Posted on Fri, Sep 03, 2010
As mobile technology becomes more available, reliable, and affordable, different options for housing regulated emergency response plans have evolved. Many companies control their SPCC or facility response plans “the old fashion” way – by word-processed plans, either printed or hosted on a company intranet. For some, “paper-based” plans may be the most affordable option. However, costs to maintain these plans are higher due to the inefficiencies of managing multiple plans and many files that are not connected.
To determine if paper-plans fare costing more than you suspect, consider how much overlapping data exists between each plan type and among common plan types required for multiple facilities. For instance, are common company contacts required in more than one plan? Understanding which option is right for you is the key to easy plan maintenance, controlling costs, and ease of implementation during an emergency.
Consider a paper-based plan (word processed document, printed or posted to company intranet) if your company has:
- Less than five locations with no regulatory requirements
- Minimal duplication of information for each site
- One main corporate plan with no requirements for site-specific plans for operations
If paper plans are deemed a better option, it is best to minimize duplication of telephone numbers and name-specific responsibilities. If possible, limit the location of telephone numbers to one section of the plan, since each file must be updated separately.
A database-driven plan or system may be a better option for:
- Business continuity plans with more than 10 critical business processes.
- Emergency response or any other plan types for more than 5 locations – the more complex and numerous the plans, the more beneficial database-driven systems are likely to be.
- Plans in which more flexibility is desired to display corporate contact information in multiple plans.
- Plans in which ease and convenience are desired to display contact information in response checklists, and in multiple locations in the plan. This information can typically be updated in one location in the database and instantaneously display in all plans.
- Numerous regulatory agencies require plan submittal for approval.
These are just some of the circumstances that may aid in your decision to convert to a database driven planning system. Internal plan audits and consultations should also be considered, to ensure use of the right planning method for the specific circumstances.
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Posted on Tue, Aug 31, 2010
Corporate regulatory compliance can be a complex puzzle and challenging effort for industrial facilities that are subject to hundreds of constantly changing federal, state, and local requirements. Companies must track and document actions items required for compliance and maintain vigilance for new requirements.
Companies cannot afford to be out of compliance. The financial implications, negative public perception, and irrecoverable reputable damages can be significant. The use of Excel spreadsheets is a common way to manage these requirements and may be effective for small operations. However, larger operations must use an effective relational database to ensure that compliance can be managed on an enterprise level.
Key concepts for managing regulatory compliance:
- Utilize corporate resources or out source compliance expertise and leverage that expertise across the company
- Utilize a relational database to tie each regulatory requirement to all applicable facilities so that updating static and evolving regulatory information can be effectively managed across multiple facilities
- Identify mandatory submission requirements and tasks associated with each regulatory requirements
- Utilize database tools to assign compliance tasks, frequencies, due dates, and persons responsible. Document completion actions
- Track best practices procedures utilized across the company and the industry. Adopt these best practices when practical and beneficial
- Organize compliance information as to limit unnecessary duplication
- Create the ability to search this database for key words and phrases associated with regulations
With the use of technology, Corporations can get a handle on the continually evolving agency regulatory requirements and ensure compliance on an enterprise-wide basis.
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Posted on Fri, Aug 27, 2010
Spill Prevention Control and Countermeasure (SPCC) and Facility Response Plan (FRP) inspections are conducted to fulfill the Oil Pollution Prevention Regulation of the Clean Water Act as amended by the Oil Pollution Act of 1990. The EPA has conducted such inspections since 1973 in an effort to minimize oil spills from reaching our nation’s waters.
Owners and operators of facility from which a spill could reasonably be expected to discharge oil into navigable waters, must possess a professional engineer certified SPCC plan if their facility has more than a 1,320 gallon capacity aboveground storage tanks and/or more than 42,000 gallons capacity in underground storage tanks.
According to the EPA’s "What To Expect During an SPCC/FRP Inspection", the inspections have two purposes:
- To ensure that oil storage facilities, refineries, electrical utilities, and oil production fields, among other subject industries, are in compliance with 40 Code of Federal Regulations (CFR) part 112.
- To give U.S. Environmental Protection Agency (EPA) representatives the opportunity to educate owners and operators about the regulations and ways to ensure compliance.
Regional EPA representative(s) conduct both announced and unannounced inspections at facilities. A copy of the facility’s SPCC Plan should be available for inspector(s) to review at all times. Any other relevant documentation of your operating procedures, spill prevention measures, personnel training, inspection procedures, drainage discharges, and spill incidents should be provided to inspector(s), as well as, site plans for tankage, diversionary structures, and drainage patterns.
The inspector(s) will evaluate:
- Storage tanks, and other equipment containing oil
- Diversionary structures
- Truck loading/unloading areas
- Facility design
- Drainage patterns
- Operating procedures
- SPCC measures and their ability to prevent the release of oil to storm drains (onsite or offsite), creeks, streams, ditches, rivers, bays, or other waterways
The inspector(s) familiarize themselves with the facility’s SPCC plan and current operations, including aboveground and underground equipment (i.e., tanks, pipelines, oil-water separators, etc.). After the opening review, the inspector(s) conducts a walk-through of your facility, possibly taking photographs as proof of SPCC implementation. The SPCC measures discussed in your Plan must have been implemented throughout the facility in order to be in compliance with the regulations.
Usually, a debriefing meeting concludes the inspection. Observations are discussed with those accompanying personnel who are familiar with your facility’s SPCC measures, diversionary structures, and standard operating procedures. By having key individuals present, questions can be answered by both parties and ensure that correct information is provided. The inspection and evaluation may be summarized in a letter or a more detailed report containing photographs.
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Posted on Tue, Aug 24, 2010
The EPA has requested $34.4 million of its total budget to be allocated to continue to focus on issues included in the Energy Policy Act of 2005. The Energy Policy Act of 2005 P.L. 109-58 (EPAct) imposed several responsibilities and regulatory requirements on the individual states. Section 1523 of the Act imposed one of the most significant new requirements: States must inspect all regulated underground storage tanks (USTs) every three years. States had to complete the first three-year inspection cycle by August 2010.
Leaks, or releases, from underground storage tanks (UST) continue to pose a serious threat to the environment and to public health. "Out of sight does not mean out of mind when it comes to underground storage tanks, which is why it is critical that facilities monitor their tanks and make sure they are not leaking," said EPA Region 2 Administrator, Judith Enck.
The EPA’s 2011 “Budget in Brief” explains that individual states will continue to use the UST categorical grant funding to implement their leak prevention and detection programs. Through these UST categorical grants, states can continue to fund such activities as:
- Seeking state program approval to operate the UST program in lieu of the Federal program.
- Approving specific technologies to detect leaks from tanks.
- Ensuring that tank owners and operators are complying with notification and other requirements.
- Ensuring equipment compatibility.
- Conducting inspections.
- Implementing operator training.
- Prohibiting delivery for non-complying facilities
- Requiring secondary containment or financial responsibility for tank manufacturers and installers.
Routine EPA inspections of P.J. Hyde & Son, Inc.’s gas stations and hotel in N.Y revealed that from 2007 to 2009, the company failed to properly test the leak detection equipment of underground petroleum storage tank systems for leaks at five gas stations in Saranac Lake, Tupper Lake and Indian Lake, and a hotel in Lake Clear. The company was fined $16,000 under the agreement. As a result, P.J. Hyde & Son, Inc is spending $60,000 to improve its leak detection system.
According to the EPA’s semi-annual report of UST Performance Measures Mid fiscal year 2010, 491,572 releases have been reported since the beginning of the monitoring program in 1984. UST partners have completed more than 395,433 cleanups or about 80 percent. Between October 2009 and March 2010, 48,235 on-site inspections have been conducted. The 2011 allocated budget will continue to allow the EPA to monitor underground storage tanks. Facilities must be aware of their responsibilities and regulatory requirements.
Be prepared for a leak or release. For tips and best practices on conducting an effective oil spill exercise, download our Free Best Practices Guide.
Posted on Fri, Aug 20, 2010
The U.S. Coast Guard’s new regulations to improve pollution-response preparedness for vessels carrying or handling oil upon the navigable waters of the United States goes into effect February 22, 2011.
This final rule, applicable upon all navigable waters of the U.S. including the exclusive economic zone and adjoining shorelines, updates Coast Guard requirements for oil-spill removal equipment associated with vessel response plans and marine transportation-related facility response plans.
The new rules directly regulate vessels carrying oil in bulk and marine transportation related (MTR) oil facilities that are required to have an oil response plan under the current Vessel Response Plan rules. These regulatory updates add requirements for plan holders to use new response technologies and revise methods and procedures for oil spill response. Vessel Response Plan holders must ensure dispersant service providers meet regulatory response requirements. Instead of detailed equipment lists, plan holders can reference OSROs that provide dispersants if USCG classified and whose availability has been ensured by contract or other approved means.
The following additional American Society for Testing and Materials (ASTM) are applicable to vessels:
- ASTM F1413–07, Standard Guide for Oil Spill Dispersant Application Equipment: Boom and Nozzle Systems, incorporation by reference approved for §155.1050.
- ASTM F1737–07, Standard Guide for Use of Oil Spill Dispersant-Application Equipment During Spill Response: Boom and Nozzle Systems, incorporation by reference approved for §155.1050.
- ASTM F1779–08, Standard Practice for Reporting Visual Observations of Oil on Water, incorporation by reference approved for §155.1050.
The following are some of the additional updated requirements for vessels. A detailed list of the new requirements can be found at: http://edocket.access.gpo.gov/2009/pdf/E9-20311.pdf
- § 155.230 Emergency control systems for tank barges- Each operator of the system should wear a safety belt or harness secured by a lanyard to a lifeline, drop line, or fixed structure such as a welded padeye, if the sea or the weather warrants this precaution. Each safety belt, harness, lanyard, lifeline, and drop line must meet the specifications of ANSI A10.14
- 155.235 Emergency towing capability for oil tankers- An emergency towing arrangement shall be fitted at both ends on board all oil tankers of not less than 20,000 deadweight tons (dwt), constructed on or after September 30, 1997. For oil tankers constructed before September 30, 1997, such an arrangement shall be fitted at the first scheduled dry-docking, but not later than January 1, 1999. The design and construction of the towing arrangement shall be in accordance with IMO resolution MSC.35(63)
- 155.1035 Response plan requirements for manned vessels carrying oil as a primary cargo-
o The format and content of the ship-to-ship transfer procedures must be consistent with the Ship-to-Ship Transfer Guide (Petroleum) published jointly by the International Chamber of Shipping and the Oil Companies International Marine Forum (OCIMF).
o For vessels that handle, store, or transport Group I through Group V petroleum oils, the appendix must also separately list the resource providers identified to provide the salvage, vessel firefighting, and lightering capabilities.
o For vessels that handle, store, or transport Group II through Group IV petroleum oils, and that operate in waters where dispersant use pre-authorization agreements exist, the appendix must also separately list the resource providers and specific resources, including appropriately trained dispersant-application personnel, necessary to provide, if appropriate, the dispersant capabilities required in this subpart. All resource providers and resources must be available by contract or other approved means.
o The appendix must also separately list the resource providers and specific resources necessary to provide oil-tracking capabilities required in this subpart.
- 155.1040 Response plan requirements for unmanned vessels carrying oil as a primary cargo-
o The appendix must include a separate listing of the resource providers identified to provide the salvage, vessel firefighting, and lightering capabilities.
o The appendix must include a separate listing of the resource providers and specific resources necessary to provide, if appropriate, the dispersant capabilities.
o The appendix must include a separate listing of the resource providers and specific resources necessary to provide oil-tracking capabilities.
- 155.1050 Response plan development and evaluation criteria for vessels carrying groups I through IV petroleum oil as a primary cargo.
o The owner or operator of a vessel carrying groups II through IV petroleum oil as a primary cargo that operates in any inland, nearshore, or offshore area with pre-authorization for dispersant use must identify in their response plan, and ensure availability through contract or other approved means, of response resources capable of conducting dispersant operations within those areas.
o The owner or operator of a vessel carrying groups I through IV petroleum oil as a primary cargo must identify in the response plan, and ensure their availability through contract or other approved means, response resources necessary to provide aerial oil tracking to support oil spill assessment, and cleanup activities. Vessels operating on inland rivers are not required to comply with this directive.
o Aerial oil tracking resources must be capable of arriving at the site of a discharge in advance of the arrival of response resources identified in the plan for tiers 1, 2, and 3 Worst Case Discharge response times, and for a distance up to 50 nautical miles from shore (excluding inland rivers).
o The Coast Guard will continue to evaluate the environmental benefits, cost efficiency and practicality of increasing mechanical recovery capability requirements. This continuing evaluation is part of the Coast Guard's long-term commitment to achieving and maintaining an optimum mix of oil spill response capability across the full spectrum of response modes. As best available technology demonstrates a need to evaluate or change mechanical recovery capacities, a review of cap increases and other requirements contained within this subpart may be performed.
- Appendix B to part 155 Determining and Evaluating Required Response Resources for vessel Response Plans-
o If the required capacity exceeds the applicable cap, then a vessel owner or operator must contract for at least the quantity of resources required to meet the cap, but must identify sources of additional resources as indicated in §155.1050(p). For a vessel that carries multiple groups of oil, the required effective daily recovery capacity for each group is calculated and summed before applying the cap.
o A vessel owner or operator must plan either for a dispersant capacity to respond to a vessel's worst case discharge (WCD) of oil, or for the amount of the dispersant resource capability as required by §155.1050(k)(3) of this chapter, whichever is the lesser amount. When planning for the cumulative application capacity that is required, the calculations should account for the loss of some oil to the environment due to natural dissipation causes (primarily evaporation).
Affected plan holders should review the final rules and take all necessary measures to ensure that an updated response plans are submitted by February 22, 2011 and in compliance.
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Posted on Tue, Aug 17, 2010
The U.S. Coast Guard’s new regulations to improve pollution-response preparedness for facilities carrying or handling oil upon the navigable waters of the United States goes into effect February 22, 2011.
This final rule, applicable for shorelines adjoining navigable waters of the U.S. including the exclusive economic zone, updates Coast Guard requirements for oil-spill removal equipment associated with facility response plans and marine transportation-related facility response plans. These regulatory updates add requirements for plan holders to use new response technologies and revise methods and procedures for oil spill response.
The rule applies to pre-approved areas only, not areas designated for quick approval of dispersant use. If you have an existing approved facility response plan, you must have your plan updated and submitted to the Coast Guard by February 22, 2011.
The new regulations will affect facility response plans, vessel response plans, and dock operations manuals. The new rules directly regulate marine transportation related (MTR) oil facilities that are required to have an oil response plan under the current Facility Response Plan rules.
The new regulations include, but are not limited to the following:
- Plan holders to offset their mechanical recovery equipment inventory by as much as 25% in exchange for including dispersants in the response plans.
- Pre-authorization agreements indicate that dispersant use may be appropriate and will be approved for use in a spill incident meeting certain predetermined criteria that may occur in the covered area. The regulations will ensure that the dispersant equipment and materials are available, and that the cost of maintaining those resources is shared equitably among all potential private sector users.
- Regulations were modified to clarify that plan holders should plan to have aerial tracking capabilities available to support response operations for entire daily operational periods. As operations are not routinely conducted during darkness, these operational periods will be less than 10 hours per day when there is less than 10 hours of daylight, and longer than 10 hours when there is more than 10 hours of daylight. The 10-hour operational period is offered as a planning target. An individual plan holder may choose to plan more precisely, based on actual length of daylight operational periods. Vessels/facilities operating on inland rivers aren’t required to maintain aerial tracking capabilities. Vessels operating on open waters of the Great Lakes will be required to maintain these capabilities.
Some of the new regulations for Facilities transferring Oil or Hazardous Material in Bulk are as follows:
- Hose assemblies may also have Flanges that meet ANSI B16.5 or B16.24 (both incorporated by reference; see §154.106
- Each mechanical loading arm used for transferring oil or hazardous material and placed into service after June 30, 1973, must meet the design, fabrication, material, inspection, and testing requirements in ANSI B31.3.
- All welding or hot work conducted on or at the facility is the responsibility of the facility operator. The COTP may require that the operator of the facility notify the COTP before any welding or hot work operations are conducted. Any welding or hot work operations conducted on or at the facility must be conducted in accordance with NFPA 51B. The facility operator shall ensure that the additional conditions or criteria are met.
- Barring exceptions, Tank cleaning or gas freeing operations conducted by the facility on vessels carrying oil residues or mixtures shall be conducted in accordance with sections 9.1, 9.2, 9.3, and 9.5 of the OCIMF International Safety Guide for Oil Tankers and Terminals (ISGOTT)
- Vapor collection system piping and fittings must be in accordance with ANSI B31.3 and designed for a maximum allowable working pressure of at least 150 psig. Valves and flanges must be in accordance with ANSI B16.5 or B16.24, 150-pound class.
- Flanges must have a bolt hole arrangement complying with the requirements for 150 pound class ANSI B16.5
- The additional vessel liquid overfill protection requirements must be met: ANSI/NEMA WD6 and NFPA 70, National Electrical Code, Articles 410–57 and 501–12.
- Overfill control panel on the dock capable of powering and receiving an alarm and shutdown signal from the cargo tank level sensor system must have Has a female connecting plug for the tank barge level sensor system with a 5 wire, 16 amp connector body meeting IEC 309–1/309–2.
- The vessel vapor overpressure and vacuum protection be tested for relieving capacity in accordance with paragraph 1.5.1.3 of API 2000 with a flame screen fitted.
- The inerting, enriching, and diluting systems be installed in accordance with API Recommended Practice 550
- Take special note to § 154.1035: Specific requirements for facilities that could reasonably be expected to cause significant and substantial harm to the environment
- Take note of § 154.1045: Response plan development and evaluation criteria for facilities that handle, store, or transport Group I through Group IV petroleum oils.
- A new or existing facility owner or operator must submit the required dispersant and aerial oil tracking resource revisions to a previously submitted or approved plan, made pursuant to §§154.1035(b)(3) or 154.1045, to the COTP and all other holders of the response plan for information or approval no later than February 22, 2011.
- Under Appendix C to Part 154: The guidelines for determining daily application capacities for dispersant response systems, evaluating the high-rate required response methods, and calculating cumulative dispersant application capacity has been updated.
- In addition to the equipment and supplies required, a facility owner or operator must identify a source of support to conduct the monitoring and post-use effectiveness evaluation required by applicable regional plans and Area Contingency Plans.
- Identification of the resources for dispersant application does not imply that the use of this technique will be authorized. Actual authorization for use during a spill response will be governed by the provisions of the National Oil and Hazardous Substances Contingency Plan (40 CFR part 300) and the applicable Local or Area Contingency Plan.
For a full list of regulations, see http://edocket.access.gpo.gov/2009/pdf/E9-20311.pdf.
The Coast Guard is also revising the compliance date for updates to vessel response plans required by the Salvage and Marine Firefighting final rule published Dec. 31, 2008 (73 FR 80618). This new compliance date of Feb. 22, 2011, ensures plan holders will not be required to update their Vessel Response Plan’s twice within a 12-month period.
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Posted on Fri, Aug 13, 2010
Numerous organizations have emergency response policies in place based on misinterpretation of the HAZWOPER regulations. The purpose of the initial responder (operations level) of an emergency is to protect life, property, or the environment from the effects of the release, not stop the release.
Operational responders are trained to respond in a defensive fashion without actually trying to terminate the release. Their function is to contain the release from a safe distance, keep it from spreading, and prevent exposures.
Employees who are exposed or potentially exposed to hazardous substances, including hazardous waste, are required to be HAZWOPER certified. According to OSHA, first responders at the operations level are those individuals who respond to releases, or potential releases, of hazardous substances as part of the initial response to the site.
Any employee or contractor, upon discovering a significant event or condition that requires urgent response from outside trained personnel, should take the suggested initial response actions listed below and report the emergency to the designated onsite Emergency Dispatch Center to render additional response.
Initial Response Actions:
- Discovery of an emergency situation.
- Warn others in the immediate area by word of mouth and activate local alarms.
- Take immediate personal protective measures (PPE, move to safe location, etc.).
- Report the emergency to Security.
- Implement local response actions (process shutdowns, activate fire protection systems, etc.) if safe to do so, and consistent with level of training and area specific procedures.
A response effort by trained emergency personnel from outside the immediate area, or by other designated responders (i.e., mutual aid groups, local fire departments, etc.), would then go into effect. An event that requires outside emergency assistance can be, but is not limited to, an uncontrolled release of a hazardous material, fire, explosion, and serious injury or illness to personnel where there is a potential risk of exposure to blood borne pathogens.
Below are examples of classification levels and potential responses.
LEVEL ONE Classification: Minor Incident
- Minor threat to life, property, or environment DOES NOT extend outside of immediate area.
- No spill/release or fire in progress, no potential for explosion or loss of control.
- Area Supervisor and Unit personnel can effectively manage situation.
Response
- On-Scene Incident Commander and Emergency Response Team assistance limited to routine medical response, advice, assessment, and post-incident support/cleanup activities.
- External assistance limited to routine medical transport and/or law enforcement assistance.
- Notifications as required.
LEVEL TWO Classification: Serious Incident
- Serious threat to life, property, or environment may extend outside of immediate area, but DOES NOT extend Off-Site.
- Protective actions required for unit and/or nearby areas.
- Rescue or medical response - Serious injuries reported or possible.
Response
- On-Scene Incident Commander and Emergency Response Team respond or on stand-by.
- External assistance at discretion of On-Scene IC.
- Emergency Operation Center will be activated.
LEVEL THREE Classification: Significant Incident
- Significant threat to life, property, or environment extending or with POTENTIAL to extend Off-Site.
- Protective actions required for nearby units/areas, and/or off-site communities.
- Potential for significant impact to company reputation, operability, or revenues.
Response
- On-Scene Incident Commander and Emergency Response Team respond.
- External coordination and/or assistance is required.
- An Emergency Command Center is activated.
- Corporate Crisis notification at discretion of Emergency Operations Center Director
In conclusion, operational responders are trained for defensive reactions, not to terminate the release. Their main function is to contain the release from a safe distance, keep it from spreading and creating exponential incidences, and prevent exposures.
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Posted on Tue, Aug 10, 2010
According to the Occupational Safety and Health Administration (OSHA), almost every business is required to have either a written or verbally communicated Emergency Action Plan (EAP). As stated by OSHA, if fire extinguishers are required or provided in your place of business, and if anyone will be evacuating during a fire or other emergency, then OSHA's 29 CFR 1910.157 requires you to have an EAP.
“The only exemption to this is if you have an in-house fire brigade in which every employee is trained and equipped to fight fires, and consequently, no one evacuates”, as stated by OSHA.
29 CFR 1910.157(g)(1) requires the employer provide an educational program for employees to familiarize them with fire extinguishers and the hazards involved with the incipient stage of fire fighting. Employers must train the designated employee(s) upon initial assignment of the task and thereafter, on an annual basis n the use of the specific on-site fire equipment.
A well-trained employee with an on-site fire extinguisher can put out small, non-hazardous fires effectively. However, to do this safely, the employee must have knowledge of equipment and portable fire extinguisher limitations, in addition to the hazards associated with fighting fires. There may be situations where employee firefighting is warranted to give other workers time to escape, or to prevent danger to others by spread of a fire.
OSHA provides the following Risk Assessment:
The following chart is a sample of OSHA’s fire extinguisher education.
If professional firefighting services are available in your area, immediate evacuation may be the best policy if responders can be at the site quickly.
If a hazardous substance emergency could occur at your facility and you plan to have any of your employees participate in the emergency response, you are required to have an Emergency Response Plan in writing and available for inspection consistent with 29 CFR 1910.120(q) (Hazardous Waste Operations and Emergency Response).
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Posted on Fri, Aug 06, 2010
Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. The U.S. Department of Labor's Occupational Safety and Health Administration (OSHA) role is to assure these conditions for America's workforce by setting and enforcing standards, and providing training, education and assistance.
On April 2010 OSHA cited American Packaging Corporation with 29 alleged violations of federal workplace health and safety standards, following an investigation of an employee’s death in October 2009. Those violations included the lack of a proper emergency response plan and the lack of procedures for contacting rescue and emergency services. Fines totaling $127,350 were assessed to the company.
It was only six months before the death of the long-time American Packaging Corporation employee that OSHA declared American Packaging Corporation as a star site in its prestigious Voluntary Protection Programs (VPP). "American Packaging has an excellent record in workplace safety and health," said Kimberly Stille, director of OSHA's Madison, Wisconsin, area office, who presented the company with a VPP star flag and plaque. "This site's outstanding efforts include management commitment and continuous improvement, as well as exceptional employee involvement in safety and health programs." It is unclear if OSHA reviewed their Emergency Response Plan at the time.
Corporations must ensure that their Emergency Response Plan is a living document that addresses all potential emergencies and all aspects of a potential emergency. Internal audits and/or external consultants can review your emergency response plans and identify areas of deficiencies. Considering the potential cost of cutting corners in an Emergency Response Plan, the efforts put forth to ensure a thorough emergency plan is well worth the time and financial commitment.
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Posted on Tue, Aug 03, 2010
The U.S Chemical Safety Board (CSB) is an independent federal agency that investigates the cause of chemical accidents. These investigations are crucial to identifying the cause(s) of the incidents. The agency does not assess fines, but creates “lessons learned” stemming from root causes. At times, the evidence of these investigations is used to modify regulations and positively affect the future safety of employees, the public and the environment.
The agency states that most accidents stem from flawed safety management systems. And, in most cases, accidents are a result of preventative factors.
Throughout accident investigations, CSB has the authority to re-open prior investigations before drafting key findings of the main cause of the accident. CSB utilizes this to seek regulatory revisions in order to address safety and security issues.
On June 29th, the CSB approved urgent recommendations to regulatory agencies such as OSHA and NFPA relating to pipe cleaning and purging operations. According to the CSB, the recommendation resulted from the extensive investigations into the February 7, 2010, explosion at the Kleen Energy power plant in Middletown that caused six deaths and multiple injuries, and the June 9, 2009, explosion at the ConAgra Foods Slim Jim plant in Garner, North Carolina, that killed four workers and injured 67. An investigation revealed that both explosions resulted from releases of natural gas during the installation and commissioning of new piping for gas-fired appliances.
The CSB urged OSHA to pass regulations that would prohibit the use of natural gas for pipe cleaning, the cause of the explosion at Kleen Energy, and would prohibit the venting or purging of fuel gas indoors, the cause of the explosion at the ConAgra Slim Jim plant. Both explosions resulted from releases of natural gas during the installation and commissioning of new piping for gas-fired appliances. OSHA was also urged to require that companies involve their workers and contractors in developing safe procedures and training for handling fuel gas.”
Many CSB recommendations have been adopted by industry, leading to safer plants, workers, and communities. Investigations may lead to adjustments in corporate regulatory compliance. Facilities must be aware of the constant changes in regulations, and adapt procedures and processes to comply with new regulations. Regulatory tracking results in safer work-sites and limits the potential site fines assesed by regulatory agencies.
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