1 CalARP FormalEvaluation Review Presented By Beronia Beniamine Stanislaus County Senior Hazardous Material Specialist Greg Taylor Foster Farms Corp. PSM Specialist 2 GENERAL CalARP REGUIREMENTS
Process Applicability
Management System
Registration Information
Qualified Person Certification
Recordkeeping
Hazard Assessment
Emergency Response
Program2/3 Requirements
Updates
3 Management System
Does the facility have a CalARP/RMP management system?
Has a qualified person/position been assigned the responsibility for CalARP/RMP compliance?
Can the facility demonstrate that there is not a conflict of interest in their management program e.g. is the person responsible for the programs also responsible for minimizing costs?
4 Registration Information
Are items au section 2740.1 of the CCR identified? Please refer to the Formal Evaluation Checklist it includes all the June 24 2004 changes.
We have handouts with the Formal Evaluation Checklist that you can pick up at the end of our presentation.
5 HAZARD ASSESSMENT
Offsite Consequence Analysis Parameters
WorstCase Release Scenario Analysis
Alternative Release Scenario Analysis
Defining Offsite Impacts to the Population
Defining Offsite Impacts to the Environment
Offsite Consequence Analysis Review and Update
Offsite Consequence Analysis Documentation
FiveYear Accident History
6 Offsite Consequence Analysis
Was the analysis performed by qualified people?
Are the technical assumptions credible?
Was the source of the population estimate data identified?
Was the model used valid for the type of material?
Was the initiating event for the scenario derived from a valid resource? e.g. PHA/HR accident history industry evidence etc.
Does the analysis describe the impacts on local population and the environment?
Will any safeguards claimed withstand the event and still function?
7 Offsite Consequence Analysis
Do the system operators know what will happen if a worst case scenario takes place?
Is the worst case scenario up to date within 5 years or within 6 months of a major change?
Do the system operators know what will happen if an alternative case scenario takes place?
Is the alternative case scenario up to date within 5 years or within 6 months of a major change?
8 No Transcript 9 No Transcript 10 No Transcript 11 No Transcript 12 Emergency Response
Emergency Response Applicability
Emergency Action Plan
Owner or operator whose employees will not respond to accidental releases of regulated substances need to meet the following
Coordinate with community plan
Coordinate with fire agencies for flammables.
Procedures for notifying emergency responders.
13 Emergency Response Program
Emergency response program shall include the following
Emergency Response/Action Plan
Procedures for informing/interfacing w/agencies/public
Documentation of first aid/medical monitoring treatment
Post incident response procedures
Procedures for equipment use inspection testing maintenance.
Training in Incident Command System.
Procedures in place to review and update plan
Coordination w/community emergency response plan.
14 Emergency Response Program
If employees are involved in emergency response does the plan address the following?
Emergency recognition
Safe distances and places of refuge
Site security and control
Are event specific plans e.g. IAP and SSP developed prior to entry into IDLH environments per CCR Title 8 Section 5192 requirements.
Etc
15 No Transcript 16 Sample Site Safety Plan SSP 17 No Transcript 18 No Transcript 19 See Next 20 No Transcript 21 SOPs Refer to Example On Next 22 No Transcript 23 PROGRAM 3 REQUIREMENTS
Executive Summary
Process Safety Information
Process Hazard Analysis
Operating Procedures
Training
Mechanical Integrity
Management of Change
PreStartup Review
24 PROGRAM 3 REQUIREMENTS
Compliance Audits
Incident Investigation
Employee Participation
Hot Work Permit
Contractors
25 What Process Safety Information Is Required?
Block flow diagram or simplified process flow diagram
Process chemistry e.g. M.S.D.S.
Maximum intended inventory
Safe upper / lower limits temp pressures flows compositions etc.
Evaluation of the consequences of deviation from the safe upper / lower limits?
26 What Process Safety Information Is Required? Cont.
Information on equipment used in the process
Materials of construction e.g. ASME certified vessels documented
Piping and instrument diagrams PIDs current accurate?
Electrical classification documented
Relief system design and design basis documented
Ventilation system design documented
Design codes and standards employed to construct the process must be documented
Safety systems e.g. detection documented?
Documented Safe upper / lower limits such as temp pressures flows compositions etc.
27 What Process Safety Information Is Required? Cont.
Documentation showing equipment complies with recognized engineering practices?
Or documentation showing existing equipment is designed maintained inspected tested and operated in safe manner?
Should a Process Hazard Analysis or Hazard Review be accepted if the Process Safety Information was unavailable or inaccurate? 28 What Should the Process Hazard Analysis Address?
Hazards of process
Previous incidents not just reportable releases with the potential for accidents including near misses
Engineering and administrative controls
Consequences of failure of engineering and administrative controls including safe operating limits
Stationary source sitting
Human factors
Qualitative evaluation of health and safety effects of failure of controls
29 What Should the Process Hazard Analysis Address? Cont.
External events?
Were external events such as fires floods earthquakes transportation accidents extreme wind or tornadoes fog and extreme temperatures discussed?
Were external events such as site security related to sabotage terrorism and theft discussed?
Were external events such as site security related to the potential for adjacent facilities or systems to impact the process discussed?
Did the PHA and or Revalidation address procedural steps where appropriate e.g. hot gas defrost cycle on an ammonia evaporator?
Was PHA performed by a knowledgeable team?
30 What Follow Up Is Required for Process Hazard Analysis Recommendations?
Is a system established to promptly address findings and recommendations?
Is there a written schedule of when these actions are to be completed?
Have the recommendations been resolved in a timely manner?
Are the resolutions documented?
Have actions been completed as soon as possible?
Has PHA or Hazard Review been done for major changes or additions to the process?
Has PHA been revalidated at least every 5years?
31 Process Hazard Analysis Recommendation Withdrawal
Employer can justifiably decline to adopt a recommendation where the employer can document in writing and based upon adequate evidence that one or more of the following conditions are true
analysis contains material factual errors
recommendation is not necessary to protect health safety of employees owner and/or contractors
an alternative measure would provide sufficient level of protection or
recommendation is infeasible.
32 Operating Procedures
Initial startup
Normal Operations
Temporary operations
Emergency shutdown
Emergency operations
Normal shutdown
Startup following a turnaround or after emergency shutdown?
Which SOPs reasonably apply to most processes? 33 What Other Operating Procedures Must a Facility Have?
Written operating procedures which address
Deviation from Normal Operating limits
Consequences of deviation
Steps required to correct or avoid deviation?
Regular review/annual certification of operating procedures?
Is a periodic review of written prevention programs such as EAP/ERP MOC PM Program Incident Investigation Contractor Safety Programs done?
34 What Safe Work Practices Should The Facility Have In Place?
Hot Work Permit Program
Lockout/Tagout program
Opening Process Equipment Program i.e. Line Break Permit
Confined Space Permit and Rescue Programs
Medical Surveillance Program respiratory protection program and
HazCom Program.
Written evaluations and training records.
Proper maintenance of emergency response equipment.
35 What Training Is Required?
Is refresher training provided at least every three years and more often if necessary?
Are employees consulted with concerning the frequency and need for refresher training?
Documented training on SOPs maintenance procedures operating limits safety systems hazards emergency procedures safe work practices etc.
Is the same level of training provided to an employee prior to a new job assignment?
Is training provided to contractors who maintain or operate the system or process?
36 What Training Documentation Is Required?
Does training documentation include
Documentation that employee received and understood training
Identity of employee
Date training occurred
Means used to verify employee training e.g. testing observation demonstration etc. comprehension?
37 What Should Be Included In A Mechanical Integrity Program?
Written procedures to maintain the ongoing integrity of ALL process equipment
Planned preventive predictive and proactive but not reactive and corrective maintenance procedures
Training for process maintenance activities
Inspection and testing of process equipment
Prompt correction of equipment deficiencies
Quality assurance e.g. appropriate checks and inspections performed according to manufacturers recommendations suitable spare parts available.
38 What Documentation Should Be Included In The Mechanical Integrity Program?
Is the program documented?
Including the date of each inspection or test
The name of the person who performed the inspection or test
The serial number or other identifier of the equipment on which the inspection or test was performed
A description of the inspection or test performed
The results of the inspection or test and
Actions taken to correct deficiencies.
39 Mechanical Integrity Program
Do the written testing and inspection procedures follow recognized and generally accepted good engineering practices including but not limited to?
Appropriate frequencies for testing and inspection of process equipment e.g. API IIAR NFPA ANSI ASME etc guidelines or manufactures recommendations
Criteria for acceptable test results
Methods to analyze inspection and testing results to assure that equipment deficiencies are corrected when outside acceptable limits.
40 Mechanical Integrity Program Cont.
Is data collected and documented during normal daily walk around including but not limited to?
Liquid levels in all vessels
Inspections of equipment and tasks to be performed such as defrosting evaporators
Instrument readings such and operating conditions e.g. temperature pressure flow level etc. and
System upsets including operating outside normal operating limits and what corrective actions were taken.
41 Mechanical Integrity Program Cont.
Are Equipment Deficiencies discovered during routine maintenance and daily walk around corrected?
The employer shall correct deficiencies in equipment which are outside acceptable limits defined by the process safety information or manufacturers recommendations before further use or in a safe and timely manner provided means are taken to assure safe operations.
42 Management of Change and What Is Considered Change?
Change Any modification which affects the capability of a process to maintain control of the physical and chemical transformations taking place including all modifications to equipment procedures raw materials and processing conditions other than replacementinkind.
For example this list is not to be considered all inclusive
Substitution of a material of construction with a different material. For example a process vessel and/or section of piping is designed with black carbon steel. Replacement of a section of the equipment with stainless steel would constitute a change.
Replacement of a vessel with one of a different pressure rating.
Replacing a gasket with one of a different material.
43 Management of Change and What Should Be Documented?
Is the technical basis for ALL proposed changes such as but not necessarily limited to the reasons for performing the work desired results technical design and appropriate implementation instructions documented including but not limited to?
Changes in process safety information being updated prior to any change?
Changes in operating procedures or practices being updated prior to change being put into service?
Training completed prior to startup of the changed process?
Maintenance routines developed prior to change being put in to service?
44 Compliance Audits and What Should Be Documented?
Are compliance audits conducted at least every 3years?
Are audits conducted by at least one qualified person knowledgeable in the process?
Is a system established to promptly address findings and recommendations?
Is there a written schedule of when these actions are to be completed?
Have the recommendations been resolved in a timely manner?
45 Compliance Audits and What Should Be Documented? Cont.
Are the two most recent audits and audit responses available for review?
Did the audit adequately address previous Compliance Audit PHA and Independent Audit recommendations that have not been corrected or resolved?
Have actions been completed as soon as possible?
Are actions to be taken and their status communicated to employees?
46 Incident Investigations and What Should Be Documented?
Is each incident which resulted in or could reasonably have resulted in a catastrophic release of a highly hazardous chemical including nearmisses and minor releases investigated?
Are nearmisses such as excursion of process operating parameters damaged piping and corrosion investigated?
Are incident report findings and recommendations promptly addressed and resolved?
Did a contractor employee if the incident involved work of a contractor participate in the investigation?
Was a system established to prevent a reoccurrence?
Are incidents reports retained for at least five years?
47 Contractor Safety Program and What Should Be Documented?
Does the program include all contractors who work on or adjacent to covered processs?
Have contract employers safety performance and programs been evaluated and documented?
Is the entrance presence and exit of contractors and contract employees controlled?
Have contract employees been periodically audited?
Been properly trained in and utilizing safe work practices
Know potential fire explosion or toxic release hazards and applicable provisions of the plants emergency action/response plan
48 Contractor Safety Program and What Should Be Documented?
Contractor notified of fire explosion and release hazards at facility?
Contractor performance periodically evaluated?
Contractor provided training for their employees?
Contractor informs their employees of the hazards and emergency response plan at the facility?
Contractor advised facility of hazards presented by contract work?
Contractor advised facility of any hazards found?
Contractor assured facility that employees followed its safety rules?
49 CalARP/RMP Program Updates
Within five years of its initial submission or most recent update whichever is later.
No later than three years after a newly regulated substance is first listed by USEPA or OES.
No later than the date on which a new regulated substance is first present in an already covered process.
No later than the date on which a regulated substance is first present above a threshold quantity in a new process.
Within 30 days of change in emergency contact information.
Within 6 months of a reportable release.
50 CalARP/RMP Program Updates Cont.
Within 6 months of a change that requires a revised PHA or hazard review
Within 6 months of a change that requires a revised offsite consequence analysis.
Within 6 months of a change that alters the Program level that applies to any covered process.
Within 6 months of a change that alters the Program level that applies to any covered process.
What are some examples of changes that would require a revised Process Hazard Analysis or Offsite Consequence Analysis?