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PLAIN ENGLISH GUIDE TO EHS LAWS
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HAZWASTE OPER'S & EMERGENCY RESPONSE (29 CFR 1910.120 - HAZWOPER), FEATURING 40, 24, & 8-HOUR COMPONENTS

Under the authority of section 126 of the Superfund Amendments and Reauthorization Act, Title I [not Title III] (1986), EPA and OSHA promulgated identical health and safety standards to protect workers engaged in hazardous waste operations and emergency response. The OSHA regulations, codified at 29 CFR 1910.120, became effective on March 6, 1990. The EPA regulations incorporate the OSHA standards by reference and are codified at 40 CFR Part 311. The standards affect employers whose employees are engaged in emergency response operations without regard to location, where there is a release or a substantial threat of release of a hazardous substance.

The EPA and OSHA employee protection standards for HAZWOPER apply to five groups of workers, two of which fit mainstream industry in the manufacturing sector. These two are called: 1. Mandatory Cleanups at Uncontrolled Hazardous Waste Sites; 2. Voluntary Cleanups at Uncontrolled Hazardous Waste Sites. A hazardous waste site is commonly understood to be a facility in which hazardous waste is generated as a part of its operations. The latter three groups are associated with RCRA "Treatment, Storage, Disposal" Facilities, better known as TSD's. Unlike HazCom Training, where all employees are to be trained about hazardous chemicals in the workplace, HAZWOPER does not apply to employees who do not have the potential to be exposed to hazardous substances. For example, administrative support personnel may not be covered by the standard, but are, of course, protected by other OSHA standards. They should also be made aware of the provisions of the emergency response plan, and must be briefed on emergency procedures and general site operations.

HAZWOPER Regulations contain general and specific requirements for health and safety programs, site characterization and analysis, site control, emergency response team training, medical surveillance, engineering controls and work practices, personal protective equipment, heat stress and cold exposure monitoring, informational programs, handling drums and chemical containers, hazardous waste / material handling, decontamination, and emergency procedures for catastrophic events.

To further highlight the challenges, dumping of hazardous waste poses a significant threat to the environment. In 1985, the EPA managed about 275 million metric tons of hazardous waste at licensed RCRA sites. Hazardous waste is a serious safety and health problem that continues to endanger human and animal life and environmental quality. Hazardous waste - discarded chemicals that are toxic, flammable, or corrosive - can cause fires, explosions, and environmental pollution. Unless hazardous waste is properly treated, stored, or disposed of, it will continue to do great harm to all living things that come into contact with it now or in the future. It is because of the seriousness of safety and health hazards related to hazardous waste operations that OSHA issued its HAZWOPER standard, specifically developed to protect employees in the workplace and to help them handle hazardous wastes safely and effectively.

THE WRITTEN PROGRAM. An effective and comprehensive safety and health program is essential in reducing work-related injuries, accidents, and illnesses, and in maintaining a safe and healthful work environment. OSHA, therefore, requires each employer to develop and implement a site-specific written program that identifies, evaluates, and controls hazards and provides emergency response procedures for hazardous waste sites. The plan must be periodically updated (generally on an annual basis to coincide with annual employee refresher training), and made available to all affected employees, contractors, and subcontractors.

WORKPLAN. The workplan should include the following:
- Supervisor and employee responsibilities and means of communication;
- Name of person who supervises all of the hazardous waste operations;
- Site supervisor with responsibility for an authority to develop and implement
the HAZWOPER program and to verify compliance.
- Anticipated clean-up and/or HazWaste operating procedures;
- Personnel requirements for implementing the plan;
- Procedures for training, medical surveillance, emergency response, etc.

SITE EVALUATION & CONTROL. It is extremely important, and a requirement of the standard, that a trained person conduct a preliminary evaluation of an uncontrolled hazardous waste site before entering the site. The evaluation must include all suspected conditions that are immediately dangerous to life or health or that may cause serious harm to employees (confined space entry, potentially explosive or flammable situation, visible vapor clouds, etc.)

SITE-SPECIFIC SAFETY/HEALTH, INFORMATION, & TRAINING PROGRAM. When a program is site-specific to conditions at the facility in question, while using HAZWOPER regulations as the foundation for that site-specificity, a facility shall be deemed as having met its compliance responsibilities. Moreover, employers are required to develop and implement a program to inform workers performing hazardous waste operations of the level and degree of exposure they are likely to encounter. Training makes workers aware of the potential hazards they may encounter and provides the necessary knowledge and skills to perform their work with minimal risk to their safety and health. The employer is mandated to develop a training program for all employees exposed to safety and health hazards during HazWaste operations. Employees at all sites must not perform any HazWaste operations unless they have been trained to the level required by their job function and responsibility and have been certified by their instructor as having completed the necessary training. The initial training generally is comprised of either 24 or 40 hours of onsite instruction to teams of 8, 12, or 16 employees, depending upon the circumstances existing at the facility. Subsequently, all emergency responders must receive refresher training sufficient to maintain or demonstrate competency annually, usually executed in an 8 hour onsite session. Training would include hazardous materials and their risks, as well as knowing how to select and use appropriate control, containment, or confinement procedures and how to implement them. Employees who receive the specified training must be given a written certificate upon successful completion of that training.

PERSONAL PROTECTIVE EQUIPMENT (PPE). The HAZWOPER standard further requires the employer to develop a written PPE program for all employees involved in hazwaste operations. The PPE program must include an explanation of equipment selection and use, hazwaste accumulation, maintenance, and storage, decontamination and disposal, proper fit, donning and doffing procedures, inspection, in-use monitoring, program evaluation, and equipment limitations.

MONITORING. Airborne contaminants can present a significant threat to employee safety and health, thus making air monitoring an important element of the HAZWOPER program. The employer must conduct monitoring before site entry at hazwaste sites to identify conditions immediately dangerous to life and health, such as oxygen-deficient atmospheres and areas where toxic substance exposures are above permissible limits. Accurate information on the identification and qualification of airborne contaminants is useful for selecting PPE, assessing potential exposure, and determining the need for specific medical monitoring.

MEDICAL SURVEILLANCE. A medical surveillance program is required for meeting the HAZWOPER standard since it will help to assess and monitor the health and fitness of employees working with hazardous substances.

DECONTAMINATION. Procedures for decontamination must be developed, communicated to employees, and implemented before workers may enter a hazwaste site. All decontamination procedures must also occur before the employee leaves the work area.

EMERGENCY RESPONSE. Proper emergency planning and response are important elements of the over all HAZWOPER program for the purpose of minimizing employee exposure and injury. The standard requires that the employer develop and implement a written emergency response plan to handle conceivable emergencies and contingencies before performing hazwaste operations. The plan must include the following:

Personnel roles, lines of authority, and communication protocols,
Pre-emergency planning,
Recognition of emergencies and their prevention,
Emergency medical and first-aid treatment,
Methods for alerting onsite employees,
Safety distances and places of refuge,
Site security and control,
Decontamination procedures,
Critique of response and follow-up,
Personal protective and emergency equipment,
Evacuation routes and procedures.

The plan must include site topographical maps, facility layout (with quantity, containers, and location of all chemicals reflected in Material Safety Data Sheets), prevailing weather conditions, and emergency notification procedures for local, state, and Federal authorities.

There are five basic levels for HAZWOPER training;

1. FIRST RESPONDER AWARENESS LEVEL. First responders at the awareness level are employees who are likely to witness or discover a hazardous substance release and who have been trained to initiate an emergency response sequence by notifying the authorities of the release. There are many competencies in the hazardous materials training phase of HAZWOPER for the First Responder to attain.

2. FIRST RESPONDER OPERATIONS LEVEL. These responders actually respond to releases of hazardous substances as part of the initial response to the site for the purpose of protecting nearby employees, property, and the environment from the effects of the release. Training for this level is more focused on risk assessment, PPE, and containment techniques.

3. HAZARDOUS MATERIALS TECHNICIAN. These are employees who respond to releases for the purpose of stopping the release. They assume a more aggressive role than a first responder at the operations level in that they will approach the point of release in order to plug, patch, or otherwise stop it.

4. HAZARDOUS MATERIALS SPECIALIST. The employees respond and provide support to hazardous materials technicians. Duties are parallel, but the Hazardous Materials Specialist would also act as site liaison with Federal, state, local, and medical authorities in regards to site activites and response.

5. ON SCENE INCIDENT COMMANDER. Incident commanders, who will assume control of the incident scene, will oversee all emergency response and containment strategies in the HAZWOPER program.

The TWENTY-FOUR (24) HOUR TRAINING AT THE HAZARDOUS MATERIALS TECHNICIAN LEVEL includes the following:
1. Review of the law and its compliance requirements for Hazardous Materials
Technicians;
2. Training of Hazardous Materials Technicians on hazardous substances and how to identify and verify the presence of them, using field equipment;
3. Training in performing proper containment and confinement procedures of hazardous materials and hazardous waste within the scope of the facility relative to reasonably-anticipated emergency situations;
4. Site-Specific Training Manual for all participants;
5. Personal Protective Equipment usage, fitting, and decontamination;

The EIGHT (8) HOUR TRAINING AT THE FIRST RESPONDER OPERATIONS LEVEL. This aspect of HAZWOPER serves as the annual refresher once the 24 hour course has been satisfied by each participant. It includes:
1. An understanding of pertinent hazards and associated risks;
2. An understanding of the potential for disastrous outcomes when an emergency involves hazardous materials;
3. An understanding of the additional emergency response resources available
when needed;
4. The ability to identify the hazards present in an emergency;
5. The selection and use of Personal Protective Equipment, including respirator
selection, fitting, and training;
6. The elements of control and containment of releases within the capabilities
of the responder.

LOCKOUT / TAGOUT (THE CONTROL OF HAZARDOUS ENERGY)
MACHINE-SPECIFIC PROCESS DESIGN & TRAINING - OSHA 29 CFR 1910.147

For the purpose of employee safety, health, and accident prevention, the OSHA Lockout / Tagout Standard under 29 CFR 1910.147 covers the servicing and maintenance of machines and equipment in which the unexpected energization, start up, or release of stored energy could cause injury or death to employees. OSHA requires employers to establish a written program, site-specific procedures and minimum performance standards for affixing appropriate lockout and/or tagout attachments to energy isolating devices, and to otherwise disable machines or equipment from unexpected energization, start up, or release of stored energy in order to prevent injury to employees.

Unlike OSHA Hazard Communication Training, where training is required for all employees, OSHA's objectives for Lockout / Tagout focuses on the machine-specific "Control of Hazardous Energy" through the implementation of Lockout / Tagout procedures with subsequent emphasis on employee instruction. While this difference in objectives makes employee instruction no less important, OSHA's objective, by its very nature, implies that less employees may be involved in the training functions of the Lockout / Tagout Standard. The concentration is on machinery lock and tag procedures that then must be followed by relevant training of appropriate employees.

The Wall Street Journal (February 3, 1994) reports the chance of injury is far higher at smaller companies than large ones. From 1988-1992, 4,337 workers died at inspected workplaces with fewer than 20 employees, but only 127 died at those with more than 2,500 workers. The National Safety Council reports violations pertinent to Lockout / Tagout placed in the Top 10 among all OSHA violations during fiscal 1993.

Following are general requirements for Lockout / Tagout:

- ENERGY CONTROL PROGRAM. The employer shall establish a program consisting of energy control procedures, employee training and periodic inspections to ensure that before any employee performs any servicing or maintenance on machinery or equipment, it shall be isolated from the energy source and rendered inoperative.

- LOCKOUT / TAGOUT. If an energy isolating device is not capable of being locked out, the employer's program shall utilize a tagout system. If an energy isolating device is capable of being locked out, the employer's energy control program shall utilize lockout. After January 2, 1990, energy isolating devices on new machinery shall be designed to accept a lockout device.

- FULL EMPLOYEE PROTECTION. When a tagout device is used, the tagout device shall be attached at the same location that the lockout device would have been attached, and the employer shall demonstrate that the tagout program will provide a level of safety equivalent to that obtained by using a lockout procedure.

- ENERGY CONTROL PROCEDURE. Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in servicing and maintenance of machinery and equipment. The procedures shall clearly and specifically outline the scope, purpose, authorization, rules, and techniques for the control of hazardous energy, and compliance enforcement.

- PROTECTIVE MATERIALS AND HARDWARE. Such materials and hardware shall follow "intended use" guidelines, including durability, standardization, strength, identifiability, periodic inspection, and training/communication of employees involved.

PRELIMINARY INFORMATION REQUIRED TO DEVELOP LOCKOUT PROGRAM
1. Process & Instrumentation Design (P&ID). Facility layout, diagrams, and drawings for all hazard sources (mechanical, hydraulic, pneumatic, electric, other) that identify, locate, and isolate hazard analysis information;
2. Original Equipment Manufacturer phone numbers, contacts, and machinery manuals, as available;
3. Maintenance and service data that identifies residual energy sources and steps to normal startup, energy dissipation, and normal shutdown procedures;
4. Machine-specific hazard analysis to develop locks and tags which will later become the subject matter of the training component for employee participants;
5. Identify & list Authorized Employees (Maintenance/Engineering employees who will be authorized to apply and remove lockout / tagout devices); Identify & list Affected Employees (those who operate machines); Identify and list "Other" Employees (those who work in area where lockout / tagout controls are implemented).
6. Written Program. The written program becomes a living, working document that relates the facility's Hazard Analysis to the employees' training. Proper procedures for program implementation shall be an integral part of the written program. Since OSHA's Lockout Standard mandates a written program, the written program, hazard analysis documentation, and supportive records become an inspection showpiece and defensible documentation upon the visitation of an OSHA inspector.

Training and communication shall involve three groups of employees: AUTHORIZED, AFFECTED and "OTHER" EMPLOYEES. Authorized employees shall received training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control. Affected employees shall be instructed in the purpose and use of the energy control procedure. "Other" employees whose work activity may be in an area where energy control procedures may be utilized, shall be instructed about the procedures and prohibition to restarting or re-energizing machines or equipment which are locked or tagged out. It may be necessary to conduct a "moving" classroom as per the instructor's design of content regarding machinery and procedural implementation of materials and hardware. Dialogue should encompass accident prevention, as well as procedures in responding to an accident. Personal Protective Equipment shall be discussed as pertinent to machinery operations and maintenance. Classes shall be limited to groups of no more than 15 employees, although the instruction could potentially be conducted for as low as 2 employees, or as high as all production employees in the workplace.

Employee retraining shall be required on an annual basis for the purpose of keeping procedures current with variables in the workplace: change in job assignments, new hazards, machinery and processes, inspection guidelines, new employees, introduction and review of current procedures for energy isolation, etc.

In addition to the employer's written program, employees will be provided with site-specific participant manuals for building an awareness and understanding of Lockout / Tagout. Non-threatening quizzes are given, not only to measure the employees' knowledge, but also become evidence the Lockout / Tagout Compliance program is in effect at the employer's workplace in the event of an inspection.

OSHA PROCESS SAFETY MANAGEMENT (PSM) - 29 CFR 1910.119

Effective May 26, 1992, the Occupational Safety and Health Administration (OSHA) mandated its Process Safety Management (PSM) standard aimed at protecting millions of employees in the workplace at nearly 100,000 facilities against toxic, flammable, reactive, and explosive chemical hazards "used, stored, manufactured, or transported on-site" in conjunction with processes, machinery, equipment, or activities.

Affected facilities must conduct Process Hazard Analyses (PHAs) of at least 25% of their affected processes by May 26, 1994, and at least an additional 25% of the analyses must be completed each successive year by the annual deadline so that employers will have evaluated every affected process and implemented safety measures within five years of the original effective date in 1992.

Basically, the standard mandates employee participation in PSM programs and sets requirements stemming from 14 elements including:
-written operating procedures - employee training - pre-startup reviews
- equipment maintenance - emergency action plans - compliance audits
- "hot work" permit -written procedures for managing process change
- incident investigation involving releases or near releases of covered chemicals.

OSHA chose the list of 130 Highly Hazardous Chemicals in which coverage is triggered for a facility's compliance if any or all specified Threshold Quantities (TQs) is/are being used in a single process at one point in time (not aggregated over a period of time as in Section 313 of SARA Title III). A "PROCESS" is defined to mean any activity involving a highly hazardous chemical inclusive of any use, storage, manufacturing, or on-site movement. Also included as a single process is any group of vessels that are interconnected and separate vessels which are located such that the chemical could be released.

IMPORTANT NOTE: For optimum and accurate results, this OSHA PSM project should be performed in conjunction with EPA's two compliance requirements under its CLEAN AIR ACT AMENDMENTS (TITLE V AIR OPERATING PERMIT) and under its RISK MANAGEMENT PROGRAM FOR CHEMICAL ACCIDENTAL RELEASE PREVENTION (40 CFR Part 68), as all three programs were planned by federal OSHA and EPA authorities, as well as the U.S. Congress, to be meshed or intertwined for implementation. The PSM project should be initiated under the annual compliance structure in 25% increments by each annual deadline in May, guiding the client to total project completion until the ultimate deadline of 100% compliance on May 26, 1997. A basic assumption is that a Chemical Hazard Analysis has been performed at the client's facility so as to determine which toxic and/or flammable chemicals inventoried at the facility would exceed threshold quantities and, therefore, covered by the standard.

The owner/operator of the facility must understand and assure that PSM applies, not only to his facility's employees, but to contractor and subcontractor employees, except in the case of incidental services, such as janitorial, food and drink, laundry, delivery, or other supply services.

1. NORMAL PROCESS OPERATIONS AND PROJECT PREREQUISITES. OSHA requires the compilation of written process safety information before conducting any Process Hazard Analysis (PHA). This is to enable the employer and employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals. This documentation shall include information pertinent to the hazards of highly hazardous chemicals used or produced by the process, and information pertinent to the equipment in the process.

2. PROCESS HAZARD ANALYSIS. A qualified engineer shall perform a PHA (hazard evaluation) on processes covered by this standard. The PHA must be appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process. The engineer shall determine and document the priority order for conducting PHAs based on the rationale as to the extent of the process hazards, number of potentially affected employees, age of the process, and operating history of the process. The PHA shall be conducted as soon as possible, but no later than the previously mentioned compliance schedule. The engineer shall use one or more of the following methods that are appropriate to determine and evaluate the hazards of the process being analyzed:
- What-if - Checklists - What-if/checklists - Hazard & Operability Study (HAZOP)
- Fault Tree Analysis - Appropriate Equivalent - Failure Mode and Effects Analysis
PHAs must be updated and revalidated at least every five years to assure that it continues to be consistent with the current process. This must be done for the life of the process.

3. PRE-STARTUP SAFETY REVIEW. A pre-startup safety review shall be performed for new or modified facilities whenever the process might influence a change in the process safety information. The review shall confirm that prior to the introduction of highly hazardous chemicals to a process:
- Construction and equipment is in accordance with design specifications;
- Safety, operating, maintenance, and emergency procedures are in place and are adequate;
- A PHA is performed and recommendations must be resolved or implemented before startup;
- Training of each employee involved in operating a process has been completed.

4. MANAGEMENT OF CHANGE. The owner/operator shall establish the implementation of written procedures to manage changes to process chemicals, technology, equipment, and procedures, as well as changes to facilities that would affect a covered process.

5. OPERATING PROCEDURES. The owner/operator shall establish the implementation of written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address the following five elements:
- An 8 step procedure for each operating phase; - Operating limits;
- Safety and health considerations; - Safety systems and their functions;
- Safe Work Practices to provide for the control of hazards during operations such as lockout/tagout, confined space permitting, opening process equipment or piping, entrance control - all of which must apply to employees and contractor employees. Note: Projects requiring work under separate OSHA standards lie outside the scope of this PSM project, but can be implemented as a part of the facility's overall OSHA compliance program.

6. HOT WORK PERMITS. A procedure for securing hot work permits will be developed for any hot work operations conducted on or near a covered process.

7. TECHNOLOGY OF PROCESS. Information concerning the technology of the process shall include at least the following: - Block flow or simplified process flow diagram;
- Process chemistry; - Maximum intended inventory;
- Safe upper and lower limits for such items as temperatures, pressures, flows or compositions;
- Evaluation of the consequences of deviations, including those affecting the safety and health of employees.

8. MAINTENANCE OF PLANT AND EQUIPMENT. A procedure must be maintained and implemented to minimize the possibility of fire, explosion, or any unplanned sudden or non-sudden release of hazardous substance to air, soil, or surface water that could threaten human health or the environment.

9. PROCESS EQUIPMENT. A thorough 8-step procedure should be utilized to provide written information pertaining to the equipment in the process and documentation must be certified by the owner/operator that equipment complies with recognized and generally accepted good engineering practices. Separate from this project in nature and pricing, an additional written procedure can and should be utilized to maintain the on-going mechanical integrity of various process equipment in order to be operated within safe parameters. Inspections and tests shall be performed on process equipment. The owner/operator must correct deficiencies to assure all equipment is suitable for process application. See the synopsis on Mechanical Integrity, as a companion project to PSM, which follows.

MECHANICAL INTEGRITY AS PURSUANT TO PROCESS SAFETY MANAGEMENT
(29 CFR 1910.119)

Pursuant to OSHA's Process Safety Management (PSM) under 29 CFR 1910.119, it is highly probable that a facility may need to engage in a program of Mechanical Integrity (MI) in order to support the efficacy of its ongoing PSM program and related compliance directives from the Federal Government. MI is a companion program to its PSM service, but yet separate in its own scope, objectives, and fee structure. MI can be defined as the ongoing study, maintenance, management, and anticipated replacement of plant equipment - as well as adequacy and fitness for service - (including pressure vessels, tanks, pumps, relief devices, heat exchangers, piping, etc.), as it is used to process, store, or handle a chemical substance at any point in time connected to the process. Understandably, a facility may have one or more processes under the definition above in which PSM and MI are concurrently required. While the above MI definition aligns with PSM regulations, this does not preclude the possibility that the client may wish to engage in some form of MI, even though some of the factors relative to the above regulatory compliance definition may not actually exist to increase reliability. MI changes the maintenance and reliability theme from reactive to proactive. Downtime is decreased and becomes a scheduled event. Scope of repairs is based on condition/risk criteria, not a fix/crisis.

IMPORTANT NOTE: For optimum and accurate results, with an accent on economy of means and expense, PSM should be performed in conjunction with EPA's CLEAN AIR ACT AMENDMENTS (TITLE V AIR OPERATING PERMIT) and the new RISK MANAGEMENT PROGRAM (RMP) FOR CHEMICAL ACCIDENTAL RELEASE PREVENTION (40 CFR Part 68), as all three programs were planned by federal OSHA, EPA, and the U.S. Congress, to be meshed for proper implementation. Emphatically, there is much inter-related compliance activity between PSM & RMP to warrant satisfying both in a dualistic project. The RMP's so-called affected geographical radius can be controlled (reduced) with a comprehensive MI review of equipment.

Since it is OSHA's objective - through the PSM Standard - to prevent a catastrophic event from occurring, it is highly unlikely that an effective PSM program could be initiated and maintained without also being accompanied by an effective ongoing MI program. Process operations, maintenance, management of change, and deterioration / life span are to be monitored, analyzed, documented, and upgraded prior to incidents, accidents, and down-time events. Being that virtually all process machinery and equipment have a finite life, that finite life must not be exceeded, hence the facility should become vulnerable to a catastrophic event, especially where toxic and flammable chemicals may be involved. The repercussions of such events could include the loss of life, serious injury and illness, damage to property, and the release of toxic substances to the environment, as well as the community-at-large and the region downwind from the facility.

SCOPE, STRUCTURE, PROJECT DESCRIPTION OF MI IN TWO INCREMENTAL LEVELS: 1. GENERAL SITE AUDIT; 2. IMPLEMENTATION OF THE MI PROGRAM.
It is only reasonable that a qualified engineer establish the scope and structure of the MI project via an initial site audit, which would better define through written description just what the client's MI program would entail if and when fully implemented. This allows all parties to understand the scope, objectives, and projected expense of the project prior to the client's full commitment. Moreover, the magnitude of the fully implemented MI project may dictate the client's necessity to budget a certain set of hours and monies on an annual basis. Unless regulatory intervention or major process deterioration has occurred, a sensible structure to managing the project over time is essential. Basically, this is a common practice among companies engaged in MI programming. The outline below may assist in understanding the rudiments and flow of a standard schedule of work on the MI program.

I. MI SITE AUDIT AT THE CLIENT'S FACILITY
The site audit is usually accomplished between 3-10 days. Needless to say, such a wide variance of days for the site audit is completely influenced by the size and sophistication of the facility and its processes. The scope of the audit can be easily defined by a simple discussion and walk-through among those parties involved in the audit. The results of the site audit would provide findings in the form of an executive summary with recommendations for the scope of any follow-up work that should be pursued. The executive summary would report on the existing infrastructure and reviews of the required process safety information including P&ID's, equipment inspection records, and basis of design and operation. Site-specific by law, the executive summary will also better define the ongoing MI program with regard to needs, pertinent research within the plant, inspection methods, and appropriate client involvement for the purpose of joint management of the project.

II. SIMPLIFIED OUTLINE STRUCTURE OF THE ONGOING MI PROGRAM
A. Build - Operate - Change - Deterioration.
This is a 4-step approach in which a facility's MI program must be understood. A facility and/or process is built. Over a period of time it is operated (accompanied by written operating procedures). Written procedures are a vital component of the project's objectives. As processes, technology, operations, output, volumes, and objectives change, the MI program properly plans for that change and evolution of the facility's processes. Practically all equipment has a finite life (deterioration being a natural outgrowth of process operations), therefore, that finite lifetime of equipment must not be exceeded.

B. Analysis to determine physical influences, thresholds, and lifetime predictions. Obviously, this is one the major objectives of the project. The results of this analysis allow Sr. management of the client facility to understand and plan accordingly with regard to processes and essential process safety, especially for the sake of employees, contract labor, the environment external to the facility, plus the community/neighborhood in which the facility is located. Another crucial objective is to inform management on predictions of unscheduled downtime of the processes in question. Preventing unscheduled downtime avoids the losses associated with production and work stoppage, equipment repair or replacement, delays in product delivery, customer complaints and dissatisfaction, cash flow deficits, not to mention the potential for the previously mentioned accidents that could easily transpire.

C. Methods of Inspection.
MI engineering staff must make use of all certified and approved API & ASME methods of inspection necessary for yielding findings, results, and supportive documentation pertinent to the facility's MI needs. These methods would include:
- Magnetic Particle Inspection (MT); - Liquid Penetrant (PT);
- Ultrasonic Testing (UT); - Radiographic Inspection / X-ray (RT-1);
- Visual Testing (VT); - Certified Welding Inspection (CWI-AWS)
- Certified pressure Vessel Inspection (Amer. Petroleum Inst., API-510).
The findings of these inspection methods would further assist in determining issues such as design conditions, corrosion, adverse influences, potential for catastrophic events, written operating procedures to prolong the life of the process and protect those individuals operating the equipment, reasonable predictions on remaining lifetime of process equipment, recommendations on replacement timing; and next inspection due.

D. Deliverables.
Sometimes, it is difficult to describe all the service that accompanies a project like MI. However, the consulting and coaching by the performing engineering staff is an essential ingredient of the project's results and success. A teamwork spirit between engineering personnel and other staff must be maintained for optimum success. Along with that coaching comes a complete document book descriptive of the various processes studied, analyzed, graphically depicted, written operating procedures, with best available information on the facility's process for decision-making by the top level of management. Sample documentation excerpts in most cases would include the following.

Relief Device Review - Set Pressure/Capacity
Relief Device Inspection Records
Pressure Vessel Inventory
Pressure Vessel: Basis of Design
Pressure Vessel Calculation Summary
Pressure Vessel Inspection Report
Written Standard Operating Procedures (SOPs)
"As Built" Process & Instrumentation Diagrams
Vessel Inspection - Written Findings

It is important to note that documentation with the above captions in mind would be developed for every pressure vessel, tank, pump, relief device, heat exchanger, and piping for each inspection implemented at the facility.

MATERIAL SAFETY DATA SHEET (MSDS) - DOCUMENT ORIGINATION SERVICE
OSHA 29 CFR 1910.1200

When an organization originates a chemically-oriented product for commerce - liquid, solid, or gas - to be used, stored, processed, manufactured, imported, or resold, the Occupational Safety & Health Administration (OSHA) requires that proper health and safety information - specifically related to the chemical constituents of the product - become documented for hazard communication purposes to all human beings that could become exposed to the hazards therein. This especially applies to those persons exposed to the hazards of the product prior to end-use by the consumer. However, any end-use consumer has the right to know of the hazards contained within a product also and, therefore, may request an MSDS at the time of purchase. The activity of MSDS Origination must be established for those companies originating (creating, producing, etc.) one or more products that require the MSDS document as regulated by OSHA.

OSHA's Hazard Communication Standard of 1987 clearly states that a supplier or manufacturer of an original product - liquid, solid, or gas - must provide a Material Safety Data Sheet with each product upon its initial delivery and then provide an update of the product's MSDS at which time the product undergoes any changes, improvements, or chemical compositional change. Moreover, the law provides that any employer that uses, stores, processes, produces, manufactures, or imports a chemically-oriented product must acquire an MSDS from the product's originator, creator, or supplier so as to make it accessible to all employees at all times in the employer's workplace.

OSHA has allowed for the product originator's potential need for protection of TRADE SECRET AND PROPRIETARY INFORMATION. Any client needing to secure his rights under this protection shall be advised accordingly, with all rights protected under OSHA's guidelines for this clause. The MSDS Document can and will be developed with these rights intact.

Originating MSDSs should include the following important items:

the MSDS currently in use (if available);
trade name;
chemical composition, inclusive of known formula or percentage;
physical property data;
known safety and health hazards associated with the use of the product;
a sample of the product if analytical measurements are deemed necessary;
known data where the product may be harmful to the environment;

It may be necessary to have a product sample(s) tested for the following properties:

specific gravity;
vapor pressure;
boiling point;
flash point;
evaporation rate relative to butyl acetate;
percent volatile.

A qualified, certified lab must be used for all analyticals. The EHS manager or other facility personnel, though, can expedite samples.

3. The MSDS format should be either two-page or four-page, and must conform to the current requirements of the U.S. Department of Labor, OSHA, and the U.S. EPA Superfund Amendments & Reauthorization Act - Title III Supplier Notification. The language on the MSDS must be understandable by the average shop worker and medical terms should be expressed in colloquial terms, whenever possible.

4. A draft copy should be developed for review and acceptance by Sr. Mgt., who in turn, should approve the draft via signature and date it, thus authorizing production of the final document.

INDOOR AIR QUALITY [AIR MONITORING & ANALYSIS OF WORKPLACE ATMOSPHERE FOR EMPLOYEE EXPOSURE TO CHEMICAL HAZARDS & INDOOR AIR CONTAMINANTS]

What are air contaminants? An air contaminant is any substance which is accidentally or unwillingly introduced into the air, having the effect of rendering the indoor atmosphere toxic or harmful to some degree. The greatest concern when dealing with hazardous materials, including their byproducts, fumes, residues, etc., is with air contamination.

Through inhalation, airborne dust, fumes, vapors, mists, smoke, and gases (many of which can be invisible) may all be taken into the body. These particles can then irritate the skin, eyes, nose, throat, and lungs, or they may also be absorbed into the bloodstream and transported to affect other organs.

Airborne contaminants can present a significant threat to worker health and safety. Thus, identification and quantification of these contaminants through air monitoring is an essential component of every company's health and safety program.

[Note: The issue of indoor air quality is a matter relative to Employee Health and Safety as regulated under laws pursuant to the Occupational Safety & Health Administration (OSHA) and should not be mistaken for issues related to environmental air emissions regarding Air Permitting under the auspices of the Environmental Protection Agency and the State of Record.] Reliable measurements of airborne contaminants are useful for:

Selecting personal protective equipment;
Delineating areas where protection is needed;
Assessing the potential health effects of exposure;
Determining the need for specific medical monitoring;
Develop written programs and standard for Employee Training;
Redesign processes for improved elimination of air contaminants to the workplace.

What are PELs and TLVs?
In 1968, based on current, accurate scientific information, air contaminant values were established. The American Conference of Governmental Industrial Hygienists (ACGIH) developed exposure limits called Threshold Limit Values (TLVs). TLV's are unique to this organization. TLVs represent the levels of chemicals in the air that are believed most workers can be exposed to day after day without harm. Permissible Exposure Limits (PELs) are those TLV employee exposure limits of toxic chemicals published by OSHA as legal standards.
Two different types of measurement are used by PELs. Concentration of gases and liquids in the air is measured in parts per million (ppm). Solids or liquids, in the form of mists, dusts, or fumes, are measured in milligrams per cubic meter (mg/m3).

Soon after adoption of the Occupational Safety & Health Act of 1970, OSHA promulgated PELs for approximately 430 substances. The PELs have remained static, nothing changing since the initial list was developed in 1970. The TLV list has been regularly revised whenever scientific evidence determines that a new TLV should be added to the list or an old one adjusted, usually downward. The very first health standards were the 8-hour time-weighted averages (TWA) values of air contaminants from the 1968 research. They now have the force of law. Today there is a total of 547 regulated air contaminants under 29 CFR 1910.1000.

OSHA requires employers to measure contaminants, maintain records, and notify employees of overexposures, and the corrective action planned to be taken for all future health standards. Moreover, it is important that the employer understands the importance of the action level concept. In 1976, OSHA defined the action level as typically one-half the PEL. Where exposures reach or exceed the action level, additional requirements apply, including medical surveillance and a full air-monitoring program. Exposures to an airborne concentration, above the PEL trigger still further requirements, including reduction of exposures to (or below) the PEL by means of engineering controls supplemented by work practice controls, use of specified respirators, and use of other appropriate protective clothing and equipment.

Employee protection. OSHA decided as a policy matter that the action level, which triggers the measurement requirements, be set below the PEL to better protect employees from overexposure. OSHA reasoned that this method was the most reasonable approach to a recurring problem, that is, how to provide the maximum employee protection necessary with the minimum burden to the employer. Thus, where the results of employee exposure measurements demonstrate that no employee is exposed to airborne concentrations of a substance in excess of the action level, employers are exempted from major provisions of the particular standard.

It has been determined, therefore, that three key duties should be triggered when an action level is reached - exposure measurement; medical surveillance, and employee training. OSHA considers all three actions necessary before employee exposure reaches the PEL. It is important to initiate measurement procedures periodically (generally assumed to be annual updating) to monitor whether levels are approaching the PEL. One must do so to ensure that employee exposure does not exceed it. Similarly, employees should be screened for preexisting medical conditions and trained in suitable precautions against dangerous properties of the substance when there is some chance that their exposure will become significant.

Finally, there are no less than 23 substance-specific OSHA standards that must be addressed in the workplace.

POWERED INDUSTRIAL TRUCKS (FORKLIFT TRAINING) - OSHA 29 CFR 1910.178

The Occupational Safety and Health Administration requires very specific operator training with regard to Powered Industrial Trucks (Forklifts) for the safety and welfare of drivers, as well as employees whose work orientation requires they be in the presence of forklift operations. OSHA requires that "only trained and authorized operators shall be permitted to operate a powered industrial truck."

Training shall include topics on:

power sources - locations - safety guards - fuels
trucks / railroad cars - lighting - gases / fumes - batteries
driver knowledge and skills - loading - maintenance - regulations

This regulation and mandated training has proven to save lives, prevent property damage, and prevent accidents and injury involving drivers and other employees in the workplace. Instruction for forklift operations encompasses all proper safety procedures as required in 29 CFR 1910.178.

A qualified trainer must conduct an on-site review to identify current operational procedures, evaluate working order of current powered industrial truck equipment, assess potential safety concerns, and present a site-specific instructional program, inclusive of driver exams. Many states require that drivers undergo rigorous driver testing and be issued a license upon successful completion of the course and driver exam.

Materials for instruction should include the written program, class roster, quizzes, and instructional manual, which provide defensible documentation for compliance in the event of an enforcement inspection.

RESPIRATOR TRAINING - OSHA 29 CFR 1910.134

The Occupational Safety and Health Administration requires very specific training in the proper use of respirators in the workplace as changing conditions and chemically-oriented atmospheres in industrial settings may have an adverse effect on the safety and health of employees. Therefore, Respirator Training becomes an integral part of a company's overall OSHA compliance program.

The Respirator Training program satisfies OSHA's requirements under 29 CFR 1910.134 in the use and fitting of respirator equipment for personal protection against breathing contaminated air due to normal and abnormal causes. Such equipment is typically used as a part of accident cleanup, internal emergency response, confined spaces, and other situations in which hazardous environments may exist. The cost of respirator equipment should be taken into consideration as respirators can be expensive, depending on the style and purpose.

OSHA requires the training to include:

instruction on awareness of OSHA compliance regulations related to the proper use of respirators;
recognition of conditions which would require breathing protection;
the four types of respirator equipment to be used for specific environmental conditions;
proper fitting of respirators specific to each individual;
activities to be performed while using respirator equipment;
written company policy and program site-specific to the use of respirators in the company's facility.

A format of 1 1/2 - 2 hour programming should be utilized to include a multimedia presentation of video, visual aids (overhead transparencies), student manuals, classroom instruction, plus at least 20 minutes "proper fit time" to be spent with each participant. The written program, class roster, and instructional manual provides defensible documentation for compliance in the event of an enforcement inspection.