GOOD MANUFACTURING PRACTICES AND STEWARDSHIP … · GOOD MANUFACTURING PRACTICES AND STEWARDSHIP...

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GOOD MANUFACTURING PRACTICES AND STEWARDSHIP AUDIT

Introduction

This document is an audit tool to help determine the level of compliance with good management and product stewardship practices as determined by CPDA.

Self Evaluation Practices

To effectively conduct this self audit the following practices are recommended:

Audit teams

Teams of t hree or more persons are recommended. Select team members that reflect a cross section· of the business. People from diverse functions and disciplines should be included on the team.

Review

Review the audit results and discuss among the team. Review the results with site management. This can highlight potential problem areas with the business management and assure action/resources to correct/avoid the problem. Consider a peer review if there are some questionable areas on the audit Select the peer group from people with particular expertise on the issue in question,

Rating System to be Used

The rating system will follow the ACC established and approved scoring criteria.

RI - Reassessing implementation of management practicePP - Practice in placeIA - Implementing action planDP - Developing action planEV - Evaluating current practices against standardsNA - No actionDNA-Does not apply

Compliance

Audit score must reflect 75% oft he practices at the PP or RI stage. No more than 10% oft he practices can be at the EV stage. No scores in the NA category.

CPDA Good Management Practices / Product Stewardship Audit

1) Policy Statement(s)A written, signed and dated policy statement (s) exists at the corporate and/or local levelreflecting management's positive attitude and commitment to continuous improvement ingood management and stewardship practices. This policy statement (s) should apply toevery work site and be signed by the current chief operating executive or equivalent. Itshould be posted in a visible location at each facility and refer to the following areas:Occupational Health and Safety, Quality, Environmental Protection, Legal Compliance

D RI The policy statement has been reviewed and/or reissued within the past year.

D PP There is a current policy statement in place

D IA A policy statement exists but has not been formally issued.

D DP A policy statement is under development and a plan is in place to implement.

0 EV A policy statement is under evaluation.

D NA No policy statement exists, no plan to develop one.

0 DNA Does not apply

2) QualitylHealth/Safety/Environment Program (s) AccountabilityAccountability for coordinating the Q/H/S/E Program( s) is clearly defined in writing. Atleast one person at each site is designated as the coordinator, and there are clearly statedresponsibilities for each aspect of the Program(s). The designated coordinator at each sitehas been appropriately trained in modern Q/H/S/E practices and legal regulations. Theyhave access to related professional support.

D RI Accountability in place an has been reassessed within the past year.

0 PP Accountability is assigned and accepted

D IA Accountability is identified and will be assigned

0 DP Accountabilities are planned to be identified

0 BV The assignment of accountability is being evaluated

0 NA No one is accountable for any of these items

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0 DNA Does not apply3) Rules, Standards and Procedures ManualA manual of standard safe practices and acceptable procedures is established andaccessible to all employees. Plant rules and standards are clearly understood by allemployees and used as part of all job training programs.

0 RI Manual is in place and has been reviewed in the past year

D PP Manual is in place

D IA Manual has been prepared, plan is in place to implement

D DP Rules, standards and procedures are being developed

D EV Development of a manual is being evaluated

0 NA No plan to develop a standards manual


4) Joint Health & Safety CommitteeA joint labor/management health & safety committee must exist at each plant site. Theyhold regular meetings on an established schedule at least six times per year. Fixed lines ofcommunication exist which facilitate the recommendations and the concerns of thecommittee being communicated both up and down the organization.

0 RI Safety Committee in place for more than 2 years. All recommendations reviewed

D PP Safety committee in place

D IA Safety committee identified, not formally in place.

f'O DP Safety committee election planned

D EV Implementation of a safety committee under evaluation

D NA No plan to introduce a safety committee

0 DNA Does not apply \-.

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5) TrainingA written standard exists requiring a specific health, safety and environmental protectiontraining schedule for all line management and plant employees at a plant site. Workerstraining is similar to management HISlE training, but not focused on specific departmentalconcerns. There is also a requirement for pre-start-up health and safety reviews at thebeginning of the first shift for each new production campaign. New employees arerequired to undergo plant orientation and health, safety and environmental protectionprogram training prior to starting work. This training includes: Legalrequirements/regulations, communications and responsibility, knowledge of plant hazardsand a test or audit of each person's understanding and retention.

0 RI Training program in place, regular sessions held for the past 2 years. Programhas been reviewed annually.

D PP Training program in place

D IA Training needs identified, sessions planned

0 DP Training needs under evaluation, company commitment to training program

D EV Need for training under evaluation

0 NA No plan to do any more than on the job training

D DNA Does not apply

6) Planned InspectionsAt least monthly, health and safety inspections are planned for each plant department.These inspections have a documented schedule and are conducted by a supervisor whomay be accompanied by a worker representative.

0 RI Regular inspections have been conducted and recorded for the past 2 years

D PP Inspections have been conducted and recorded

0 IA Inspection procedure written, inspections planned

D DP Inspection procedure under development

D EV Need for regular inspection being evaluated

0 NA Inspections are seldom or never conducted ...

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7) Preventative Maintenance ProgramThere is a documented preventive maintenance program and schedule established for allmechanical equipment. As part of this program, critical components have been identifiedfor detailed inspections. Maintenance and replacement schedules are set up to upgradeparts prior to failure. Indications of worn parts and imminent failure are identified andchecked. All inspections and regular maintenance are performed by competent personsand documented.

D RI PM program in place for the past 2 years with annual reviews

D PP PM program in place

D IA PM program developed, is being or is planned to be implemented

D DP PM needs identified, program under development

D EV Need for a PM program being evaluated

D NA Maintenance is done as equipment breaks down


8) Accident / Incident InvestigationThere is a standard requiring all accidents / incidents including unusual occurrences to berecorded and examined for potential harm or loss. The Health & Safety Committee is tobe involved in these investigations. A written report summarizing the findings andsubsequent preventative action is to be communicated to all employees concerned with thesystem failures involved.

D RI Accident reporting procedure in place for the past 2 years with annual review

0 PP Accident reporting procedure in place

0 IA Accident reporting procedure written and will be implemented

D DP Accident reporting procedure under development

D EV Need for an accident reporting procedure under evaluation~

0 NA Accidents are not investigated and seldom reported

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9) Emergency PreparednessA written emergency plan exists. This plan has been communicated to all employees and u

is drilled at least annually. Relevant to a formulation or packaging facility, this plan covers:fire, evacuation, equipment protection (e.g. shut-down procedures), power failures,responsibility and chain of command, search and rescue, first aid, co-ordination withpolice/fire/disaster services, environmental protection, natural disasters and sabotage

D RI Written plan in place. Annual drill conducted. Annual review conducted

D PP Written plan in place

0 IA Plan is written but awaiting implementation

0 DP Plan is being written

D EV Need for plan is under evaluation

DNA There is no preparedness for emergencies at the site


10) Legal ComplianceThere is a written and implemented process in place to self-assess compliance with allapplicable laws and regulations (e.g. OSHA, EPA, SARA etc.)

D RI All legal requirements are met and are reviewed at least annually

0 PP All legal requirements are met

D IA Legal requirements are identified and a plan to comply has been written

D DP Legal requirements are being identified

D EV Determination if there are legal requirements to be met

0 NA It is likely that legal requirements are not being met~D ~:;"

DNA Does not apply ;,~I;'

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11) Medical ExaminationsA procedure is established which assesses the fitness to work for all permanent, temporaryand seasonal employees involved with handling or exposed to chemicals. This procedureincludes a pre-employment medical examination. Annual medical examination similar tothe pre-placement examinations are arranged for all permanent (or returning seasonal)employees who handle chemicals.

0 RI Medical program with annual review in place for the past 2 years

0 PP Medical program in place

0 IA Medical program complete, doctor contracted, to be implemented

0 DP Medical program under development

0 BV Evaluating need for medical program

0 NA Medical exams are seldom or never performed


12) Identification of Potential Health HazardsThe most current health and safety information for raw materials and finished goods,including the MSDS, is available. Conduct and evaluation of the processes to identifyphysical, chemical or environmental risks. Implement action plans to remediate theseconditions.

0 RI Risk assessment done on all processes. Safety information in place and reviewed

monthly

0 PP Risk assessment done on all processes. Safety information in place

0 IA Risk assessment started not all processes complete

0 DP Risk assessment program under development

0 EV Need for risk assessment being evaluated

0 NA Significant risks exist and have not been identified


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13) Personal Hygiene FacilitiesAdequate showers and washroom facilities must be provided at the work site. Thesefacilities are clean and tidy at all times. They are used for wash up each time an employeewho handles chemicals leaves the work area to eat or go somewhere outside the plant.Contaminated clothing is removed before employees leave the work site.

D RI Adequate facilities in place. Hygiene program in place and followed

D PP Adequate facilities in place.

D IA Adequate facilities under construction.

D DP Adequate facilities planned

D EV Need for hygiene facilities being evaluated.

D NA There is marginal or no hygiene facility available


14) Record MaintenanceIndependent of the medical records maintained by the medical consultant or companymedical officer, each site maintains a health and safety record system for all plantemployees. This record includes length of employment, nature of work, records of unsafeworking practices involving the employee or injuries incurred by the employee. It alsoincludes the record of training courses the employee has undertaken and the participationof each employee in specific health monitoring programs.Note that all employee specific medical records are to be regarded as confidential.

D RI All medical records maintained. Records reviewed on a annual basis

0 PP All medical records maintained.

D IA Plan to maintain all medical records written and planned to be implemented

D DP Plan to maintain all medical records under development

D EV Assessing need to maintain medical records

DNA No records are maintained on medical histories


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15) First Aid ProgramEach site has sufficient number of qualified first aiders to provide at least two certified(First Aid /CPR) people readily available in each plant department/area for every shift.First aid equipment is readily available in every area and its location is clearly marked.Emergency telephone numbers should be located beside the first aid station. Names ofqualified first aid personnel are identified and records are maintained for all first aidtreatments.

D RI Appropriate number of trained first aiders in place. Training reviewed annually

D PP Appropriate number of trained first aiders in place

D IA Appropriate number of first aiders scheduled for training

0 DP Plan in place to train first aiders

0 EV Need for first aiders being evaluated

D NA No first aiders on site, no plan to train any personnel


16) Plant LocationIdeally a formulation or packaging plant should be located away from residential areas,hospitals, schools, shopping centers, drinking water sources, and areas liable to flooding.If this is not possible, extra precautions must be taken; for example, facilities to limit thespread of contaminants in emergency situations.

D RI Plant location ideal, all precautions taken against releases

D PP Plant location in built up area, all precautions taken against releases

D IA Plant location in built up area, precautionary measures underway

0 DP Plant location in built up area, precautionary measures planned

0 EV Plant location in built up area, precautionary measures incomplete .:

DNA Plant in built up area, no precautionary measures planned


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17) Site LayoutThe site layout permits reasonable movement of materials. It has sufficient space to allowfor hygienic working conditions. It allows clear access to fire-fighting at any time of theday. Security provisions are set up to adequately protect the site from trespassers.

D RI Well planned, secure site. Easy access for emergency vehicles

D PP Well maintained site, can be secured, easy access for emergency vehicles

D IA Improvements to site underway

D DP Improvements to site planned

D EV Need to improve site under evaluation

0 NA Poorly planned, unsecured site


18) Building ConstructionThe construction of all building on the site meets all applicable building, fire, electrical andany other legal regulations which may apply. All exterior and interior walls and ceiling areconstructed of non-combustible or minimum 1.5 hour fire-rated materials. Fire separationwall openings have been provided with automatic self-closing doors. Floors are essentiallyimpervious and have a smooth finish ( no cracks) for ease of cleaning.

D RI Meets all requirements of construction

D PP Meets most requirements of construction, no serious faults

D IA Some faults but construction underway to correct

D DP Some faults but construction planned to correct

D EV Significant faults, construction under evaluation

DNA Significant to serious faults


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19) Building Ventilation and HeatingAll areas where products are stored or used should be well ventilated to ensure bothlighter-than-air and heavier-than-air vapors and gases are not allowed to accumulatewithin the interior of buildings. The heating systems should be hot water or low pressuresteam variety with the source of heat (e.g. boiler system) located in a room separated fromthe rest of the facility. Open flame heaters are strongly discouraged.

D RI Climate controlled work areas, heat source isolated, no open flames

D pp Well ventilated, heat source isolated, no open flames

D IA Well ventilated, heat source under construction to isolate, no open flames

D DP Well ventilated, plan to isolate heat source and remove open flames

0 EV Well ventilated, heat source not isolated, may be open flames

0 NA Poorly ventilated, heat source not isolated, may be open flames


20) Interior / Exterior LightingIntrinsically safe lighting is of sufficient intensity to provide safe working conditions and isstrategically located to allow hazard warnings, product labels or any other instruction tobe easily read. Lighting units are installed where they are least likely to interfere withhandling or processing equipment and/or with material in storage.

D RI Bright well planned lighting. All warning signs well illuminated

D PP Bright well planned lighting. Most warning signs well illuminated

0 IA Sufficient lighting. Most warning signs well illuminated

0 DP Sufficient lighting. Some warning signs well illuminated

0 EV Sufficient lighting. Most warning signs poorly illuminated

0 NA Poor lighting. Warning signs poorly illuminated ~:-


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21) Electrical InstallationsLighting, electrical panels, and other electrical equipment conform with the applicableelectrical codes. Switch panels are located outside areas where flammable liquids or gasesare handled / stored. Electrical systems are regularly inspected by a competent electrician.High voltage (>220 V) and control panels are properly identified, closed and securedagainst unauthorized tampering.

D RI All above conditions met. Regular, recorded inspections are conducted

D PP All above conditions met

D IA Work underway to ensure that all above conditions are met

D DP Work planned to ensure that all above conditions are

D EV It is likely that service is below code. Plan in place to upgrade

D NA Electrical service compliance with codes is unknown and high voltage sourcesare not marked or secured


22) Personal Protective EquipmentAppropriate personal protective equipment is identified and distributed the for thematerials and equipment hazards present. Sufficient quantities of the correct equipmentare available there is a formal issue, recall, and maintenance procedure. Equipment is onlyissued following proper fitting and training in its use. Use of personal protectiveequipment, where required, is strictly enforced.

0 RI Above conditions are met. Training and fit testing is reviewed on a regular basis.

D PP Above conditions are met

D IA Proper equipment is issued, maintained and enforced. Training and fit testing hasbeen planned and will be implemented.

D DP Assessment is underway to identify hazards and determine where equipment isrequired. Training and fit testing program planned. Equipment is issued but notenforced.

0 EV Assessment is underway to identify hazards and determine where equipment isrequired. No training or fit testing program planned.

D NA Personal protective equipment is not issued and/or its use is not enforced


23) ContractorsArrangements are to be made for contractors personnel on site, to ensure their adherenceto site safety standards and to take account of special non-routine hazards which may beassociated with the contractor's operation. There is also provision for a company safetyrepresentative to periodically inspect the precautionary measures taken by contractorpersonnel in working on the project contracted.

0 RI Procedure in place for contract workers. Procedure reviewed at least annually.Regular inspections by company safety representative.

0 PP Procedure in place for contract workers. Regular inspections by company safetyrepresentative

D IA Procedure in place for contract workers. No regular inspections by companysafety representative

0 DP Procedure developed for contract workers.

0 EV Need for procedure for contract workers under evaluation.

0 NA No procedure or contact workers, no plan to generate one.


24) Emergency EquipmentIn addition to safety provisions made by building and fire codes (e.g. access to emergencyexists), the facility must provide emergency showers, eye-wash fountains and readilyaccessible first aid supplies. This equipment must be clearly marked.

0 RI All equipment in place and clearly marked. Operation tested or contents reviewedmonthly.

D PP All equipment in place and clearly marked.

D IA All equipment in place not clearly marked. Plan to improve marking I

D DP Some equipment/supplies required, plan in place to improve

0 EV Some equipment/supplies required, improvements being evaluated

0 NA Serious lack of emergency equipment

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25) Fire / Explosion PrecautionsWhere combustible liquid formulations are used, transferred, or stored, all electricalequipment in the vicinity must not produce sparks and must be approved from a fire andexplosion safety viewpoint. Applicable vapor and dust explosion limits must be known.Naked flames and spark-producing tools and equipment are also prohibited from this area(e.g. No Smoking). To prevent build-up of static electrically, all equipment must beadequately grounded. Drums are also to be grounded during emptying and filling. Propergrounding and ventilation also applies to powdered products which present a dustexplosion hazard.

D RI All above conditions met. Safety information reviewed at least annually.

0 PP All above conditions met

D IA Plan in place to gather necessary safety information.

D DP Plan in place to meet above conditions and gather necessary safety information.

0 EV Proper grounding and ventilating of all equipment is being evaluated.

0 NA Equipment is improperly grounded and poorly ventilated.


26) Machine GuardingAll mechanical power transmission points, pinch points, in-running nip points, and pointsof operation are physically guarded against entanglement with employees' clothing, fingersand hair. These guards are secured well and are regularly inspected to keep them in goodcondition. Guards on powered hand tools are also used as provided and are wellmaintained. Emergency stop buttons, trip wires, electric photocells, and other interlockguards are positioned so as to provide operators with easy and quick access.

D RI All necessary guards are installed and maintained. Guards are checked andrecorded at least weekly

D PP All necessary guards are installed and maintained.

D IA Where guards are required they are installed or under installation

0 DP Some guards are required. There is a plan in place to install them.

D EV There is a plan in place to evaluate where guards are required

D NA There are a number of places where guards are required.

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27) HousekeepingFloors are clean, orderly, and in sanitary condition, There are no slip, trip, or fall hazardsand opening are covered or securely barricaded. Aisles and passageways are clear andunobstructed. They are marked and of sufficient width to allow normal movements andsafe visibility. Approaches to exits are unobstructed and clearly marked, and the exitdoors are not locked and are kept clear of snow or other obstructions. Stairs are clear ofslipping or tripping hazards. They are adequately lit, have secure handrails, and provideslip-resistant treads (or grating) and nosings. Ladders and platforms are free fromobstructions, are unpainted, provide nonskid footing, and are clean of grease and oil.

D RI Housekeeping is excellent. Regular documented inspections are conducted

D PP Housekeeping is excellent, very few exceptions

D IA Housekeeping is very good, few exceptions

0 DP Some areas where housekeeping could be improved

D EV Numerous areas where housekeeping needs to be improved

0 NA Housekeeping is poor


28) Stacking and StorageStorage areas are marked so as to provide safe access, not allow blockage of exits or aisle-ways, and restrict incompatible materials from being stored together. All stored productsare stable and secure against sliding or collapsing. Load/height limits are posted andrespected on all racks and platforms.

D RI Safe storage areas are used and safe practices are followed. Incompatibleproducts are marked and segregated. Load and height limits are posted.

D PP Safe storage areas are used and safe practices are followed. Incompatibleproducts are marked and segregated.

0 IA Safe storage areas are used and safe practices are followed. There is a plan inplace to segregate materials and post warning signs.

D DP Safe storage areas are used and safe practices are followed. A plan to segregate j

materials and post warning signs is under development.

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D EV Storage needs improvement, a plan for improvement is under evaluation

D NA Storage needs improvement, no plan to improve

D DNA Does not apply29) Chemical and FuelsTanks and other storage or process vessels are constructed of an appropriate material forthe contained materials and are properly groundedlbonded. All vessels are checked on aregular basis to ensure they are in good condition. Safety controls and warning devices areinstalled to ensure heated or reacting products are not allowed to reach dangeroustemperatures. Levels in all tanks and vessels are monitored and, where justified, fittedwith high/low level alarms. For small quantity storage proper safety containers andstorage cabinets are provided (i.e. fire resistant and vented). Fuels are stored outside or ina storage facility blocked off from the rest of the production / packaging plant.

D RI All storage vessels in compliance. Safety devices and controls installed. Smallcontainers properly stored. Vessels inspected and results recorded at least monthly

D PP All storage vessels in compliance. Safety devices and controls installed.

D IA All storage vessels in compliance. Safety devices in process of installation

D DP Plan in place to bring all vessels into compliance

D EV Evaluating need for improvements in storage vessels

D NA Storage of chemicals needs improvement, no plan to improve in place.


30) Compressed GasesCylinders and tanks are stored upright and secured against falling over. They aresegregated by contents and legibly marked. Caps are in place and hand tight. Theirstorage area is away from sources of heat, stairs, elevators and egress routes, and isadequately ventilated. These containers are also regularly checked against damage andcorrosion (test record maintained).

D RI Cylinders stored properly. Cylinders are marked. Inspections done andrecorded at least monthly

D PP Cylinders stored properly. Cylinders are marked.

0 IA Plan in place to properly store and mark all cylinders

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D DP Plan under development to properly store and mark all cylinders

D EV Evaluation underway to determine if and how to improve cylinder storage

D NA Cylinders improperly stored, no plan in place to improve


31) Identification of System/Tank ContentsIn addition to labels on packaging, drums and other portable containers, all pipes, valves,tanks, and vessels are also clearly labeled/identified as to their contents. Direction of flowand nature of hazard (if any) are also indicated. A color coding system may be used whereit is well understood by employees. OSHA style labels are recommended.

D RI All pipes, tanks, valves and vessels are properly marked as to contents, flow andhazard. Marking is reviewed at least quarterly and changes are made immediately.

D PP All pipes, tanks valves and vessels are properly marked as to contents, flow andhazard.

D IA Program underway to mark all pipes, valves, tanks and vessels properly

0 DP Program under development to mark all pipes, valves, tanks and vessels properly

D EV Marking of all pipes, valves, tanks and vessels is being evaluated

0 NA Pipes, valves, tanks and vessels are not marked properly


32) Fire ProtectionAn appropriate number (meets or exceeds NFPA guidelines) of fire extinguishers areproperly mounted and identified throughout the plant. The extinguishers are appropriatefor the type of materials handled. Fire hoses are also properly mounted, guarded andidentified. Each is regularly (monthly) inspected and maintained in top working order.Personnel are trained in their use. If a sprinkler system is installed in the plant, the headsmust have proper clearance (e.g. three feet) and the master control valves must beaccessible and locked open.

D RI All fire equipment is properly stored, marked and in good condition. Sprinklersystem in place. All units are inspected and the results recorded at least monthly

I 0 PP All fire equipment is properly stored, marked and in good condition. All units arei inspected and the results recorded at least monthly

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D IA All fire equipment is properly stored, marked and in good condition. Plan in placeto conduct regular inspections

D DP Plan in place to install proper equipment and to conduct regular inspections

D BV Installation/upgrade of fire equipment under evaluation

D NA Fire equipment installation or upgrades are required

D DNA Does not apply33) Hand and Portable ToolsAll tools, electrical cords, and air hoses are kept in good condition. Provision is made forproper and safe storage. Guards and safety devices are installed and in good condition.All electric power tools are either double insulated or properly grounded.

D RI All tools in good condition and stored properly. All safety devices in place. Powertools are inspected and checked on a regular basis and the results are recorded

D PP All tools in good condition and stored properly. All safety devices in place.

D IA Tools are in good condition. Construction underway on safe storage facilities

D DP Tools are in good condition. Safe storage facilities are planned

0 EV Evaluating the condition and storage of tools

D NA Tolls in less than good condition and improperly stored


34) Lifting Gear / EquipmentAll lifting devices (hoists, booms, pulleys, cranes, forks, chains, hooks, etc.) are in goodcondition and inspected at least annually for metal fatigue, damage, cleanliness,lubrication, and maintenance. They are labeled as to capacity and load testing, fitted withoverhead guards, and provide safe access to the controls. All controls, limit stops andhoist motor brakes are operational. There is full visibility to the entire lift area from thecontrol point. Only properly trained and authorized personnel are permitted to operatethis equipment.

0 RI All equipment in good condition and properly labeled. All safety devices areinstalled and operational. Inspections and training is conducted and recorded.

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D PP All equipment in good condition and properly labeled. All safety devices areinstalled and operational. Inspections and training are conducted

D IA All equipment in good condition and properly labeled. Plan in place for trainingand inspection

D DP All equipment in good condition and properly labeled. Plan under developmentto install safety devices, train operators and inspect equipment

D EV Need for training and inspection is being evaluated

DNA Some equipment in poor condition and/or improperly labeled.

D DNA Does not apply35) Lock-out SystemsPositive lock-outs are required for all power systems and individual power equipment.Lock-outs permit multiple lock-out where more than one person may be involved in theinspection or maintenance of powered equipment. Appropriate personnel are trained in the :~proper use of lock-out procedures and devices. ',~

"!D RI Comprehensive lock out procedure. Personnel are trained. Procedure is reviewed j

at least annually

i 0 PP Comprehensive lock out procedure. Personnel are trained :~

D IA Comprehensive lock out procedure. Training program planned or underway "'~

0 DP Lock out procedure under development. Training program under development

D EV Comprehensive lock out procedure. Personnel are trained

D NA No lock out procedureI ;: D DNA Does not apply

36) Materials Handling EquipmentDock boards/plates are provided at loading points. Materials containers are in goodcondition. Pallets and skids are of the correct type and in good repair. Chains, slings, andropes are adequate for the loads handled and in good order. Lifting equipment is properlystored when not in use. Wheel chocks are provided for trailers and used. Trailer securingmechanisms may only be removed by the loader. Regular inspections of this equipmentare performed and written records maintained.

I D RI All above conditions are met.

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D PP All above conditions are met, inspections are not regular and/or recorded.

D IA A plan has been implemented to meet the above requirements

D DP A plan has been developed to meet the above requirements

D EV Many areas of the above requirements are not met

D NA Few of the above requirements are met


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37) Mobile EquipmentAll mobile equipment (lift trucks, etc.) have overhead guards where required, strongenough to withstand the impact of falling materials under normal conditions. Designatedareas are provided for safe refueling/recharging separate from other operations. Onlywell-trained, qualified persons are permitted to operate mobile equipment. The vehiclesmust have on-board adequate warning devices, fire extinguishers, and lights whererequired. This equipment must be inspected regularly and maintenance recordsmaintained.

D RI All above conditions are met.

0 PP All above conditions are met, inspections are irregular and/or not recorded

0 IA A plan has been implemented to meet the above requirements

0 DP A plan has been developed to meet the above requirements

0 EV Many of the above requirements are not met

DNA Few of the above requirements are met


38) Signs and TagsHazard warning, directional, authorized entry restrictions, and informational signs are usedwhere there are immediate dangers, potential hazards, or there is a need for generalinstructions. Signs and tags are consistent in use throughout the whole facility.

0 RI All signs are posted consistently where required. Placement of signs is reviewedat least annually

0 PP All signs are posted consistently where required

0 IA There is a program underway to install all required signs

0 DP There is a program in development to install all required signs

0 EV Signing requirements are being evaluated

0 NA Signs are not posted or improperly posted where required


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39) Exterior ConditionsAll areas susceptible to chemical spills must be concrete or paved. Roadways and pavedsurfaces are in good repair. Snow and ice is removed promptly. There is sufficient widthand safe clearance for anticipated truck traffic. Standard signs and safety marks areemployed to control traffic safely. Rail sidings are in good condition, clear of obstruction,mud and ice, and protected from other traffic.

0 RI The site is in excellent condition. Regular, recorded inspections are conducted

D PP The site is in very good condition

0 IA The site is in good condition. Construction is underway to improve

0 DP The site is in good condition. Construction to improve is planned

D EV The site is in fair condition. Improvements are being evaluated

0 NA The site is in poor condition


40) Waste ManagementWaste streams at production sites are clearly identified and separated by hazard class anddegree of hazard. A program is in place to minimize the quantities of hazardous wastescreated. Contracts fo~ removal a~d disposal of waste materia~s is done using ~ rep~table "~contract company. This company is known to be safety conSCIOUS and responsIble m 1

respecting all environmental laws. All options are investigated to dispose of or recycle ) I

waste materials within acceptable government guidelines. Initiatives are in place topurchase recycled material and use own waste material in process where not prohibited by

regulation.

D RI All above conditions are met. The waste management system is reviewed

annually

0 PP All above conditions are met

D IA A program is underway to meet all of the conditions ,~e;,

,0 DP A program is under development to meet all of the conditions '

D EV The current waste management system is being evaluated

0 NA There is no organized waste management system.

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41) RecordsAll handling of waste is documented. These records are maintained in a central file. These

t records also are used in system audits for improvement of waste management and as~ evidence of the company's controls effectiveness.

r~:' 0 RI All waste handling is documented and maintained in a central file. TheI documents are reviewed annually during a system audit.c'

.t 0 PP All waste handling is documented and maintained in a central file

0 IA There is a program underway to document and maintain all waste handling

0 DP There is a program in development to document and maintain all waste handling

0 EV The need for documentation and maintenance of all waste handling is beingevaluated

0 NA Waste handling is not properly documented


42) Air EmissionsStack discharge and ventilation systems are designed to allow as Iowa volume ofemissions as practical; or at least below the limits set by legal standards. Regular testing isdone on these emissions to ensure they are continuing to be within allowable standards

0 RI All of the above conditions are met. Testing procedures and results are reviewed

annually

0 PP All of the above conditions are met.

0 IA There is a program underway to meet the above conditions

D DP There is a program under development to meet the above conditions

0 EV The need for emissions testing is being evaluated

0 NA There is no plan to monitor emissions to the air


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43) Spills PreventionTanks, vessels, piping and valves are inspected regularly for corrosion, leakage, cracks,signs of potential structural failure, and loss of thickness. Drums and other liquidcontainers in storage are inspected regularly for corrosion and leakage. Standardprocedures are in place to ensure tanks and vessels are not overfilled. Existingunderground tanks are monitored and dip-tested frequently (e.g. weekly) to check for lostvolumes.

D RI Vessels are inspected at least monthly and results are recorded. Standardprocedures are in place. All procedures are reviewed at least annually.

D pp Vessels are inspected at least monthly and results are recorded. Standardprocedures are in place

D IA Procedures for spill prevention have been written and will be implemented

D DP Procedures for spill prevention are being developed

D EV Procedures for spill prevention are being evaluated

D NA There are no procedures for spill prevention


44) Spills Clean-UpEvery packaging and formulating facility has in place, procedures to handle any type ofspill clean-up in consideration of the materials handled and the physical layout of theproduction site. Adequate clean-up equipment is either provided on site, or in the case oflarge clean-up requirements, contracted for by professional clean-up and disposalcompanies. Employees are trained in how to react to and report a spill. Clean-up crewshave been trained in control measures and safe clean-up methods for all types of materials(e.g. powder, liquids, etc.). Regulatory authorities are notified in the event of a majorclean-up effort.

D RI All above conditions are met. Procedures are reviewed at least annually

D PP All above conditions are met

D IA A plan to meet the conditions will be I place within 3 months

D DP A plan to meet the conditions will be in place within 6 months

0 EV A plan to meet the conditions will be in place within 12 months

0 NA No plan to meet the conditions

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0 DNA Does not apply45) Spills ContainmentFormulation, filling and storage areas for liquid materials have firm, smooth- finishedfloors sealed in conjunction with the walls, and the floors are sufficiently impermeable tocontain spills. Adequate spill containment of the contents of any vessel inside is required(e.g. doorways to the exterior of the plant are built up above floor). No floor drains tooff-site exist in these areas. There are no opening or cracks in the floor. Outside storagetank (tank farms) are located in an sealed walled area. The area must be large enough andthe wall high enough to contain a volume of liquid at least as great as that contained by thelargest of the tanks. If the area is not roofed over, there must be provision for the safedrainage of collected rain water. Likewise, similar containment must be provided aroundrail tanker loading areas.

D RI All above conditions are met. All areas are inspected and the results are recorded

D PP All above conditions are met. All areas are inspected

D IA Construction is underway to meet the conditions

D DP A plan is being developed to meet the conditions

0 EV Requirements for compliance are being evaluated

D NA Spill containment is non existent or ineffective


46) Safety Recording

Lost time incidents, first aid treatments and medical treatments are measured and recorded

0 RI All safety information is recorded. Results are reviewed each quarter andperformance against targets is evaluated

D PP All safety information is recorded

D IA A program to record all safety information will be in place within 3 months

D DP A program to record all safety information will be in place within 6 months

0 EV A program to record all safety information will be in place within 12 months

D NA No plan to record any safety information

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47) Product Stewardship Goals and PerformanceProduct stewardship goals have been established and communicated to the organization.Performance against these goals is measured.

D RI Goals have been established and reviewed annually. Performance is measuredagainst these goals

D PP Goals have been established. Performance is measured against these goals

0 IA Goals have been identified and will be in place within the next 3 months

0 DP Goals are being developed and will be in place within the next 6 months

0 EV Goals are being evaluated and will be in place within the next 12 months

~ 0 NA There are no goals

: D DNA Does not apply

48) MSDSCurrent and correct MSDS are generated and issued for all products. A file ofMSDS ismaintained in an accessible location that contains data sheets for all chemicals used in theplant. This file is updated on a regular basis.

0 RI Current MSDS are generated for all products. All chemicals used in the planthave an MSDS. MSDS' are reviewed annually.

D PP Current MSDS are generated for all products. All chemicals used in the planthave an MSDS.

0 IA Current MSDS are generated for most products. Most chemicals used in the planthave an MSDS. There is a plan to upgrade the MSDS.

0 DP There is a plan to generate MSDS for all products and chemicals used in the plant

D EV MSDS requirements are being evaluated

D NA Very few MSDS are generated or available j

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GOOD MANUFACTURING PRACTICES AND STEWARDSHIP … · GOOD MANUFACTURING PRACTICES AND STEWARDSHIP...

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Transcript of GOOD MANUFACTURING PRACTICES AND STEWARDSHIP … · GOOD MANUFACTURING PRACTICES AND STEWARDSHIP...