicals, St. Louis, MO
06/22/94
X
Meadow Gold Dairies, Des Moines, IA
06/23/94
X
3M Commercial Graphics, Nevada, MO
07/08/94
X
ICI Explosives, Joplin, MO
09/15/94
X
BioKyowa, Cape Girardeau, MO
09/29-30/94
X
Elf Atochem, Wichita, KS
11/08/94
X
IES Industries, Marshalltown, IA
11/10/94
X
Dyno-Nobel, Louisiana, MO
11/28/94
X
Vulcan Chemicals, Wichita, KS
12/30/94
X
Chemcentral, Maryland Heights, MO
12/31/94
X
Hudson Foods, Noel, MO
01/17/95
X
Nat. Coop. Refinery Assoc., McPherson, KS
01/31/95
X
St. Louis Water Company, Florissant, MO
02/09/95
X
Howard Bend WWTP, Chesterfield, MO
03/28/95
X
Chemtech, Kansas City, MO
05/08/95
X
Douglas Battery, N. Kansas City, MO
05/12/95
X
Slay Bulk Terminals, St. Louis, MO
06/13/95
X
Extrusions, Fort Scott, KS
06/16/95
X
Philip Environmental, Kansas City, MO
07/14/95
X-R
Wagner Brake, Berkeley, MO
09/14/95
X
Foamex, Cape Girardieu, MO
02/12/96
X-R
Siegwerk, Inc., Greenfield, IA
04/09/96
X-R
Koch Sulfur Products, DeSoto, KS
08/08/96
X-R
General Motors, Kansas City, KS
11/04/96
X-R
Owens-Corning, Kansas City, KS
11/08/96
X-R
Tyson Foods, Monett, MO
12/13/96
X-R
Copeland Corporation, Lebanon, MO
01/29/97
X-R
United Refrigeration Services, Wichita, KS
10/02/97
X-R
Agrium Homestead Nitrogen, Beatrice, NE
10/07/97
X-R
Morton International, Hutchinson, KS
02/10/98
X-R
Reames Foods, Clive, IA
08/05/98
X-R
LaRoche Industries, Crystal City, MO
05/02-04/89
X
Phillips Refinery, West Bountiful, UT
06/13-15/89
X
Chevron Chemical, Rock Springs, WY
08/15-17/89
X
Western Forge, Colorado Springs, CO
03/27/90
X
Koppers Industries, Denver, CO
05/15-17/90
X
Amoco Production Company, Powell, WY
06/26-29/90
X
Amoco Casper Refinery, Casper, WY
08/27-31/90
X
Western Zirconium, Ogden, UT
11/01/90
X
Jemm Plating, Co., Denver, CO
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REGION DATE OF AUDIT
REPORT STATUS NAME OF FACILITY
02/06-07/91 X
02/19-21-91 X
04/30-05/03/91 X
05/29-31/91 X
09/29-30/91 X
11/12-13/91 X
02/18-20/92 X
02/25-27/92 X
05/27-29/92 X
08/18-19/92 X
02/09-12/93 X
05/18-21/93 X
06/15-18/93 X
09/08-10/93 X
03/01-04/94 X
05/03-06/94 X
06/07-10/94 X
09/13-15/94 X
07/10-14/95 X-D
08/29-31/95 X-D
09/18-21/95 X-D
9 05/12-13/89 X
07/25-27/89 X
08/16-17/89 X
09/07-08/89 X
04/17-20/90 X
06/19-22/90 X
07/17-20/90 X
09/10-16/90 X
04/09-12/91 X
07/16-19/91 X
08/20/91 X-ND
08/21-23/91 X
02/11-14/92 X
06/08/92 X
07/14-17/92 X
08/24-27/92 X
02/23-24/93 X
05/04-05/93 X
07/27-30/93 X
04/12-15/94 X
07/19-21/94 X
10/06-08/94 X
12/05-08/94 X
08/14-15/95 X-D
08/16/95 X-D
08/05-09/96 X-ND
10 07/27/89 X
SAS Circuits, Littleton, CO
Kodak-Colorado Division, Windsor, CO
Col. Falls Aluminum, Columbia Falls, MT
Syncom Techologies, Mitchell, SD
LaRoche Industries, Orem, UT
T.G. Soda Ash, Granger, WY
Coastal Chemical, Cheyenne, WY
Chevron Refinery, Salt Lake City, UT
Rhone-Poulenc, Butte, MT
ALCHEM, Ltd., Grafton, ND
Stone Container Corp., Missoula, MT
Magnesium Corp., Salt Lake City, UT
Frontier Refining, Cheyenne, WY
Koch Sulfur Products, Riverton, WY
Dakota Gasification, Mercer County, ND
John Morrell, Sioux Falls, SD
Huish Detergents, Salt Lake City, UT
Montana Refining, Great Falls, MT
Coors Brewing Company, Golden, CO
Anheuser Busch Brewer, Fort Collins, CO
Sinton Dairy Foods, Colorado Springs, CO
Nunes Cooling, Salinas, CA
Unocal Chemical, Brea, CA
Eticam of Nevada, Fernley, NV
Coronado Generator, St. Johns, AZ
Ultramar Refinery, Wilmington, CA
Magma Copper, 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
Brewer Environmental Services, Honolulu, HI
General Chemical Corporation, Pittsburg, CA
Chevron Refinery, Richmond, CA
Shell Oil Refinery, Martinez, CA
Brewer Environmental Services, Honolulu, HI
Union Pacific Railroad, Stockton, CA
Louisiana Pacific Pulp Mill, Samoa, CA
ATSF Rail Yard, Barstow, CA
General Chemical Corporation, Pittsburg, CA
Kerley Ag, Antioch, CA
Southern Pacific Lines, Long Beach, CA
Pimalco, Chandler, AZ
Solkatronic Chemical, Chandler, AZ
Puna Geothermal Venture, Hawaii
All Pure Chemical Company, Kalama, WA
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REGION DATE OF AUDIT
REPORT STATUS NAME OF FACILITY
08-10/89
X
ITT Rayonier, Port Angeles, WA
09/12-15/89
X
McWhorter Northwest, Portland, OR
03/19-23/90
X
BP Oil Company, Ferndale, WA
04/23-27/90
X
FMC Corporation, Pocatello, ID
05/14-18/90
X
Neste Resins, Springield, OR
09/24-28/90
X
Unocal Chemicals, Kenai, AK
01/08/91
X
Occidental Chemicals, Tacoma, WA
01/15-18/91
X
Chevron USA, Seattle, WA
03/18-22/91
X
James River Corporation, Clatskanie, OR
04/22-26/91
X
Potlatch Corporation, Lewiston, ID
07/23-26/91
X
Great Western Chemical Co., Nampa, ID
08/05-09/91
X
Boise Cascade Mill, Wallula, WA
02/24-28/92
X
Georgia-Pacific Paper Division, Toledo, WA
03/23-27/92
X
SEH America, Vancouver, WA
04/28-05/01/92
X
Amalgamated Sugar Company, Twin Falls, ID
07/27-31/92
X
ALCOA, Wenatchee, WA
11/16-20/92
X
Weyerhauser Company, Springfield, OR
01/25-29/93
X
Wacker Siltronics, Portland, OR
04/12-16/93
X
Ponderay Newsprint, Usk, WA
07/26-27/93
X
Darigold, Caldwell, ID
07/28-29/93
X
Simplot, Caldwell, ID
10/25-29/93
X
Unocal, Kennewick, WA
02/14-17/94
X
Boise Cascade, Medford, OR
03/22-25/94
X
Ocean Spray, Markham, WA
06/20-24/94
X
Elf Atochem, Portland, OR
11/14-15/94
X
Southern Oregon Marine, Coos Bay, OR
11/16/94
X
South Coast Lumber, Brookings, OR
02/27-03/03/95
X
Georgia-Pacific, Bellingham, WA
06-05-09/95
X
American Microsystems, Pocatello, ID
11/13-17 and 12/11-13/95
X-D
Kalama Chemical, Kalama, WA
04/08-11/96
X-D
Blount International, Lewiston, ID
07/08-11/96
X-D
Fujitsu Microelectronics, Gresham, OR
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Notes:
1. "X" indicates that the final report has been received, and the profile has been entered into the database.
2. "X-R" indicates that the final report and the profile has been received, and the profile will be finalized.
3. "X-D" indicates that only the final report has been received, and the profile will be developed and completed.
4. "X-ND" indicates that the final report has been received, but no profile will be prepared because the audit was a
follow-up visit, rather than a new audit.
5. Bold text indicates that the final report has not yet been received.
6. The audit conducted by Region 10 at ITT Rayonier in Port Angeles, WA, occurred over a period of several
months.
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