Post on 21-Dec-2015
CalARP FormalEvaluation Review
Presented By:
Beronia Beniamine, Stanislaus County, Senior Hazardous
Material Specialist
&
Greg Taylor, Foster Farms, Corp. PSM Specialist
GENERAL CalARP REGUIREMENTS
Process Applicability Management System Registration Information Qualified Person Certification Recordkeeping Hazard Assessment Emergency Response Program2/3 Requirements Updates
Management System
Does the facility have a CalARP/RMP management system?
Has a qualified person/position been assigned the responsibility for CalARP/RMP compliance?
Can the facility demonstrate that there is not a conflict of interest in their management program (e.g. is the person responsible for the programs also responsible for minimizing costs)?
Registration Information
Are items a-u in section 2740.1 of the CCR identified? Please refer to the Formal Evaluation Checklist, it includes all the June 24, 2004 changes.
We have handouts with the Formal Evaluation Checklist that you can pick up at the end of our presentation.
HAZARD ASSESSMENT
Offsite Consequence Analysis Parameters Worst-Case Release Scenario Analysis Alternative Release Scenario Analysis Defining Offsite Impacts to the Population Defining Offsite Impacts to the Environment Offsite Consequence Analysis Review and Update Offsite Consequence Analysis Documentation
Five-Year Accident History
Offsite Consequence Analysis
Was the analysis performed by qualified people? Are the technical assumptions credible? Was the source of the population estimate data
identified? Was the model used valid for the type of material? Was the initiating event for the scenario derived from a
valid resource? (e.g. PHA/HR, accident history, industry evidence, etc.)
Does the analysis describe the impacts on local population and the environment?
Will any safeguards claimed withstand the event and still function?
Offsite Consequence Analysis
Do the system operators know what will happen if a worst case scenario takes place?
Is the worst case scenario up to date (within 5 years or within 6 months of a major change)?
Do the system operators know what will happen if an alternative case scenario takes place?
Is the alternative case scenario up to date (within 5 years or within 6 months of a major change)?
While CalARP and EPA regulations require estimating the population within a circle having a radius equal to the distance to toxic endpoint, the actual area affected by the scenarios as predicted by most models is less than 6% of the area of the circle.
Typically the population that will likely be affected is significantly less than what is reported in a facilities CalARP Worst-Case and Alternative Release Scenarios!
Note: 2004 ERG NH3 Worst-Case downwind evacuation is 1.4 miles!
Wind
Variables & Modifying ConditionsVariables & Modifying ConditionsRelated to Downwind DistancesRelated to Downwind Distances
Location– (inside building vs. open field vs. downtown)
Weather– (wind, temperature, rain)
Size of problem– (5 gallon vs. 5,000 gallon)
Stage of incident– (short vs. long duration release)
Nature of materials– Semi Bad Stuff, Bad Stuff, or Really Bad Stuff
Type, condition & behavior of container/vessel
Responders & equipment
Availability & amount of control agents
Anhydrous Ammonia @ 20,000 ppm can be in the form of a visible cloud and is fatal now!
Anhydrous Ammonia @ 20,000 ppm can be in the form of a visible cloud and is fatal now!
Note what happens when anhydrous ammonia is released as an aerosol! An aerosol is heavier than air and in its vapor form its lighter that air!
UpwindUpwind
The result of a state-wide drill was that the ammonia lifted over the firefighters and dropped down on the spectators.
Emergency Response
Emergency Response Applicability– Emergency Action Plan
• Owner or operator whose employees will not respond to accidental releases of regulated substances need to meet the following:
– Coordinate with community plan
– Coordinate with fire agencies for flammables.– Procedures for notifying emergency responders.
Emergency Response Program
Emergency response program shall include the following:– Emergency Response/Action Plan;
• Procedures for informing/interfacing w/agencies/public;
• Documentation of first aid/medical monitoring treatment;
• Post incident response procedures;
– Procedures for equipment use, inspection, testing, maintenance.
– Training in Incident Command System.
– Procedures in place to review and update plan
– Coordination w/community emergency response plan.
Emergency Response Program
If employees are involved in emergency response does the plan address the following?– Emergency recognition
– Safe distances and places of refuge
– Site security and control
– Are event specific plans (e.g. IAP and SSP) developed prior to entry into IDLH environments per CCR Title 8, Section 5192 requirements.
– Etc…
IN C ID E N T O B JE C T IV E S
1 . IN C ID E N T N A M E
A m m onia R elease ? Y E S __ N O __ 2 . D A TE PR E PA R E D
____ /____ /_____
3 . T IM E PR E PA R E D
__________________________
4 . O P E R A T IO N A L P E R IO D (D A T E /T IM E ) ____ /____ /____ _____ H ours (T yp ically 2 to 8 H ours)
5 . G E N E R A L C O N T R O L O B JE C T IV E S FO R T H E IN C ID E N T (IN C L U D E A L T E R N A T IV E S) T he safe ty o f a ll personnel on site m ust be our first consideration . P ro tect life , environm ent & p roperty (rem em ber L ife is 1 st, E nvironm ent is 2 nd , & P roperty is last!
P rio rity C on tro l O b jective IC S A ssignm ent: E stab lish in itia l iso la tion perim eters per E R G guidelines and contro l access to a ll areas o f th is incident. R em ain up w ind , upgrade and upstream o f any re lease . A ssigned to : E n ter N am e(s)
S afety: T he sa fe ty o f a ll personnel o n site m ust be our firs t consideration .
Iso la te & D eny E ntry: T his m eans an evacuation o f the im m ediate area and contro l o f a ll entry po ints to p ro tect o ther personne l in surround ing areas. R em ain up w ind , up grade and upstrea m o f any release . In itia l Iso lation D istance ________ feet.
N o tifica tio ns: (P lant, M anagem ent, 9 -1 -1 (F ire , H azM at & P o lice), N at’l R esponse C ente r, S ta te O E S , & C o unty A A , and o thers as necessary e .g . L ocal W ater T reatm en t, R egional W a ter Q ua lity, F ish & G am e, e tc .) C ircle those that have been o r are being no tified .
C o m m and: IC S positions are docum ented on the S ite Sa fety P lan.
Identifica tion & H azard A ssessm ent: H azards are docum ented on the S ite Sa fety P lan "Sections III & IV "
A ction P lanning: E xam ple: re scue, reconna issance, conta inm en t, contro l, o r no action until adequate resources arrive . C irc le those tha t are being considered .
S am p le In cid ent A ction P lan (IA P )S am p le In cid ent A ction P lan (IA P )
Protective Equipment: Protective equipment being used to take safe defensive actions: ____________________________________
Containment & Control: Defensive Steps being considered and or taken: _______________________________________________
Protective Actions: Notify appropriate agencies (e.g. Police, Fire, County, etc.) that measures need to be taken to protect persons beyond our property lines. This might include evacuation or shelter in place. Agencies have been notified? Yes ___ or No ___
Decontamination: Initially setup for 2 - stage emergency decon to protect life.
D isposal: Follow all applicable laws and regulations if any HazW aste is generated.
Documentation: Including but not limited to IAP, Site Safety Plan, IC Emergency Incident Log, Incident Investigation, and Critique.
6 . W E ATHE R FO R E C AS T FO R O P E R ATIO NAL P E R IO D: Te m p : Ho t, Mild o r C o ld S ky: C le a r o r C lo u d y Hu m id ity: Dry, F o g g y, R a in Win d : No n e , Lig h t, Me d ium , He a vy (C irc le a ll th a t a p p ly) Lo g a c tu a l c o n ditio ns in c lu d in g : Te m p _ _ _ _ _ _ _ , W ind S p e e d _ _ _ _ _ _ _ , W in d Dire c tio n _ _ _ _ _ _ _ .
7 . G E NE R AL/S AFE TY ME S S AG E Th e s a fe ty o f a ll p e rs o n n e l o n s ite m us t b e o u r firs t c o ns id e ra tio n . S a fe ty o f th e re s p o n s e p e rs o n n e l is o f th e h ig h e s t p rio rity. All wo rk is to b e c o n d uc te d in a s a fe m a n n e r a n d if a n y u ns a fe c o n d itio n is e n c o u n te re d it s h ou ld b e im m e d ia te ly re p o rte d to th e S a fe ty O ffic e r. Th e e n try te a m is to im m e d ia te ly le a ve th e Ho t Zo n e if a n y u ns a fe co n d itio n is e nc o u n te re d .
8. ATTACHM ENTS (? IF ATTACHED) ORGANIZATION LIST (ICS 203) M EDICAL PLAN (ICS 206) HAZ M AT SITE SAFETY PLAN
DIVISION ASSIG NM ENT LISTS (ICS 204) INCIDENT M AP ___________________________
COM M UNICATIONS PLAN (ICS 205) TRAFFIC PLAN ___________________________
202 CSTI 9. PREPARED BY:
_________________________________________
10. APPROVED BY INCIDENT COM M ANDER
_______________________________________________________
Sample Site Safety Plan (SSP) Sample Site Safety Plan (SSP)
SITE SAFETY AND CONTROL PLAN
1. Incident Name:
Ammonia Release? YES ___ NO ___
2. Date Prepared: ___/___/_____
Time: ____________________
3. Operational Period: ___________
(Typically 2 to 8 Hours)
Section I. Site Information
4. Incident Location: (e.g. Engine Room)
Section II. Organization
5. Incident Commander: Enter Name
6. Operations Section Chief:
(Typically None)
7. Information Officer: _______________________
(Typically Legal Council or Risk Management)
8. Safety Officer: Enter Name
(May be same as IC)
9. Entry Team Leader: Enter Name 10. Site Access Control Leader (Typically None)
Communications/Security: Enter Name
11. Field Monitoring: Enter Name
12. Decontamination Leader: Enter Name 13. Safe Refuge Area Mgr: Enter Name
(Typically someone from production)
14. Medical Monitoring: Enter Name
15. Training: Is everyone's training current? YES___ NO___
16. Head Count: Is all personal accounted for? YES___ NO___
17. Entry Team (Buddy System)
Name: Level
18. Decontamination Element
Name: Level
Entry 1 Enter Name A Decon 1 Enter Name (May be Decon Leader) B
Entry 2 Enter Name A Decon 2 (Required for formal Decon) ________________ B
Entry 3 Enter Name A Decon 3
Entry 4 Enter Name (May be Entry Team Leader) A Decon 4
Section III. Hazard/Risk Analysis
19. Material Container type /
Source of Leak
Qty. Phys.
State
pH IDLH F.P. I.T. V.P. V.D. S.G. LEL UEL
Anhydrous Ammonia (UN# 1005) ______________? ____? ____? 11.6 300 ppm NA 1204 F 8.5 atm 0.6 0.6+ 15% 28%
Comment: Anhydrous Ammonia - Primary toxicity risks include inhalation and dermal hazards secondary risk is fire/explosion hazard. The PEL for Anhydrous Ammonia is 25 PPM. (You may have to conduct recon to determine Source of Leak, Quantity, and Physical State.)
Section IV . H azard M onitoring
20. L E L Instrum ent(s): C on fi n ed Sp ace L E L M eter
21. O 2 I nstrum ent(s): C on fi n ed Sp ace O 2 M eter
22. T oxicity/PPM Instrum ent(s): A m m o n ia T o xici ty M eter
23. R adiological I nstrum ent(s): N /A
C om m ent: T h e E x c lu s io n Z o n e s h a l l b e m o n i to r e d f o r p r im a r y / s e c o n d a r y h a z a r d s b y u s in g O 2 , L E L , a n d P P M m o n i to r in g d e v ic e s .
Im m e d ia t e e v a c u a t io n o f e n t ry t e a m fro m th e H o t Z o n e i f O 2 le v e l d r o p s b e lo w 1 6 % o r L E L a p p r o a c h e s 1 0 % o f th e L E L
P e r im e te r a n d Z o n e m o n i to r in g w i l l b e p e r f o r m e d u s in g to x ic i ty in s t ru m e n t( s ) a n d p e r im e te r / z o n e s w i l l b e a d ju s te d a s r e q u i r e d .
Section V . D econtamination P rocedures
24. Standard D econtam ination Procedures: Y ES: _ _ _ _ _ N O : _ _ _ _ _ C om m ent:
In i t i a l ly s e tu p fo r 2 - s ta g e e m e r g e n c y d e c o n to p r o te c t l i f e . T r a n s i t io n to f o r m a l 2 - s t a g e d e c o n to p ro te c t e n v i r o n m e n t a n d o r p ro p e r ty .
Section V I . Site C ommunications
25. C om m and Frequency _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 26. T actical Frequency: N o n e 27. Entry Frequency: H an d sign als an d h o rn .
Section V I I . M edical A ssistance
28. M edical M onitoring Y ES: _ _ _ N O : _ _ _ 29. M edical T reatm ent and T ransport I n -place Y ES: _ _ _ _ _ N O : _ _ _ _ _
C om m ent:
C o n d u c t p r e - e n t ry a n d p o s t - e n t ry m e d ic a l m o n ito r in g o f e n t r y t e a m , b a c k u p t e a m a n d d e c o n t e a m p r io r t o e n te r in g H o t Z o n e . T ru c k o r o th e r v e h ic le i s a v a i la b le f o r t r a n s p o r t a t io n . Y E S _ _ _ N O _ _ _ A 9 1 1 c a l l h a s b e e n m a d e to r e q u e s t b a c k u p m e d ic a l a n d t r a n s p o r ta t io n s u p p o r t ? Y E S _ _ _ N O _ _ _
Section VIII. Site Map
30. Site Map: SEE ATTACHED MAP/SITE PLAN (Be sure to indicate Wind Direction, Command Post Location, Zones [Hot, Warm, Decon, Cold, Assembly Area, and Entry & Escape Route(s)] here or on attached Map/Site Plan.)
N
Weat her
Com m and Post
Zones
Escape Rout es
Assem bl y Areas
Ot her
If this information has been included on your attached Map/Site Plan then place an X in each box to confirm.
Wind Direction
Zoning within the perimeter (ICS System):– Support Zone or Cold Zone or Green Zone.– Contamination Reduction Zone or Warm Zone or Yellow Zone.– Contamination Reduction Corridor (DeCon Area)– Exclusion Zone or Hot Zone or Red Zone.
Zoning within the perimeter (ICS System):Zoning within the perimeter (ICS System):–– Support Zone or Cold Zone or Support Zone or Cold Zone or Green ZoneGreen Zone..–– Contamination Reduction Zone or Warm Zone or Contamination Reduction Zone or Warm Zone or Yellow ZoneYellow Zone..–– Contamination Reduction Corridor (Contamination Reduction Corridor (DeCon AreaDeCon Area))–– Exclusion Zone or Hot Zone or Exclusion Zone or Hot Zone or Red ZoneRed Zone..
REMEMBER Only trained
responders are allowed in
control zones!
Perimeter may need to be over 1 mile downwind!
ICP
SafeRefugeArea
StagingArea
Section IX. Entry Objectives 31. Entry Objectives: Perform recon for trapped or injured persons and rescue same if safe do to so. Perform recon to determine source of leak and isolate same if safe to do so. Remember ONLY IF “GAINS” OUTWEIGH “RISKS” SHOULD THE ACTION BE TAKEN!
Prior to entering the Exclusion Zone or performing Decon personal shall be wearing proper protective equipment.
The safety of all personnel on site must be our first consideration. Safety of the response personnel is of the high est priority. All work is to be conducted in a safe manner and if any unsafe condition is encountered it should be immediately reported to the Safety Officer. Remember to respond safely, slowly, methodically, and watch for slip, trip, and fall hazards. The entry team is to immediately leave the Hot Zone if any unsafe condition is encountered.
Section X. SOP’S and Safe Work Practices 32. Modifications to Documented SOP’s or Work Practices YES: _______ NO: _______
Comment: (If you are not going to follow your SOPs and or Isolation Steps indicate what you intend to do here or referred to an attachment.)
Section XI. Emergency Procedures
33. Emergency Procedures:
Two long horn blasts from the Entry Team Leader means that the entry team is to immediately leave the Hot Zone. If the entry team requires immediate rescue they are to signal by continuous short blasts from their horn. Hand signals will be reviewed prior to entry into Hot Zone and used for routine communication. If the entry team cannot exit the way they entered the Hot Zone they are to immediately use the escape route identified on the Map/Site Plan.
Section XII. Safety Briefing
34. Safety Officer Signature: (M ay be same as IC) Safety Briefing Completed (Time): ________________________
Safety Briefing M UST be completed prior to entering H ot Zone
_________________________________________________
35. HM Group Supervisor/Entry Leader Signature:
_________________________________________________
36. Incident Commander Signature: (M ay be same as SO)
_____________________________________________________
SOP’s Refer to Example On Next Slide!SOP’s Refer to Example On Next Slide!
Typical Air Handler / Evaporator
(with valves on roof)Isolation Steps
1. Close Liquid Valve
2. Open Liquid SOV
3. Close Hot Gas Valve
4. Open Hot Gas SOV
5. Close Suction Valve
6. Close By-Pass Valve
7. Follow Pump Out SOP
2
1
3
6
5
4
Defensive Action = Mitigating a release utilizingskills normally used in operating facility systemsThis is a example of what facilities can develop to
their assist emergency response teams.
PROGRAM 3 REQUIREMENTS Executive Summary Process Safety Information Process Hazard Analysis Operating Procedures Training Mechanical Integrity Management of Change Pre-Startup Review
PROGRAM 3 REQUIREMENTS
Compliance Audits Incident Investigation Employee Participation Hot Work Permit Contractors
What Process Safety Information Is Required?
Block flow diagram or simplified process flow diagram,
Process chemistry (e.g. M.S.D.S.), Maximum intended inventory, Safe upper / lower limits - temp, pressures,
flows, compositions, etc., Evaluation of the consequences of deviation
(from the safe upper / lower limits)?
What Process Safety Information Is Required? (Cont.) Information on equipment used in the process:
– Materials of construction (e.g. ASME certified vessels) documented,
– Piping and instrument diagrams (P&ID’s current & accurate?),
– Electrical classification documented, – Relief system design and design basis documented, – Ventilation system design documented,– Design codes and standards employed to construct the
process must be documented, – Safety systems (e.g. detection) documented?– Documented Safe upper / lower limits such as temp,
pressures, flows, compositions, etc.
Documentation showing equipment complies with recognized engineering practices?
Or documentation showing existing equipment is designed, maintained, inspected, tested and operated in safe manner?
What Process Safety Information Is Required? (Cont.)
Should a Process Hazard Analysis or Hazard Review be accepted if the Process Safety
Information was unavailable or inaccurate?
What Should the Process Hazard Analysis Address? Hazards of process, Previous incidents (not just reportable releases) with
the potential for accidents including near misses, Engineering and administrative controls, Consequences of failure of engineering and
administrative controls including safe operating limits,
Stationary source sitting, Human factors, Qualitative evaluation of health and safety effects of
failure of controls,
What Should the Process Hazard Analysis Address? (Cont.) External events?
– Were external events such as fires, floods, earthquakes, transportation accidents, extreme wind or tornadoes, fog, and extreme temperatures discussed?
– Were external events such as site security related to sabotage, terrorism, and theft discussed?
– Were external events such as site security related to the potential for adjacent facilities or systems to impact the process discussed?
Did the PHA and or Re-validation address procedural steps where appropriate (e.g. hot gas defrost cycle on an ammonia evaporator)?
Was PHA performed by a knowledgeable team?
What Follow Up Is Required for Process Hazard Analysis Recommendations? Is a system established to promptly address findings
and recommendations? Is there a written schedule of when these actions are
to be completed? Have the recommendations been resolved in a
timely manner? Are the resolutions documented? Have actions been completed as soon as possible? Has PHA or Hazard Review been done for major
changes or additions to the process? Has PHA been re-validated at least every 5-years?
Process Hazard Analysis Recommendation Withdrawal
Employer can justifiably decline to adopt a recommendation where the employer can document, in writing and based upon adequate evidence, that one or more of the following conditions are true; analysis contains material factual errors; recommendation is not necessary to protect health &
safety of employees of owner and/or contractors; an alternative measure would provide sufficient level
of protection; or recommendation is infeasible.
Operating Procedures
Initial startup, Normal conditions, Temporary operations, Emergency shutdown, Emergency operations, Normal shutdown, Startup following a turnaround or after
emergency shutdown?
Which SOPs reasonably apply to most processes?
Written operating procedures which address: – Deviation from Normal Operating limits:
• Consequences of deviation, • Steps required to correct or avoid deviation?
Regular review/annual certification of operating procedures?
Is a periodic review of written prevention programs such as EAP/ERP, MOC, PM Program, Incident Investigation, Contractor Safety Programs, done?
What Other Operating Procedures Must a Facility Have?
What Safe Work Practices Should The Facility Have In Place? Hot Work Permit Program, Lockout/Tagout program, Opening Process Equipment Program (i.e. Line Break
Permit), Confined Space Permit and Rescue Programs, Medical Surveillance Program (respiratory protection
program), and HazCom Program. Written evaluations and training records. Proper maintenance of emergency response equipment.
What Training Is Required?
Is refresher training provided at least every three years, and more often if necessary?– Are employees consulted with concerning the
frequency and need for refresher training?– Documented training on SOPs, maintenance
procedures, operating limits, safety systems & hazards, emergency procedures, safe work practices, etc.
– Is the same level of training provided to an employee prior to a new job assignment?
– Is training provided to contractors who maintain or operate the system or process?
What Training Documentation Is Required?
Does training documentation include:– Documentation that employee received and
understood training,
– Identity of employee,
– Date training occurred,
– Means used to verify employee training (e.g. testing, observation, demonstration, etc.) comprehension?
What Should Be Included In A Mechanical Integrity Program? Written procedures to maintain the on-going
integrity of ALL process equipment, Planned (preventive, predictive, and proactive but
not reactive) and corrective maintenance procedures,
Training for process maintenance activities, Inspection and testing of process equipment, Prompt correction of equipment deficiencies, Quality assurance (e.g. appropriate checks and
inspections performed according to manufacturer’s recommendations, & suitable spare parts available).
Is the program documented?– Including the date of each inspection or test,
– The name of the person who performed the inspection or test,
– The serial number or other identifier of the equipment on which the inspection or test was performed,
– A description of the inspection or test performed,
– The results of the inspection or test, and
– Actions taken to correct deficiencies.
What Documentation Should Be Included In The Mechanical Integrity Program?
Mechanical Integrity Program
Do the written testing and inspection procedures follow recognized and generally accepted good engineering practices including but not limited to?– Appropriate frequencies for testing and inspection of
process equipment (e.g. API, IIAR, NFPA, ANSI, ASME, etc… guidelines or manufacture's recommendations),
– Criteria for acceptable test results,
– Methods to analyze inspection and testing results to assure that equipment deficiencies are corrected when outside acceptable limits.
Mechanical Integrity Program (Cont.)
Is data collected and documented during normal daily walk around including but not limited to?– Liquid levels in all vessels,
– Inspections of equipment and tasks to be performed such as defrosting evaporators,
– Instrument readings such and operating conditions (e.g., temperature, pressure, flow, level, etc.), and
– System upsets including operating outside normal operating limits and what corrective actions were taken.
Mechanical Integrity Program (Cont.)
Are Equipment Deficiencies discovered during routine maintenance and daily walk around corrected?– The employer shall correct deficiencies in
equipment which are outside acceptable limits defined by the process safety information or manufacturers recommendations before further use, or in a safe and timely manner provided means are taken to assure safe operations.
Management of Change and What Is Considered Change? Change - Any modification which affects the capability of a
process to maintain control of the physical and chemical transformations taking place, including all modifications to equipment, procedures, raw materials, and processing conditions other than replacement-in-kind.
For example (this list is not to be considered all inclusive):– Substitution of a material of construction with a different material.
For example, a process vessel and/or section of piping is designed with black carbon steel. Replacement of a section of the equipment with stainless steel would constitute a change.
– Replacement of a vessel with one of a different pressure rating.
– Replacing a gasket with one of a different material.
Is the technical basis for ALL proposed changes, such as but not necessarily limited to, the reasons for performing the work, desired results, technical design, and appropriate implementation instructions documented including but not limited to?– Changes in process safety information being updated prior to
any change?
– Changes in operating procedures or practices being updated prior to change being put into service?
– Training completed prior to startup of the changed process?
– Maintenance routines developed prior to change being put in to service?
Management of Change and What Should Be Documented?
Are compliance audits conducted at least every 3-years?
Are audits conducted by at least one qualified person knowledgeable in the process?
Is a system established to promptly address findings and recommendations?
Is there a written schedule of when these actions are to be completed?
Have the recommendations been resolved in a timely manner?
Compliance Audits and What Should Be Documented?
Are the two most recent audits and audit responses available for review?
Did the audit adequately address previous Compliance Audit, PHA, and Independent Audit recommendations that have not been corrected or resolved?
Have actions been completed as soon as possible?
Are actions to be taken and their status communicated to employees?
Compliance Audits and What Should Be Documented? (Cont.)
Is each incident which resulted in, or could reasonably have resulted in a catastrophic release of a highly hazardous chemical (including near-misses and minor releases) investigated?– Are near-misses such as excursion of process operating
parameters, damaged piping, and corrosion investigated?– Are incident report findings and recommendations
promptly addressed, and resolved?– Did a contractor employee if the incident involved work
of a contractor participate in the investigation?– Was a system established to prevent a reoccurrence? – Are incidents reports retained for at least five years?
Incident Investigations and What Should Be Documented?
Does the program include all contractors who work on or adjacent to covered process(s)?
Have contract employers’ safety performance and programs been evaluated and documented?
Is the entrance, presence, and exit of contractors and contract employees controlled?
Have contract employees been periodically audited?– Been properly trained in and utilizing safe work practices– Know potential fire, explosion, or toxic release hazards
and applicable provisions of the plants emergency action/response plan
Contractor Safety Program and What Should Be Documented?
Contractor notified of fire, explosion, and release hazards at facility?
Contractor performance periodically evaluated? Contractor provided training for their employees? Contractor informs their employees of the hazards and
emergency response plan at the facility? Contractor advised facility of hazards presented by contract
work? Contractor advised facility of any hazards found? Contractor assured facility that employees followed its
safety rules?
Contractor Safety Program and What Should Be Documented?
CalARP/RMP Program Updates Within five years of its initial submission or most recent
update whichever is later. No later than three years after a newly regulated substance is
first listed by USEPA or OES. No later than the date on which a new regulated substance is
first present in an already covered process. No later than the date on which a regulated substance is first
present above a threshold quantity in a new process. Within 30 days of change in emergency contact information. Within 6 months of a reportable release.
CalARP/RMP Program Updates (Cont.)
Within 6 months of a change that requires a revised PHA or hazard review
Within 6 months of a change that requires a revised offsite consequence analysis.
Within 6 months of a change that alters the Program level that applies to any covered process.
Within 6 months of a change that alters the Program level that applies to any covered process.
What are some examples of changes that would require a revised Process Hazard Analysis or
Offsite Consequence Analysis?