Blank PSM & RMP Audit Form

Process Safety Management and Risk Management Compliance Audit

1

Company: Facilility: Audit Date: Leader/Secretary: Team Members:

Questions Comments/Findings/Recommendations

Does a written program exist regarding employee participation?

(c)(1)

(c)(2)

(c)(2)

(c)(3)

N/A

5. Interviews

.119(c)(1)

Employee Participation

29 CFR 1910.119 Reference

Full Compliance

1. Records Review

2. Records Review

Does the plan include consultation with employees and their representatives on the conduct and development of process hazards analyses?

3. Records Review

Does the plan include consultation with employees and their representatives on the development and implementation of other elements of the PSM standard?

4. Records Review

Have employees (including contractor employees) and their representatives been provided access to process hazard analyses and other information required by the PSM Standard?

On-site Conditions

Based on interviews with a representative number of employees and their representatitives, have they been consulted on the conduct and development of the process hazard analyses? Criteria Reference .119


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Questions Comments/Findings/RecommendationsEmployee

Participation29 CFR 1910.119

ReferenceFull

Compliance

6. Interviews

.119 (c) (2)

7. Interviews

.119 (c) (3)

8. Appendix B

(CPL)

Based on interviews with a representative number of employees and their representatives, have they been consulted on the development of other elements?

Based on interviews with a representative number of employees (including contractor employees) and their representatives, have they been informed of their rights of access and provided access to process hazard analyses and to all other information required to be developed by the PSM Standard? (Ask about unreasonable delays in access to information and whether time is given during the working hours to access information required by the PSM Standard.)

Has the employer consulted with contractors to the same extent that they consult with direct hire employees if the contractor employees fulfill one of the following roles: Process operator; routine periodic preventive maintenance; has a role in the MOC program, has a role in approving HWPs; has unique process knowledge, routinely interfaces with the facility's safe work place?


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1. Records Review (d)

2. Records Review (d)(1)(i-vii)

3. Records Review Does it include toxicity information? (d) (1) (i)

4. Records Review Does it include permissible exposure limits? (d) (1) (ii)

5. Records Review Does it include physical data? (d) (1) (iii)

6. Records Review Does it include reactivity data? (d) (1) (iv)

Process Safety Information


Full Compliance

Has written process safety information been complied prior to conducting any process hazard analyses?

Does it include information pertaining to the hazards of highly hazardous chemicals used or produced by the process? I-vi


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Questions Comments/Findings/RecommendationsProcess Safety

Information29 CFR 1910.119

ReferenceFull

Compliance

7. Records Review Does it include corrosivity data? (d) (1) (v)

8. Records Review Does it include thermal and chemical stability data? (d) (1) (vi)

9. Records Review (d)(1) (vii)

10. Records Review Does it include information pertaining to the technology of the process? (d) (2) (i) (A-E)

11. Records Review Does it include block flow diagrams or simplified PFD? (d)(2)(i)(A)

12. Records Review Does it include process chemistry? (d) (2) (i) (B)

Does it include hazardous effects of inadvertent mixing of different materials that could foreseeably occur? Note: MSDSs meeting the requirements of 29 CFR 1910.1200 (g) may be used to the extent they contain the information required.


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ReferenceFull

Compliance

13. Records Review Does it include maximum intended inventory? (d) (2) (i) (C)

14. Records Review Does it include safe upper and lower limits for key process parameters? (d) (2) (i) (D)

15. Records Review (d) (2) (i) (E)

16. Records Review Does it include information pertaining to the equipment in the process? (d) (3) (i) (A-H)

17. Records Review Does it include materials of construction ? (d) (3)(i) (A)

18. Records Review Does it include P&Ids? (d) (3) (i) (B)

Does it include evaluation of the consequences of deviations? (Where the original technical information no longer exists, it may be developed in conjunction with the PHA)


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ReferenceFull

Compliance

19. Records Review Does it include electrical classifications? (d) (3) (i) (C)

20. Records Review Does it include relief system design and design basis? (d) (3) (i) (D)

21. Records Review Does it include ventilation system design? (d) (3) (i) (E)

22. Records Review Does it include design codes and standards employed? (d) (3) (i) (F)

23. Records Review Does it include materials and energy balances [progresses built after 5-26-92] (d) (3) (i) (G)

24. Records Review Does it include safety systems? (d) (3) (i) (H)


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ReferenceFull

Compliance

25. Records Review (d) (3) (ii)

26. Records Review (d)(3)(ii)

.119(d)

.119 (d) (3) (ii)

.119 (d)(3)(iii)

30. Interviews .119(d)

Has the employer documented that equipment complies with recognized and generally accepted good engineering practice, codes and standards? (Review the documentation for evidence that compliance with the appropriate consensus standards has been researched.)

Has the employer determined and documented that where equipment has been designed and constructed in accordance with codes, standards, designed, maintained, inspected, tested, and operated in a safe manner? (Documentation may be through methods such as; documenting successful prior operation procedures; documenting that the equipment is consistent with the appropriate editions of codes and standards; or performing an engineering analysis to determine that the equipment is appropriate for its intended use.)

27. On-Site Conditions

Do observations of a representative sample of process chemicals and equipment indicate that the process information is complete (Information that does not correspond to the actual conditions demonstrates incomplete information. Check critical equipment and components to see if they have been identified.)


Do observations of a representative sample of process components indicate that the process complies with recognized and generally accepted good engineering practice? (Review a representative number of safety devices such as pressure relief devices for proper sizing according to the maximum anticipated pressure.)


Do observations of a representative sample of the existing equipment designed and constructed according to codes, standards, or practices no longer in general use indicate that this equipment is inspected and is operated in a safe manner (as documented by the employer)?

Process Hazard Analysis (PHA) Team: Based in interviews with a representative number of members, was the process safety information complete before the process hazard analysis was conducted?


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ReferenceFull

Compliance

31. Interviews 0.1200

32. Interviews .119 (d) (3) (ii)

Is the up-to-date PSI kept for lifetime of the process? (CPL)

(CPL)

Operators: Based on interviews with a representative number of operators is MSDS Information readily available to the operators who work with hazardous materials? Criteria Reference .1200

Engineers (If any ;or other qualified persons capable of providing information requested; Based on the interviews with a representative number of engineers, has the employer documented that the process equipment complies with recognized and generally accepted good engineering practice? (Ask about the technical bases for design and selection of equipment, the materials of construction, electrical classifications, relief devices sizing verus maximum anticipated pressures, installation procedures to assure equipment meets design specifications, etc)

33. Appendix B (CPL)


If used equipment has been employed in the process, has its suitability for the intended service been confirmed by engineering records supplied with the equipment from its previous owner's engineering work by the employer, or testing by the employer?


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Questions 29 CFR 1910.119 Reference Comments/Findings/Recommendations

1. Records Review Have all the initial process hazard analyses been completed? (e) (1) (iv)

2. Records Review (e)(1) (v)

3. Records Review Is an acceptable methodology being used for process hazard analysis? (e) (2)

4. Records Review Does the Process Hazard Analysis address the hazards of the process? (e) (3) (1)

5. Records Review (e) (3) (ii)

6. Records Review Does the process Hazard Analysis address actual incidents resulting in a release of a covered material? (e)(3) (ii)

Process Hazard Analysis

Full Compliance

Do PHAs conducted after 5/26/87, that are being used as initial PHAs, meet the requirements of the standard?

Does the process Hazard Analysis address the identification of any previous incidents which had likely potential for catastrophic consequences?


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Questions 29 CFR 1910.119 Reference Comments/Findings/RecommendationsProcess Hazard Analysis

Full Compliance

7. Records Review (e) (3) (iii)

8. Records Review Does the Process Hazard Analysis address hardware (detection, prevention, mitigation)? (e)(3)(iii)

9. Records Review (e) (30 (iii)

(e)(3)(iv)

Does the process Hazard Analysis address facility siting? (e) (3) (v)

Does the process Hazard Analysis address human factors? (e) (3) (v)

Does the Process Hazard Analysis address engineering and administrative controls applicable to the hazards?

Does the Process Hazard Analysis address administrative procedures (e-g; preventive maintenance, when performed on time, inventory reduction, etc.)?

10. Records Review

Does the Process Hazard Analysis address consequences of Failure of Engineering and Administrative Controls?

11. Records Review

12. Records Review


11


Full Compliance

(e) (3) (vii)

Is the process hazards analysis team staffed with the proper personnel? (e) (4)

Does the team have expertise in engineering and process operations? (e) (4)

(e) (4)

Is at least one team member knowledgeable in the specific PHA technique being used? (e) (4)

Is a system in place to promptly address the team's findings and recommendations? (e) (5)

13. Records Review

Does the process Hazard Analysis address qualitative evaluation of a range of possible safety and health effects of failure of controls on employees in the workplace. (i.e. A risk ranking scheme, or equivalent)?

14. Recoreds Review

15. Records Review

16. Records Review

Does at least one team member have experience and knowledge specific to the process being evaluated?

17. Records Review

18. Records Review


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Full Compliance

Are resolutions and their rationale documented? (e)(5)

(e) (5)

Is a written schedule prepared for when actions will be completed? (e) (5)

(e) (6)

Has the PHA been revalidated in the last 5 years? (e) (6)

(e) (6)

19. Records Review

20. Records Review

Are resolutions communicated to the PHA team and any subsequent recommendations of the team expeditiously resolved?

21. Records Review

22. Records Review

Does the facility have a system in place to update and revalidate process hazard analyses within 5 years of the initial PHA, including grandfathered studies?

23. Records Review

24. Records Review

Have revalidated PHAs been performed by a team meeting the same qualifications as the initial PHAs?


13


Full Compliance

Does the revalidated PHAs reflect the current design and operation of the process? (e) (6)

Are PHA records being kept for the life of the process? (e) (7)

Are all the originals kept for the life of the process? (e) (7)

Are PHA documenaton, study worksheets, and reports kept for the life of the process? (e) (7)

Are documentation on recommendations and action items kept for the life of the process? (e) (7)

(e) (1)

25. Records Review

26. Records Review

27. Records Review

28. Records Review

29. Records Review


Do observations of a representative sample of process-related equipment indicate that obvious hazards have been identified, evaluated, and controlled? (For example , hydrocarbon or toxic gas monitors and alarms are present; electrical classifications are consistent with flammability hazards; destruct systems such as flares are in place and operating ; controls room sitting is adequate or provisions have been made for blast resistant construction , pressurization,alarms, etc; pressure relief valves and rupture disks are properly designed and discharge to a safe area; pipework is protected from impact; etc.)


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Full Compliance

.119 (e) (5)

32. Interviews .119 (e) (1)






Do observations of a representative sample of process-related equipment indicate that the PHA recommendations have promptly resolved ?

Based on interviews with a representative number of the PHA methodologies used appropriate for the complexity of the process?

Based on interviews with a representative number of the PHA team members, is the priority order for conducting PHAs based on the extent of the process, the number of potentially affected employees, the age of the process, and the operating history of the process?

Based on interviews with a representative number of the PHA team members, have the hazards of the process been addressed?

Based on interviews with a representative number of the PHA team members have previous incidents with likely potential for catastriohic consequences been addressed?

Based on interviews with a representative number of the PHA team members have the engineering and administrative controls applicable to the hazards been addressed?


15


Full Compliance


38. Interviews ..119(e)(3)





Based on interviews with a representative number of the PHA team members have the consequences of control failures been addressed?

Based on interviews with a representative number of the PHA team members have the facility sitting been addressed?

Based on interviews with a representative number of the PHA team members have the human factors been addressed?(Ask about shift rotations, extended schedules, and other possible sources of error.)

Based on interviews with a representative number of the PHA team members has a qualitative evaluation of a range of possible safety and health effects of failure of controls on employees in the workplace been addressed?

Based on interviews with a representative number of the PHA team members, do the members have the appropriate expertise in engineering, process operations, and the process methodology used? Does one member of the team have experience and knowledge in the specific process?

Based on interviews with a represeentative number of the PHA team members, does the system established by the employer address the team's findings and recommendations promptly?


16


Full Compliance



Does the Process Hazard Analysis address location of ignition sources? (CPL)

Does the Process Hazard Analysis address types of construction in the room? (CPL)

Does the Process Hazard Analysis address fire protection facilities? (CPL)

Does the Process Hazard Analysis address capabilites to respond to explosions? (CPL)

Based on interviews with a representative number of operator and maintenance employees have the PHAs addressed the recognized hazards of the process and previous incidents which had a likely potential for catastrophic consequences?

Based on interviews with operator, maintenance, and other employees who may be affected by PHA recommendations, have actions taken to resolve PHA findings been communicated in these employees ?






17


Full Compliance

Does the Process Hazard Analysis address drainage facilities? (CPL)

Does the Process Hazard Analysis address location of fresh air intakes? (CPL)

Does the Process Hazard Analysis address human errors indentified as causes of hazard scenarios? (CPL)

Does the Process Hazard Analysis address environmental influences on employees? (CPL)

Does the Process Hazard Analysis address clarity of procedures? (CPL)

Does the Process Hazard Analysis address design of equipment? (CPL)








18


Full Compliance

Does the Process Hazard Analysis address accessibility of controls? (CPL)

Does the Process Hazard Analysis address readability of displays? (CPL)

(CPL)

Does the Process Hazard Analysis address clarity of signs? (CPL)

Is it appropriate to the complexity of the process? (CPL)

Does the Process Hazard Analysis address task underload/overload and frequency? (CPL)




Does the Process Hazard Analysis address clarity and simplicity of displays/operator-to-equipment interface?





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Full Compliance

Does the Process Hazard Analysis address extended or unusual work schedules? (CPL)

Does the Process Hazard Analysis address instrumentation verus manual procedures? (CPL)

Does the Process Hazard Analysis address operator feedback? (CPL)





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Operating Procedures Questions Full Compliance Comments/Findings/Recommendations

1. Records Review (f)(1)

2. Records Review (f) (1)

3. Records Review (f) (1) (1)

4. Records Review (f) (1)(l)(B)

5. Records Review (ff) (1) (l) (C)

6. Records Review (f) (1) (l) (D)


Does the SOPs provide clear instructions for safely conducting all of the required tasks in each process- are they complete(e.g., do the SOPs cover require sampling operations)?

Are the written SOPs implemented in the unit to which they apply (i.e., are they official operating documents, and are they available to the operating staff?

Do the SOPs address the operating phase of the process for((f) (1)(l) (A-G) initial start-up? (e.g., preparation of process lines, instruments, and utlities, any required pre-startup equipment tests, dryout of equipment, inerting/purging of equipment or lines, intital valve positions, warm-up phase, steps to place the process onstream.)

Do the SOPs address operating phases of the normal operations of the process? (e.g., steady-state conditions, means and steps to detect out-of-spec conditions, steps to make necessary adjustment.)

Do the SOPs address the operating phases of the temporary operations? (e.g., holding periods, safety features bypass, reduced, rates/capacity temporary loss of DCS, temporary loss of DCS, temporary loss of utilities, sampling, purging/inerting)

Do the SOPs address the operating phases of the emergency shut-down including the conditions under which emergency shut-down is required, and the assignment of shut-down responsibility to qualified operators to ensure that emergency shut-down is executed in a safe and timely manner?(e.g., actuation of emergency shut-down steps, assignment of responsibilities for emergency shut-down steps.)


21

Operating Procedures Questions Full Compliance Comments/Findings/Recommendations29 CFR 1910.119

Reference

7. Records Review (f) (1) (l) (E)

8. Records Review (f) (1) (l) (F)

9. Records Review (f) (1) (l) (G)

10. Records Review (f) (1) (ii)(A-B)


12. Records Review Do the SOPs address the information about operating limits for the consequences of deviations? (f) (1) (II)(A)

Do the SOPs address the operating phases of the emergency operations? (e.g., control of emergency conditions, safe upper or lower limits are exceeded, start-up following emergency shut-down.)

Do the SOPs address the operating phases of the normal shut-down? (e.g., steps to conduct controlled shut-down, cooldown requirements, removing excess inventories)

Do the SOPs address the operating phases of the start-up following a turnaround or after an emergency shut-down? (e.g., shut-down during the change of shift)

Do the SOPs address the information about operating limits for the identification of critical operating parameters?

Do the SOPs address the information about operating limits for the ranges and limits for operating parameters for different operating modes?


22


Reference


14. Records Review Are steps required to correct or avoid a deviation? (f) (1) (ii) (B)

15. Records Review (f) (1) (iii) (A)

16. Records Review (f)(1) (iii) (B)

17. Records Review (f) (1) (iii) (C)

18. Records Review (f) (1) (iii) (d)

Do the SOPs address the information about operating limits for the separate ranges and limits for design (i.e., safety) and operability (e.g., product quality)?

Do the SOPs address the safety and health considerations for properties of and hazards presented by the chemicals used in the process?

Do the SOPs address the safety and health considerations for precautions necessary to prevent exposure, including engineering controls, administrative controls and personal protective equipment?

D0 the SOPs address the safety and health considerations for control measures to be taken if physical contact or airborne exposure occurs?

Do the SOPs address the safety and health considerations for quality control for raw materials and control of hazardous chemical inventories?


23


Reference

19. Records Review (f) (1) (iii) (E)

20. Records Review Do the SOPs address safety systems and their functions? (f) (1) (iv)



23. Records Review Are reviews and updates certified as conducted at least annually? (f) (3)

24. Records Review (f)(4)

Do the SOPs address the safety and health considerations for any special or unique hazards?(e.g. runaway reactions, particial or incomplete reactions , overcharge, out-of -sequence charge, spontaneous combustion of materials at ambient conditions, etc.)

Are the SOPs readily accessible to employees who work in or maintain the process-- are the SOP manuals located in key locations?

Are the SOPs reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities?

Is there a program (permit system ) in place to develop and implement written safe practices and procedures for lockout/tagout?


24


Reference




28. Records Review Are contractors subject to the safe work practices? (f) (4)

.119 (f) (1)

.119 (f) (2)

Is there a program ( permit system) in place to develop and implement written safe work practices and procedure for confined space entry?

Is there a program (permit system) in place to develop and implement written safe work practices and procedure for opening process equipment or piping?

Is there a program (permit system) in place to developed and implement written safe work practices and procedure for control over entry into a process by maintenance, contractor, laboratory or other support personnel?


Does observation of a representative sample of processes indicate that the written operating procedures are being implemented?


Does observation of a representative sample processes indicate that the written procedures are readily accessible to employees who work or maintain a process?


25


Reference

.119 (f) (3)

.119(f) (4)

Do such work practices include, where appropriate lockout/tagout? .119(f) (4)

Do such work practices include where appropriate confined space entry? ..119 (f) (4)

Do such work practices include, where appropriate opening process equipment or piping? .119 (f) (4)

.119 (f) (4)


Does observation of a representative sample of processes indicate that operating procedures reflect current practice, including changes that result from process chemicals, technology, equipment, and facilities? (Observe to see if actual procedures match the written operating procedures.)


Does observation of representatives operations indicate that safe work practices have been implemented for company and contractor employees?





Do such work practices include, where appropriate control over entrance into a facility by maintenance, contractor,laboratory, and other support personnel?


26


Reference

37. Interviews .119(f) (1)



40. Interviews .119 (f) (3)

41. Appendix B (CPL) (CPL)


Based on interviews with a representative number of operators, are the written operating procedures implemented for each covered process?

Based on interviews with a representative number of operators, do operating procedures provide clear instructions for safely conducting activities? (specifically ask for conditions requiring emergency shut-down, the operating limits of a particular process or item of equipment, what might occur if a deviation from those limits should take place, steps to avoid the deviation, and precautions necessary to prevent exposure to hazardous chemicals.)

Based on interviews with a representative number of employees who work in or maintain a process, are the operating procedures readily accessible?

Based on interviews with a representative number of operators and maintenance employees, do the operating procedures reflect current operating practice?

Are the SOPs written? (i.e., written text documents, and not merely the graphical system mimic displays on a DCS)

Do the written SOPs reflect actual, current operating practice, or are operations conducted with unofficial or ad-hoc procedures


27


Reference

43. Appendix B (CPL) Are the SOPs consistent with the PSI? (CPL)


28


Training Questions Comments/Findings/Recommendations

1. Records Review Has the operations staff received initial training? (g) (1) (i)

2. Records Review (g) (1) (i)

3. Records Review (g) (1) (i)

4. Records Review Was initial training on existing procedures completed by May 26, 1992? (g)(1) (ii)

5. Records Review (g) (1) (ii)

6. Records Review Did the training cover/include emergency operations including shut-down? (g) (1) ( l)


Full Compliance

Have all operators, managers and supervisors and others who currently have duties involving actual operations of a covered process received initial training?

Have all operators, managers and supervisors and others received initial training prior to being newly assigned to a covered process?

Has the grandfather training certification system/document been prepared for those operators that were involved in operating a process prior to May 26, 1992 and whose qualifications are considered grandfathered?


29

Training Questions Comments/Findings/Recommendations29 CFR 1910.119

ReferenceFull

Compliance

7. Records Review Did the training cover/include safe work practices applicable to the employee's job tasks? ((g) (1) (l)

8. Records Review Have the operators received refresher training at least every three years? (g) (2)

9. Records Reviw Have the operators been consulted regarding the frequency of the refresher training? (g) (2)

10. Records Review .119 (g) (2)

11. Records Review (g) (3)

12. Records Review (g) (3)

Has the employer consulted with employees and contractor employees involved in operating the process to determine the appropriate frequency for refresher training? Is the frequency at least once every 3 years?

Did the employer ascertain that each employee involved in operating a process received and understood the training?

Is there a process in effect to document initial and refresher training of all operators (i. E., training records)?


30


ReferenceFull

Compliance

13. Records Review Is the identity of employees receiving training documented? (g) ( 3)

14. Records Review Is the date of each training activity documented? (g) (3)

15. Records Review Is the means used to ascertain that employees understand the training documented? (g) (3)

On-Site Conditions N/A

16. Interviews .119 (g) (1) (l)

17. Interviews .119(g) (2)

Based on interviews with a representative number of employees, has their training emphasized specific safety and health hazards, emergency operations including shut-down, and safe work practices applicable to their tasks?

Based on interviews with employees named as having provided consolation, has the employer consulted with employees involved in operating the process to determine the appropriate frequency of refresher training?


31


ReferenceFull

Compliance

Do the grandfather documents describe the rationale for granting the grandfathered qualifications? (CPL)

(CPL)

Did the training cover/include an overview of the process? (e.g., safety systems and their functions) (CPL)

(g) (1) (l) (CPL)

(g) (1) (l) (CPL)

Is refresher training provided within three years of the date of last training or grandfathered date? (CPL)



Have veteran employees been grandfathered for each position for which they were qualified on May 26, 1992-- are granndfathered qualifications still valid for all positions worked by each operator on a covered process?



Did the training cover/include operating procedures? (e.g., steps for each operating phase ,initial start-up, normal operations, temporary operations, emergency shut-down, emergency operations, normal shut-down, and start-up following a turnaround or emergency shut-down, operating limits, consequences of deviations, and steps required to avoid deviations)


Did the training cover/include emphasis on the specific safety and health hazards? (e.g., properties and hazards of chemicals used and precautions for preventing exposure)



32


ReferenceFull

Compliance

(CPL)24. Appendix B (CPL)

Is the refresher training separate from any training received as part of the management of change or pre-startup safety review programs?


33


Contractors Questions Full Compliance Comments/Findings/Recommendations

(h) (1)

(h) (1)

(h) ( 1)

Are contractors performing turnaround work on or adjacent to a covered process incluled? (h) (1)

Are contractors performing major renovation work on or adjacent to a covered process included? (h) (1)

Are contractors performing specialty work on or adjacent to a covered process included? (h) (1)


1. Records Review: General Requirements

Has the employer applied this paragraph accurately to all contractor activities at the site (i.e. are the host employers decisions regarding applicability of this paragraph to various vendors correct)?


Are contractors performing preventive maintenance work on a adjacent to covered process included?


Are contractors performing corrective mainentence (repair) work on or adjacent to a covered process included?





34

Contractors Questions Full Compliance Comments/Findings/Recommendations29 CFR 1910.119

Reference

(h) (2) (l)

(h) (2)(ii)

(h) (2) (ii-iii)

(h) (2) ii-iii)

(h) (2) ii-iii)

(H) (2) II-iii)

7. Records Review: Host Employer Responsibilities

Has information been obtained and evaluated regarding the contract employer's safety program and performance and has it been used when selecting a contractor?


Are contractor employers informed prior to the initation of the contractor's work at the site, of the known potential fire, explosion, or toxic release hazards related to the contractor's work and the process?


Are contractor employers informed, prior to the initiation of the contractor's work at the site, of the applicable provisions of the emergency action plan?


Are contractors employers informed prior to the initiation of the contractor's work at the site, of the site's safe work practice procedures?


Are contractor employers informed prior to the initiation of the contractor's work at the site, of other site work rules applicable to the contractor's work?


Are contractor employers informed prior to the initiation of the contractor's work at the site, of the methods of reporting contractor-discovered hazards to the host employer's organization?


35


Reference

(h) (2) (iv)

(h) (2) (iv)

(h) (2) (vi)

(h) (3) (l)

(h) (3) (ii)

(h) (3)(ii)


Is there a safe work practice (permit) program that controls the access, presence, and agress of contract employees to process units?


Are contractors required to report their entry and egress by notation in a log, electronic passcard, or some equivalent method?


Is there a program in effect to periodically evaluate the contractor employer's responsibilities under the PSM Standard?


Does the evaluation check that the contractor has provided its employees with training in safe work practices?


Does the evaluation check that the contractor has provided its employees with training on hazards they will face at the worksites they service, and in particular the host employer's worksite hazards?


Does the evaluation check that the contractor has provided its employees with training in applicable provisions of the emergency action plans that they might have to comply with at the worksites they service and in particular the host employers emergency response plan provisions?


36


Reference

(h) (3) (iii)

(h) (3) (iv)

(h) (3) (v)

Does the facility maintain a contractor employee injury and illness data? (h) (2) (vii)

(h) (3) (l)

(h) (3) (ii)


Does the evaluation check that the contractor maintains training records for each employee that include, at a minimum, the name of the contractor employee, the date of the training, and the means used to verify that the contractor employee understand the training?


Does the evaluation check the contractors safety performance in the field on a periodic basis to ensure that their employees follow safety rules and work practices?


Does the evaluation check that the contractor advises employer of unique hazards that they find when performing their work?


23. Records Review: Contract Employer Responsibilities

Does the contact employer assure that each contract employee is trained in the work practices necessary to safely perform his/her job? (i.e., the job skills that they will need to perform the services that they are hired to provide)


Does the contract employer assure that each contract employee is instructed in the known potential fire, explosion, or toxics release hazards related to his/her job and the covered process, and in the applicable provisions of the emergency action plan for the worksites where they normally provide services?


37


Reference

(h) (3) (iii)

(h) (3) (iv)

(h)(3) (v)

28. On-Site Conditions (.119) (h) (2) (iv)

29. On-Site Conditions .119 (h) (3) (iv)

30. Interviews


Is a training record prepared that contains the identify of the contract employee, the date of the training, and the means used to verify that the contract employee understood the training?


Does the contract employer assure that each contract employee follows the safety rules of the facility, including the safe work practices required by the PSM Standard?


Does the contract employer advise the employer of any unique hazards presented by the contract employer's work, or of any hazards found by the contract employer's work?

Based on a representative sample of observations of contractor employees, has the employer's program to control their entrance, presence, and exit been implemented?

Based on a representative sample of observations of contractor employees, do they follow the safety rules of the facility? (these rules include the employer's safe work practices such as lockout/tagout ,confined space entry, and opening process equipment or piping; they may also include other rules such as excavation procedures or use of PPE.)

Based on interviews with contractor employers, did the host employer obtain and evaluate information regarding the contractor's safety performance and programs for selection of contractors?

.119 (h) (2) (l) Appendices C and D


38


Reference

31. Interviews .119 (h) (2) (ii)

32. Interviews .119 (h) (2) (iii)

33. Interviews .119 (h) (2) (iv)

34. Interviews .119 (h) (2) (v)

35. Interviews .119 (h) (3)


Based on interviews with contractor employers, have they been informed of the known fire, explosion, or toxic release to their work and the processes in which they are involved prior to the initiation of their work at the site?

Based on interviews with contractor employers, have they been informed of the applicable provisions of the employer's emergency action plan prior to the initation of their work at the site?

Based on interviews with contractor employers and employees, have work practices to control their entrance, presence, and exit of covered process areas been implemented?

Based on interviews with the contractor employer, has the employer periodically evaluated the contractor's performance in fulfilling the obligations required in .119 (h) (3) to assure their employees are trained in safe work practices needed to perform the job?

Based on interviews with the contractor employer, has the employer periodically evaluated the contractor's performance in fulfilling the obligations required in .119 (h) (3) to assure their employees are instructed in the known potential fire, explosion, or toxic release hazards related to the job and the applicable provisions of the emergency action plan?

Based on interviews with the contractor employer, has the employer periodically evaluated the contractor's performance in fulfilling the obligations required in .119 (h) (3) to document the required training and the means to verify their employees have understood the training?


39


Reference



39. Interviews .119 (h) (2) (v)

40. Interviews .119(h) (2) (v)

41. Interviews .119 (h) (3) (l)

42. Interviews .119 (h) (3) (ii)

Based on interviews with the contractor employer, has the employer periodically evaluated the contractor's performance in fulfilling the obligations required in .119(h) (3) to assure their employees follow the facility safety rules and practices?

Based on interviews with the contractor employer, has the employer periodically evaluated the contractor's performance in fulfilling the obligations required in .119 (h) (3) to advise the employer of unique hazards presented by the contractor's work?

Based on interviews with the contractors employer, has the host employer ensured, through periodic evaluations, that the training provided to contractor employees by the contractor employer is equivalent to the training required for direct hire employees?

Based on interviews with the contractor employers, if the employer has identifed deficiencies in the performance of contract employers, what action has the employer taken to correct the deficiencies?

Based on interviews with a representative number of contractor employees, has the contractor employer trained them in the work practices necessary to perform their jobs?

Based on interviews with a representative number of contractor employees, are they being instructed the known potential fire, explosion, or toxic release hazards related to their work and the processes in which they are involved?


40


Reference

43. Interviews .119 (h) (3) ( ii)

44. Interviews .119 (h) (3) (iv)

(CPL)

Has the host employer and the contractor applied this paragraph to subcontractors? (CPL)

(CPL)

(CPL)

Based on the interviews with a representative number of contractor employees, have they been instructed in the applicable provisions of the emergency action plan? (Ask them to explain the plan and evacuation procedures.)

Based on interviews with a representative number of contractors employees, has the contract employer assured that they follow the safety rules of the facility? (Ask how safe work practices, entry restrictions for the facility, and use of required PPE are enforced.)

45. Appendix B (CPL): General Requirements

Are other contractors performing work on adjacent to covered process that have the potential for affecting process safety included? (e.g., contractors performing construction, demolition, equipment installation)



If contract employees are involved in operating a process or maintaining the on-going integrity of process equipment, do they receive training in accordance with the specific training requirements set forth in the training and mechanical integrity elements? (either directly from the contractor employer or from host employers that they service)

48. Appendix B (CPL): Host Employer Responsibilities

Has the host employer provided training to contractor employees which is equivalent to the training provided to direct hire employees who perform the same roles?


41



1. Records Review (l) (1)


3. Records Review Is a PSSR performed prior to the introduction of the highly hazardous chemical to the process? (l) (2)

4. Records Review Do the PSSRs confirm that construction and equipment is in accordance with design specifications? (l) (2) (l)

5. Records Review (l) (2) (ii)

6. Records Review (1) (2) (iii)

Pre-Startup Safety Review


Full Compliance

Are PSSRs being performed for new covered processes? (i.e., physically separated from existing processes, or a facility at a site where there were none before)

Are PSSRs being performed at a minimum, when changes occur in existing covered processes that result in a change to the process safety information?

Do the PSSRs confirm that safety, operating, maintenance, and emergency procedures are in place and are adequate?

Do the PSSRs for new facilities, confirm that PHAs have been performed and recommendations have been resolved or implemented before start-up?


42

Questions Comments/Findings/RecommendationsPre-Startup Safety

Review29 CFR 1910.119

ReferenceFull

Compliance

7. Records Review (l) (2) (iii)

8. Records Review Do the PSSRs confirm that operator training has been completed? (l) (2) (iv)

9. On-Site Conditiond

10. Interviews .119 (l) (2) (l)

11. Interviews .119 (l) (2) (ii)

12. Interviews .119 (l) (2) (ii)

Do the PSSRS, for modified facilities confirm that the process meets the requirements contained in the management of change program?

Do Observations of new or modified facilities indicate that prior to the introduction of highly hazardous chemicals that construction and equipment is in accordance with design specifications? Safety, operating, maintenance, and emergency procedures are in place and adequate.

Based on interviews with a representative sample of operators, maintenance employees, and engineers, can it be confirmed that the construction and equipment are in accordance with design specifications prior to introducing highly hazardous chemicals to a process?

Based on interviews with a representative sample of operators, maintenance employees, and engineers, are safety, operating, maintenance, and emergency procedures in place prior to introduction of highly hazardous chemicals into a process?

Based on interviews with a representative sample of operators, maintenance employees, and engineers, is a PHA performed and are recommendations resolved prior to a start-up that introduces highly hazardous chemicals into a new process?


43

Questions Comments/Findings/RecommendationsPre-Startup Safety

Review29 CFR 1910.119

ReferenceFull

Compliance

13. Interviews .119 (l) (2) (iii)

14. Interviews .119 (l)2(iv)

15. Appendix B (CPL) Do the PSSRs confirm that the modified process safety information is in place prior to start-up? (CPL)

Based on interviews with a representative sample of operators, maintenance employees, and engineers, do modified facilities meet requirements of paragraph (1), Management of change prior to introducing a highly hazardous chemical?

Based on interviews with a representative sample of operators, is training completed for each employee involved in operating the process prior to the introduction of a highly hazardous chemical?


44


Mechanical Integrity Questions Comments/Findings/Recommendations

1. Records Review ((j) (6)

2. Records Review (j) (6)





Full Compliance

Does the MI program cover activities for critical processes, and include written management systems procedures to control design and engineering?

Does the MI program cover activities for critical processes, and include written management systems procedures to control procurement?

Does the MI program cover activities for critical processes and include written management systems procedures to control fabrication?

Does the MI program cover activities for critical processes, and include written management systems procedures to control installation of critical equipment?

Does the MI program cover activities for critical processes, and include written management systems procedures to control planning and scheduling of test, inspection, and preventive maintenance?


45

Mechanical Integrity Questions Comments/Findings/Recommendations29 CFR 1910.119

ReferenceFull

Compliance



8. Records Review Does the equipment in the MI program include at a minimum, vessels and storage tanks? (j)(1)(l)

9. Records Review (j) (1) (ii)

10. Records Review (j) (1) (iii)

11. Records Review Does the equipment in the MI program include at a minimum emergency shut-down systems? (j) (1) iv)

Does the MI program cover activities for critical processes, and include written management systems procedures to control spare parts and material?

Does the MI Program cover activities for critical processes, and include written management systems procedures to control deficiencies discovered during MI activities?

Does the equipment in the MI program include at a minimum, piping systems including valves and other piping components? (e.g., heat exchangers, filters, strainers, flanges, seals, welds, gasket materials, bolts and fasteners, etc.)

Does equipment in the MI program include at a minimum, relief and vent systems and devices? (e.g., relief valves, rupture disks, conservation vents, relief headers, depressurizing systems, flare systems, blowout panels, etc.)


46


ReferenceFull

Compliance

12. Records Review (j) (1) (iv)

13. Records Review (j) (1) ( vi)

14. Records Review (j) (1) (vi)

15. Records Review (j) (1) l-vi)


17. Records Review Does equipment in the MI program include at a minimum fire protection equipment? (j) (1) l-vi)

Does equipment in the MI program include at a minimum controls (including monitoring devices and sensors, alarms, and interlocks)?

Does equipment in the MI program include at a minimum pumps (including other critical rotating equipment)?

Does equipment in the MI program include at a minimum key utility sytems that interface with the covered processes and whose failure could contribute to a catastrophic release?

Does equipment in the MI program include at a minimum structural componets for the critical equipment? (e.g., foundations, anchors, bolts, guy wires, pipe supports, etc.)

Does equipipment in the MI program include at a minumum, electrical distribution equipment whose failure could contribute to a catastrophic release? (e.g. ,current ,and frequency controls, uninterruptable power supplies, emergency power generation and distribution equipment)


47


ReferenceFull

Compliance


19. Records Review (j) (1) (l-vi)


21. Records Review Are there work/task instructions for test and inspection (T&I ) tasks? (j) (2)

22. Records Review Are there work/task instructions for preventibe maintencnce (PM) tasks? (j) (2)

23. Records Review Are there work/task instructions for corrective maintenance tasks? (j) (2)

Does equipment in the MI program include at a minimum secondary containments, berms, and other equipment that would limit the spread of or mitigate an actual release?

Does equipment in the MI program include at a minimum, area monitors that would detect an actual release?

Are written procedures (work/task instructions) established and implemented to maintain the on-going integrity of process equipment?


48


ReferenceFull

Compliance

24. Records Review (j) (4) (l)

25. Records Review (j) (4) (ii)



28. Records Review Are the results of each inspection documented? (j) (4) (iv)

29. Records Review Does the documentation include date? (j) (4) (iv)

Ar test, inspections, and preventive maintenance being performed on equipment in the MI program according to the published schedule?

Do the T&I/PM procedures and practices follow recognized and generally accepted good engineering practices?

Do the T&I/PM procedures and practices specify frequencies consistent with applicable manufactures' recommendations and good engineering practice?

Do the T&I/PM procedures and practices specify more frequent tasks, if determined to be necessary by prior operating experience?


49


ReferenceFull

Compliance

30. Records Review Does the documentation include name of person performing the test or inspection? (j) (4) (iv)

31. Records Review Does the documentation include serial number or other identifer of the equipment? (j) (4) (iv)

32. Records Review Does the documentation include description of the test or inspection? (j)(4) (iv)

33. Records Review Does the documentation include results of the test or inspection? (j) (4) (iv)



Are employees involved in maintaining the on-going integrity of process equipment provided training in an overview of the process equipment and its hazards?

Are employees involved in maintaining the on-going integrity of process equipment provided training in the procedures applicable to the employee's job tasks? (i.e., necessary craft skills to perform the maintenance tasks)


50


ReferenceFull

Compliance


37. Records Review Have they been corrected in a timely manner? (j) (5)

38. Records Review Have they restored to a satisfactory condition before futher use as defined by the PSI? (J) (5)


40. Records Review (J) (6) (l)

41. Records Review Are the tempory measures strictly adhered to ? (j) (5)

Are various types of equipment deficiencies defined and treated as critical process equipment which is operating outside the safe upper or lower operating limits as specified in the process safety information?

If the time required to correct the deficiency will be extended, and further use is necessory, are temporary measures taken to protect employee health and safety?

Are there written management system procedures in place that ensure the QA of the design and engeering?


51


ReferenceFull

Compliance

42. Records Review Are there written management system procedures in place that ensure the QA of the procurement? (j) (6) (1)

43. Records Review Are there written management system procedures in place that ensure the QA of the fabrication? (J) (6) (1)

44. Records Review (J) (6) (ii)


46. Records Review (j) (6) (l)

47. Records Review Is engineering work performed by persons qualified to do so? (j) (6) (l)

Are there written management system procedures in place that ensure the QA of the installation of critical equipment?

Are there written management system procedures in place that ensure the QA of the spare parts and material?

Is engineering work conducted in a manner that follows applicable codes, standards, and uses standard, referenceable methodologies?


52


ReferenceFull

Compliance

48. Records Review


50. Records Review Is spare material for equipment in the MI program ordered by vendor part number? (j) (6) (iii)



.119 (j) (5)

Are maintenance materials, spare part and equipment suitable for the process application for which they will be used?

Are maintenance materials, spare parts and equipment suitable for the process application for which they will be used

Alternatively, is a purchase spec prepared for spare material which lists the technical specifications (i.e., engineering input) as listed above for new equipment?

Ae spare materials that have exceeded their shelf life removed from inventory to preclude inadvertent use?


Do observations of a representative sample of process equipment indicate deficiencies outside acceptable llimits? (compare process safety information criteria with the conditions of the equipment found in the process.)


53


ReferenceFull

Compliance

.119 (j) (6) (l)

.119 (j) (6) (iii)

56. Interviews .119 (j) (2)





If new plants or equipment are being constructed, do observations indicate that the equipment as it is fabricated is suitable for the process application?


Do observations of a representative sample of maintenance materials, spare parts, and equipment indicate that they are suitable for the process application for which they will be used?

Engineers (if any; or other quallified persons capable of providing the information requested): Based on interviews with a representative number of engineers, have procedures to maintain the on-going integrity of the process equipment been inplemented for pressure vessels and storage tanks?

Based on interviews with a representive number of engineers, have procedures to maintain the on -going integrity of the process equipment been implemented for piping systems and components such as valves?

Based on interviews with a representative number of engineers, have procedures to maintain the on-going integrity of the process equipment been implemented for relief and vent systems and devices?

Based on interviews with a representative number of engineers, have procedures to maintain the on-going integrity of the process equipment been implemented for emergency shut-down systems?


54


ReferenceFull

Compliance



62. Interviews .119(j) (4)




Based on interviews with a representative number of engineers, have procedures to maintain the on-going integrity of the process equipment been implemented for controls (including monitoring devices and sensors, alarms and interlocks)?

Based on interviews with a representative number of engineers, have procedures to maintain the on-going integrity of the process equipment been implemented for pumps? (Ask about the possibility of safety critical equipment being inadvertently rendered inoperative. For example, a relief device might be isolated by closing an upstream valve.)

Based on interviews with a representative number of engineers, do the inspection and testing procedures follow recognized and generally accepted good engineering practice? Has prior operating experience indicated a need for a more frequent test and inspection schedule than has been implemented?

Based on interviews with a representative number of engineers, are equipment deficiencies corected before use when they are outside the acceptable limits? If not, are the deficiencies corrected in a timely manner and are necessary means taken to assure safe operation?

Based on interviews with a representative number of engineers, has the employer assured that, for new plants and equipment, the equipment as it is fabricated is suitable for the process application? Are appropriate checks and inspections made to assure equipment is installed properly and consistent with design specifications and manufacture's instructions? Are maintenance materials, spare parts, and equipment suitable for the process application for which they will be used? (Ask about contractor supplied items.)

Based on interviews with a representative number of maintenance employees (and, where applicable, contractor maintenance employees), have the written procedures for maintaining the on-going intergity of process equipment been implemented?


55


ReferenceFull

Compliance




69. Interviews .119 (j0 (6)

(CPL)

(CPL)

Based on interiews with a representative number of employees and contractor employees involved in maintaining the on-going integrity of the process, have they been trained to assure they can perform their tasks in a safe manner? Did the training include an overview of the process, its hazards, and procedures applicable to the job? (Determine if certification, specialilzed training, or unique qualifications are required.)

Based on interviews with a representative number of maintenance employees, do test and inspection procedures follow recognized and generally accepted good engineering practices? Is the frequency of inspections and tests consistent with applicable manufacturer"s recommendations and good engineering practices? Are more frequent inspections and test necessary due as indicated by prior operating experience?

Based on interviews with a representative number of maintenance employees, are equipment deficiencies that are outside acceptable limits corrected before further use? If not, are corrections made in a timely manner and necessary means taken to assure operation?

Based on interviews with a representative number of maintenance employees, are maintenance materials, spare parts and equipment suitable for the process application for which they are intended? (Ask about availability and use of substitutes.)


Do the work instructions or work orders apply either to specific pieces of equipment or to different equipment types?


Are employees involved in maintaining the on-going integrity of process equipment provided training in hot work permits?


56


ReferenceFull

Compliance

(CPL)

(CPL)

(CPL)

(CPL)

(CPL)

(CPL)


Are employees involved in maintaining the on-going integrity of process equipment provided training in lockout/tagout?


Are employees involved in maintaining the on-going integrity of process equipment provided training in confined space entry?


Are employees involved in maintaining the on-going integrity of process equipment provided training in line and vessel opening?


Are employees involved in maintaining the on-going integrity of process equipment provided training in other safe work practices?


Are employees involved in maintaining the on-going integrity of process equipment provided training in emergency response?


Are employees involved in maintaining the on-going integrity of process equipment provided training in evacuation procedures?


57


ReferenceFull

Compliance

(CPL)

(CPL)

(CPL)

(CPL)

(CPL)

(CPL)


Are employees involved in maintaining the on-going integrity of process equipment provided training in appropriate portions of SOPs applicable to preventive maintenance?


Are maintenance personnel engaged in special MI-related tasks properly trained and qualified to perform that work welding on pressure vessels?


Are maintenance personnel engaged in special MI-related tasks properly trained and qualified to perform that work high pressure welding?


Are maintenance personnel engaged in special MI_related tasks properly trained and qualified to perform that work non-destructive testing?


Are maintenance personnel engaged in special MI- related tasks properly trained and qualified to perform that work external tank, vessel, or piping inspections?


Are maintenance personnel engaged in special MI- related tasks properly trained and qualified to perform that work internal tank, vessel, or piping inspections?


58


ReferenceFull

Compliance

Are these special qualifications documented? (CPL)

(CPL)

(CPL)



If equipment, materials, and parts are purchased by contractors, are they checked to ensure that they meet the same requirements as spare material specified and purchased by the company?


Is there a general management plan or policy for MI that establishes a maintenance program that is preventive, rather than corrective in nature?


59


Hot Work Permit Questions Comments/Findings/Recommendations

1. Records Review (k) (1)

2. Records Review Does it describe the requirements for the retention of HWPs (at least until the hot work is completed)? (k) (2)


4. Records Review Does the hot work permit indicate the date(s) authorized for hot work? (k) (2)

5. Records Review Does the hot work permit identify the work location? (k) (2)


Full Compliance

Does it require a hot work permit to be issued for hot work operations conducted on or near a covered process?

Does the hot work permit document that all of the fire prevention and protection requirements in 29 CFR 1910.252 (a) have been implemented prior to beginning the hot work operations?


60

Hot Work Permit Questions Comments/Findings/Recommendations29 CFR 1910.119

ReferenceFull

Compliance


7. Records Review Is suitable fire extinguishing equipment maintained in a state of readiness ? (k) (2)





Does the HWP address the requirements of 29 CFR 1910.252 where are openings or cracks in the flooring that cannot be closed, cracks or holes in walls, open or broken windows, are precautions taken so that no combustible materials will be exposed to sparks?

Are fire watchers required whenever welding or cutting is performed in locations where other than a minor fire might develop?

Are fire watchers required if appreciable combustible material, in building construction or contents, closer than 35 feet to the point of operation?

Are fire watchers required if appreciable combustibles are more than 35 feet away but are easily ignited by sparks?

Are fire watchers required if there are wall or floor openings within a 35-foot radius which might expose combustible material in adjacent areas including concealed spaces in walls or floors?


61


ReferenceFull

Compliance


13. Records Review Do fire watchers have fie extinguishing equipment readily available and are they trained in its use? (k) (2)

14. Records Review Are fire watchers famillar with facilities for sounding an alarm in the event of a fire? (k) (2)

15. Records Review


17. Records Review Are hot work permits authorized by an individual responsible for hot work operations? (k) (2)

Are fire watchers required if combustible materials are adjacent to the opposite side of metal partitions, walls, ceilings, roofs and are likely to be ignited by conduction or radiation?

Are fire watchers trained to watch for fires in all exposed areas, try to extinguish fires only when obviously within the capacity of the equipment available, or otherwise sound the alarm?

Is a fire watch maintained for at least a half hour after completion of welding or cutting operations to detect and extinguish possible smoldering fires?


62


ReferenceFull

Compliance




21. Records Review Are floors swept clean of combustible material for a radius of 35 feet? (k) (2)

22. Records Review Are combustible floors kept wet, covered with damp sand, or protected by fire-resistant shields? (k) (2)

23. Records Review (K) (2)

Is the hot work area inspected by the individual responsible for authorizing cutting and welding operations before cutting or welding is permitted?

Does the individual designate precautions to be followed in granting authorization to proceed by indicating those precautions on the written permit?

Are precautions taken when there are combustible materials on floors or the floors made of combustible material?

Are personnel operating arc welding or cutting equipment protected from possible shock where floors have been wet down?


63


ReferenceFull

Compliance

24. Records Review Are cutting and welding prohibited in areas not authorized by management? (k) (2)

25. Records Review Are cutting and welding prohibited in areas in sprinklered buildings while such protection is impaired? (k) (2)


27. Records Review

28. Records Review Are all combustibles relocated at least 35 feet from the work site, where practicable? (k) (2)


Are cutting and welding prohibited in areas in the presence of explosive atmospheres (mixture of flammable gases, vapors, liquid, or dusts with air), or explosive atmospheres that may develop inside uncleaned or improperly prepared tanks or equipment which have previously contained such materials, or that may develop in areas with an accumulation of combustible dusts?

Are cutting and welding prohibited in areas near the storage of large quantities of exposed, readily ignitable materials such as bulk sulfur, baled paper, or cotton?

Where relocation is impracticable, are combustibles protected with flameproofed covers or otherwise shielded with metal or asbestos guards or curtains?


64


ReferenceFull

Compliance

30. Records Review (K) (2)



33. Records Review Where combustibles are not relocated, is a fire watch provided on the opposite side from the work? (k) (2)

34. Records Review

35. Records Review

Are ducts or conveyor systems that might carry sparks to distant combustibles suitably protected or shut down?

Are fire-resistant shields or guards provided to prevent ignition where cutting or welding is done near walls, partitions, ceilings or roofs of combustible construction?

When welding is to be done on a metal wall, partition, ceiling or roof, are precautions taken to prevent ignition of combustibles on the other side due to conduction or radiation, preferably by relocating combustibles?

Is welding not attempted on a metal partition, wall, ceiling or roof having a combustible covering nor on walls or partitions of combustible sandwich-typ panel construction?

Is cutting or welding on pipes or other metal in contact with combustible walls, partitions, ceilings or roof not undertaken if the work is close enough to cause ignition by conduction?


65


ReferenceFull

Compliance






41. Records Review Does the supervisor have the work moved to a location free from dangerous combustibles? (k) (2)

Does management establish areas for cutting and welding, and establish procedures for cutting and welding in other areas, based on fire potentials of plant facilities?

Does management designate an individual responsible for authorizing cutting and welding operations in areas not specifically designed for such processes?

Does management ensure that cutters or welders and their supervisors are suitably trained in the safe operation of their equipment?

Does management advise all contractors about flammable materials or hazardous conditions of which they may not be aware and hot work permitting programs?

Does the supervisor determine the combustible materials and hazardous areas present or likely to be present in the work location?


66


ReferenceFull

Compliance






47. Records Review Does the supervisor where fire watches are required, see that they are available at the site? (k) (2)

Does the supervisor ,if the work cannot be moved, have the combustibles moved to a safe distance from the work or have the combustibles properly shielded against ignition?

Does the supervisor see that cutting and welding are so scheduled that plant operations that might expose combustibles to ignition are not started during cutting or welding?

Does the supervisor secure authorization for the cutting or welding operations from the designed management representative?

Does the supervisor determine that the cutter or welder secures his approval that conditions are safe before going ahead?

Does the supervisor determine that fire protection and extinguishing equipment are properly located at the site?


67


ReferenceFull

Compliance

48. Records Review Are cutting or welding permitted only in areas that are or have been made fire safe? (k) (2)



51. Records Review Are any pipe lines or connections to the drum or vessel disconnected or blanked? (k) (2)


53. Records Review Are they purged with inert gas (recommended)? (k) (2)

When work cannot be moved practically, as in most construction work< is the area made safe by removing combustibles or protecting combustibles from ignition sources?

Is no welding, cutting, or other hot work performed on used drums, barrels, tanks or other containers until they have been cleaned so thoroughly as to make absolutely certain that there are no flammable materials present or any substances such as greases, tars, acids, or other materials which when subjected to heat, might produce flammable or toxic vapors?

Are all hollow spaces, cavities or containers vented to permit the escape of air or gases before preheating, cutting or welding?


68


ReferenceFull

Compliance



56. Records Review Where practicable, are the torch and hose removed from the confined space? (k) (2)

57. Records Review Is flammable gas test performed prior to initation of hot work? (k) (2)

58. Records Review Are testing instructment correctly calibrated? (k) (2)

59. Records Review Is periodic re-testing or scantiness monitoring required, if appropriate? (K) (2)

When arc welding is to be suspended for any substantial period of time, such as during lunch, or overnight, are all electrodes removed from the holders and the holders carefully located so that accidental contact cannot occur and is the machine disconnected from the power source?

In order to eliminate the possibilty of gas escaping through leaks or improperly closed valves, when gas welding or cutting, are torch valves closed and the gas supply to the torch positively shut off at some point outside the confined area whenever the torch is not to be used for a substantial peiod of time, such as during lunch hour or overnight?


69


ReferenceFull

Compliance

60. Records Review Are permits suspended when appropriate? (k) (2)

61. Records Review Are hot work permits kept on file until completion of the work operations? (k) (2)


64. Interviews

65. Interviews

On completion of hot work, are steps followed to provide closure for those who need to know the job is completed and that equipment can be returned to normal?


Conduct checks of current welding and cutting operations to ensure compliance with the requirments fo 1910. 119 (K) and 1910.252 (a). The 20 items listed above in Records Review may serve as an audit checklist. A management representative, the individual responsible for welding operations and the supervisor should all be invited to participate in this on-site check.

.119(k) and .252 (a)

Based on interviews with a representative number of maintenance and contractor employees, has the Supervisor visited welding work operations to verify that welders have approval for safe go ahead prior to welding?

.252 (a) (2) (xiv) (E) (F) and (G)

Based on interviews with a representative number of maintenance and contractor employees, has the Supervisor visited welding work operations to verify that fire protectionn and extinguishing equipment is properly located at the work site?

.252 (a) (2) (xiv) (E) ,(F) and (G)


70


ReferenceFull

Compliance

66. Interviews

67. Interviews .119(k) (1)

68. Interviews .119 (k) (1)

69. Interviews .252(a) (2) (l)

70. Interviews .252 (a) (2) (iii)

71. Interviews

Based on interviews with a representative number of maintenance and contractor employees, has the Supervisor visited welding work operations to verify that fire watches are functional, where required/

.252(a) (xiv) (E) (F) and (G)

Based on interviews with a representative number of maintenance and contractor employee, have hot work permits been issued for all hot work operations conducted on or near a process covered by this standard?

Based on interviews with a representative number of maintenance and contractor employees, have the hot work permits been kept on file until the hot work operations were complete?

Based on interviews with a representative number of maintenance and contractor employees, have the hot work permits identified openings, cracks and holes where sparks may drop to combustible materials below?

Based on interviews with a representative number of maintenance and contractor employees, have the hot work permits assigned fire watchers whenever welding is performed in locations where other than a minor fire might develop?

Based on interviews with a representative number of maintenance and contractor employees, are the hot work permits being authorized, preferably in writing, by the individual responsible for all welding and cutting operations? Is authorization preceded by site inspection and designation of appropriate precautions? (.252 (a ) (2) (iv) and (a) (2) xiii) (A)

.252 (a) (2) (iv) and .252(a) (2)

(xiii0 (A)


71


ReferenceFull

Compliance

72. Interviews

73. Interviews .252 (a) (2) (vi)

74. Interviews .252(a) (2) (vi)



77. Interviews .252(a) (2) (vii)

Based on interviews with a representative number of maintenance and contractor employees, have the hot work permits described precautious associated with combustible materials on floors or floors, walls, partitions, ceilings or roofs of combustible construction?

.252(a) (2) (v) and .252 )a) (2)

(ix)

Based on interviews with a representative number of maintenance and contractor employees, has hot work permitting been successful in prohibiting welding in unauthorized areas?

Based on interviews with a representative number of maintenance and contractor employees, has hot work permitting been successful in prohibiting welding in sprinkle red buildings while such protection is impaired?

Based on interviews with a representative number of maintenance and contractor employees, has not work permitting been sucessful in prohibiting welding in the presence of explosive atmospheres?

Based on interviews with a representative number of maintenance and contractor employees, has hot work permitting been successful in prohibiting welding in storage areas for large quantities of readily ignitable materials?

Based on interviews with a representative number of maintenance and contractor employees, have the hot work permits required relocation of combustibles where practicable and covering with flameproofed covers where not practicable?


72


ReferenceFull

Compliance

78. Interviews .252 (a) (2) (viii)

79. Interviews .252 (a) (2) (xii)

80. Interviews .252 (a)(2) (xI)

81. Interviews .252(e) (2) (xii)

82. Interviews

83. Interviews

Based on interviews with a representative number of maintenance and contractor employees, have hot work permits identified for shut-down any ducts or conveyors systems that may convey sparks to distant combustibles?

Based on interviews with a representative number of maintenance and contractor employees, have hot work permits required precautions whenever welding on components (e.g., steel members, pipes, etc.) that could transmit heat by radiation or conduction to unobserved combustibles?

Based on interviews with a representative number of maintenacne and contractor employees, have hot work permits identified hazaards associated with welding on walls, partitions, ceilings or roofs with combustible coverings or welding on walls or panels of sandwich -type construction?

Based on interviews with a representative number of maintenance number of maintenance and contractor employees, has management establlished areas and procedures for safe welding and cutting based on fire potential?

Based on interviews with a representative number of maintenance and contractor employees, has management designated the individual responsible for authorizing cutting and welding operations in process areas?

.252(a) (2) (xiii) (B)

Based on interviews with a representative number of maintenance and contractor employees, has management ensured that welders, cutters and supervisors are trained in the safe operation of their equipment?

.252 (a) (2) (xiii) (C)


73


ReferenceFull

Compliance

84. Interviews

85. Interviews

Based on interviews with contractors and contractor employees, has management advised outside contractors working on the site about all hot work permitting programs?

.252 (a) (2) (xiii) (D)

Based on interviews with a representative number of maintenance and contractor employees, has the supervisor determined if combustibles are being protected from ignition prior to welding by moving them, shielding them, or scheduling welding around their production?

.252 (a)(2) (xiv) (A) (B) and (C)


74





3. Records Review At a minimum, are the changes to operating procedures, being treated as MOC situations? (l) (1)


5. Records Review Do the procedures address the technical basis for proposed change prior to the change being made? (l) (2) (l)

Management of Change


Full Compliance

At a minimum, are the changes to hardware in PSM-covered equipment that are not replacement-in-kind, being treated as MOC situations?

At a minimum, are the changes to process technology in PSM-covered equipment (e.g., changes in chemicals, operating limits for parameters, or process chemistry). Being treated as MOC situations?

Have written procedures been established and implemented to manage changes to process chemicals, technology, equipment and process conditions and changes to facilities that effect a covered process?


75

Questions Comments/Findings/RecommendationsManagement of

Change29 CFR 1910.119

ReferenceFull

Compliance

6. Records Review Do the procedures address the impact of change on safety and health prior to the change being made? (l) (2) (ii)

7. Records Review Do the procedures address modifications to operating procedures prior to the change being made? (l) (2) (iii)

8. Records Review Do the procedures address the necessary time period for the change prior to the change being made? (l)(2) (iv)

9. Records Review (l) (2) (v)

10. Records Review Are authorization procedures and responsible individuals clearly identified in the procedure? (l) (3)


Do the procedures address the authorization requirements for the proposed change prior to the change being made?

Does the procedure address how employees involved in operating a process, and maintenance staff, and contract employees whose job tasks are affected by a change in the process, informed of and trained in the change prior to start-up?


76



ReferenceFull

Compliance




15. Records Review Have changes been made without appropriate updates of the PSI? (l)(4)

16. Records Review Have changes been made without appropriate updates of the SOPs? (l) (5)

17. Records Review Have changes been made without appropriate updates to the safe work practices? (l) (5)

Does the procedure address how the process safety information is to be updated if it is affected by the change? (NOTE: Final approved PSI is not required to restart the process - accurate, legible marked-up PSI is acceptable on a temporary basis.)

Does the MOC procedure address updates to the operating procedures and safe work practices if they are affected by the change?

Have changes been made to covered plant equipment or procedures which are not replacement-in-kind without the use of the MOC procedure?


77



ReferenceFull

Compliance

.119 (l) (1)

19. Interviews .119 (l) (1)

20. Interviews .119 (l) (3)



23. Appendix B (CPL) CPL)


Do observations of new or recently modified process chemicals, technology, equipment, or procedures (except replacement-in-kind) indicate that the Management of Change procedures have been implemented? (Determine if records are available to support the procedures for new or revised processes found in the facility.)

Based on interviews with operators, maintenance employees and contractor employees, are procedures implemented to manage changes to existing process chemicals, technology, equipment, facilities, and procedures?

Based on interviews with operators, maintenance employees and contractor employees, is training in process changes provided to employees whose job tasks will be affected by the changes prior to start-up?

At a minimum, are changes to consumable materials in the process such as gasket and seal materials being treated as MOC situations?

Is the restoration of equipment and procedures to their original, approved conditions at the end of the change included in the procedure?

Does the procedure contain a verification that the modifications have been made as designed and approved?


78



ReferenceFull

Compliance

24. Appendix B (CPL) Have changes been implemented as approved during the MOC process? (CPL)

25. Appendix B (CPL) Have changes been restored to status quo after temporary change time periods have expired? (CPL)


79


Incident Investigations Questions

1. Records Review (m) (3)


3. Records Review ((m) (2)




Full Compliance

Does the incident investigation procedure cover designation, training and qualification of the remaining investigation team members? (i.e., at least one person knowledgeable in the process involved, a contract employee if the incident involved work of the contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident)

Does the incident investigation procedure cover how the findings and recommendations will be promptly resolved?

Does the incident investigation procedure provide guidance that incident investigations are to be initiated as soon as possible but no later than 48 hours following the incident?

Does the incident investigation procedure cover format, content, review, and approval of incident investigation reports?

Does the incident investigation procedure cover communication of lessons learned to appropriate personnel who need to know?


80

Incident Investigations Questions29 CFR 1910.119

ReferenceFull

Compliance

6. Records Review Does the incident investigation procedure cover retention of incident reports? (m) (7)


8. Records Review Are incidents investigated by teams with the ability to properly perform the investigation promptly? (m0 (3)

9. Records Review Are incidents reports generated which includes the date of incident? (m) (4) (l)

10. Records Review Are incidents reports generated which includes the date the investigation began? (m) (4) 9ii)

11. Records Review Are incident reports generated which includes the description of the incident? (m) (4) ((iii)

Is there a system in place to assure that each incident that actually resulted in a catastrophic release or could reasonably have resulted in a catastrophic release (i.e., near miss) of highly hazardous chemicals is investigated?


81


ReferenceFull

Compliance

12. Records Review Are incident reports generated which includes factors that contributed to the incident? (m) (4) (iv)

13. Records Review Are incident reports generated which includes any recommendations resulting from the investigation? ((m) (4) (v)




17. Records Review Are incidents investigation reports retained for at least five years? (m) (7)

Are the reports reviewed with all affected personnel whose job tasks are relevant to the incident findings including contract employees where applicable?

Are resolution communicated to the incident investigation team and any subsequent recommendations of the team expeditiously resolved?

Are the incident investigation reports reviewed with affected employees whose job tasks are relevant to incident findings, including contract employees where applicable?


82


ReferenceFull

Compliance

.119 (m) (6)

19. Interviews .119(m) (3)

20. Interviews .119 (m) (3)

21. Interviews .119 (m) (6)

22. Interviews When required, are incident report recommendations rejected properly? (CPL)


Do observations of a representative sample of process components involved in incident investigation indicate that recommendations have been resolved? (Compare the corrective actions outlined in the investigation documentation with the actual equipment, procedures, material use, etc.)

Based on interviews with a representative number of operators, maintenance employees and contractor employees, have all incidents that resulted in or could reasonably have resulted in a catastrophic release of highly hazardous chemicals in the workplace, been investigated?

Based on interviews with a representative number of the members of past investigation teams, do the teams contain at least one person knowledgeable in the process involved in the incident, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident? Was a contractor employee included in the team if the incident involved work of the contractor?

Based on interviews with a representative number of employees whose job tasks are relevant to the past incident investigation findings, have the investigation reports been reviewed with the affected personnel?


83

Comments/Findings/Recommendations


84



85



86



87


Questions 29 CFR 1910.119 Reference Comments/Findings/Recommendations

1. Records Review 29 CFR 1910 .38 (a)

2. Records Review Does the emergency action plan include procedures for handling small releases and spills? 29 CFR 1910 .38 (a)

3. Records Review Is the action plan written if the facility has more than 10 employees? 29 CFR 1910 .38(a) (1)

4. Records Review 29 CFR 1910 .38 (a) (1)

5. Records Review 29 CFR 1910 .38(a) (2) (l)

Emergency Planning & Response

Full Compliance

Has the employer established and implemented an on-site emergency action plan for the entire plant which meets at a minimum, the provisions of 29 CFR 1910 .38 (a) ?

Does the action plan cover those designated actions employers and employees must take to ensure employee safety from fire and other emergencies?

Does the emergency action plan include emergency escape procedures and emergency route assignments?


88

Questions 29 CFR 1910.119 Reference Comments/Findings/RecommendationsEmergency Planning

& ResponseFull

Compliance

6. Records Review 29 CFR 1910 .38 (a) (2) (ii)

7. Records Review 29 CFR 1910 .38(a) (2) (iii)

8. Records Review 29 CFR 1910 .38 (a) (2) (iv)

9. Records Review 29 CFR 1910 .38 (a) (2) (v)

10. Records Review 29 CFR 1910 .38(a) (2) (vi)

11. Records Review 29 CFR 1910 .38(a) (3) (l)

Does the emergency action plan include procedures to be followed by employees who remain to operate critical plant operations before they evacuate?

Does the emergency action plan include procedures to account for all employees after emergency evacuation has been completed?

Does the emergency action plan include rescue and medical duties for those employees who are to perform them?

Does the emergency action plan include the preferred means of reporting fires and other emergencies?

Does the emergency action plan include names or regular job titles of persons or departments who can be contracted for further information or explanation of duties under the plan?

Is the alarm system to alert employees of an emergency established and impemented which conplies with 1910.165 (b-e)?


89


& ResponseFull

Compliance

12. Records Review Is the alarm system distinctive for each purpose of the alarm? 29 CFR 1910 .38 (a) (3) (ii)

29 CFR 1910.165(B) (1)

29 CFR 1910.165 (b)(2)

29 CFR 1910.165 (b) (2)

29 CFR 1910.165 (b) (3)

Does the employer explain to each employee the preferred means of reporting emergencies? 29 CFR 1910.165(b) (4)

13. Records Review: Requirements of 1910.165

Does the alarm system provide warning for necessary emergency action as called for in the emergency action plan, or for reaction time for safe escape of employees from the workplace or the immediate work area, or both?


Are the alarms capable of being perceived above ambient noise and light levels by all employees in the affected portions of the workplace?


Are tactile devices used to alert those employees who would not otherwise be able to recognize the audible or visual alarm?


Is the alarm distinctive and recognizable as a signal to evacuate the work area or perform actions designated under the plan?



90


& ResponseFull

Compliance

29 CFR 1910.165 (b) (4)

29 CFR 1910.165 (b) (4)

Has the employer established procedures for sounding emergency alarms in the workplace? 29 CFR 1910.165 (b) (5)

29 CFR 1910.165 (b) (5)

Is there a back-up system for such workplaces? 29 CFR 1910.165 (b) (5)

29 CFR 1910.165 (b)(5)


Does the employer post emergency telephone numbers near telephones, or employee notice boards, and other conspicuous locations when telephones serve as a means of reporting emergencies?


Where a communication system also serves as the employees alarm system, do all emergency messages have priority over all non-emergency messages?



For employers with more than 10 employees in a particular workplace, is a procedure other than direct voice communication used?



For employers with 10 or fewer employees in a particular workplace, if direct voice communication is used as the procedure for sounding the alarm, can all employees hear the alarm?


91


& ResponseFull

Compliance

29 CFR 1910.165 (c) (1)

29 CFR 1910.165 (c) (1)

29 CFR 1910.165 (c) (2)

29 CFR 1910.165(d) (1)

29 CFR 1910.165 (d) (2)

29 CFR 1910.165 (d) (3)


Does the employer assure that all devices, compontents, combinations of devices or systems constructed and installed to comply with this standard are approved ?


Does the employer assure that all devices, compontents, combinations of devices or systems constructed and installed to comply with this standard are approved?


Are spare alarm devices and compontents subject to wear or destruction available in sufficient quantities and locations for prompt restoration of the system?


Does the employer assure that all employee alarm systems are maintained in operating condition except when undergoing repairs or maintenance?


Does the employer assure that a test of the reliability and adequacy of non-superisid employee alarm systems is made every two months?


Is a different actuation device used in each test of a multi-actuation device system so that no indidual device is used for two consecutive tests?


92


& ResponseFull

Compliance

29 CFR 1910.165 (d) (3)

29 CFR 1910.165 (d) (3)

29 CFR 1910.165 (d) (4)

29 CFR 1910.165 (d) (4)

29 CFR 1910.165 (d) (5)

29 CFR 1910.165 (d) (5)


Does the employer maintain or replace power supplies as often as it is necessary to assure a fully operational condition?


Are back-up means of alarm, such as employee runners or telephones, provided when systems are out of service?


Does the employer assure that employee alarm circuitry installed after January 1, 1981, which is capable of being supervised is supevised and that it will provide positive notification to assigned personnel whenever a deficiency exists in the system? NOTE: The requirements for supervising the employee alarm system circuitry and power supply may be accomplished in a variety of ways. Typically, electrically operated sensors for air pressure, fluid pressure, steam pressure, or electrical continuity of circuitry may be used to continously monitor the system to assure it is operational and to identify trouble in the system and to give a warning signal. (1910 Subpart L, Appendix A, Non- mandatory guidance for support L,1910.165 Employee Alarm Systems).


Does the employer assure that all supervised employeealarm systems are tested at least annually for reliability and adequacy?


Does the employer assure that the servicing, maintenance and testing of employee alarms are done by persons tranined in the designed operation and functions necessary for reliable and safe operation of the system?


Does the employer assure that manually operated actuation devices for use in conjunction with employees alarms are unobstructed, conspicuous and readily accessible?


93


& ResponseFull

Compliance

29 CFR 1910.38 (a) (4)

29 CFR 1910.38 (a) (5) (l)

29 CFR 1910.38 (a) (5) (ii)

29 CFR 1910.38 (a) (5) (ii)

29 CFR 1910.38 (a) (5) (ii)

29 CFR 1910.38 (a) (5) (iii)

36. Records Review: Requirements of 1910.38(a)

Has the employer established in the emergency action plan the types of evacuation to be used in emergency action plan the types of evecuation to be used in emergency circumstances?


Has the employer, before implementing the emergency action plan, designated and trained a sufficient number of persons to assist in the safe and orderly emergency evacuation of employees?


Is the emergency action plan reviewed with each employee covered by the plan initally when the plan is developed?


Is the emergency action plan reviewed with each employee covered by the plan whenever the employee's responsibilities or designated actions under the emergency action plan change?


Is the emergency action plan reviewed with each employee covered by the plan whenever the emergency action plan itself is changed?


Does the employer review with each employee uppon inital assignment those parts of the plan which the employee must know to protect the employee in the event of an emergency?


94


& ResponseFull

Compliance

29 CFR 1910.38 (a) (5) (iii)

29 CFR 1910.38 (b) (2) (l)

29 CFR 1910.38 (b)(2) (ii)

29 CFR 1910.38 (b) (2) (iii)

29 CFR 1910.38 (b) (3)

Are housekeeping procedures included in the written fire prevention plan? 29 CFR 1910.38 (b) (3)


For employers with more than 10 employees, is the written plan kept at the workplace and made available for employee view?


Does the emergency action plan cover fires? If so, does it include, at a minimum, a list of the major workplace fire hazards and their proper handling and storage procedures, potential ignition sources and their control procedures, and the type of fire protection equipment or systems which can control a fire involving them?


Does the emergency action plan cover fires? If so, does it include at a minimum, names or regular job titles of those personnel responsible for maintenance of equipment and systems installed in prevent or control ignitions or fires?


Does the emergency action plan cover fires? If so, does it include, at a minimum, names or regular job titles of those personnel responsible for control of fuel source hazards/


Does the employer control accumulations of flammable and combustible waste materials and residues so that they do not contribute to a fire emergency?



95


& ResponseFull

Compliance

29 CFR 1910.38 (b) (4) (l)

29 CFR 1910.38 (b) (4) (ii)

29 CFR 1910.38 (b) (5)

Are maintenance procedures included in the written fire prevention plan? 29 CFR 1910.38 (b) (5)

29 CFR 1910.120 (q) (1)

29 CFR 1910.120 (q) (1)


Are employees informed of the fire hazards of the fire materials and processes to which they are exposed?


Does the employer review with each employee upon initial assignment those parts of the fire prevention plan which the employee must know to protect the employee in the event of an emergency?


Does the employer regularly and properly maintain, according to established procedures, equipment and systems installed on heat producing equipment to prevent accidental ignition of combustible materials?


52. Records Review: Requirements of 1910.120(q)

Has an emergency response plan been developed and implemented to handle anticipated emergencies prior to the commencement of emergency response operations unless the employer will evacuate employees from the danger area when an emergency occurs, will not permit any employees to assist in handling the emergency and has provided an emergency action plan complying with 1910.38 (a)?


Is the plan in writing and available for inspection and copying by employees, their representatives, and OSHA personnel?


96


& ResponseFull

Compliance

29 CFR 1910.120(q) (2)(l)

29 CFR 1910.210 (q) (2) (ii)

29 CFR 1910.210 (q)(2) (iv)

29 CFR 1910.120 (q)(2) (v)


If the employer's staff will respond, and with the facility is subject to OSHA's HAZWOPER regulations, does the emergency response plan address, as a minimum, pre-emergency planning and coordination with outside parties?


If the employer's staff will respond, and the facility is subject to OSHA's HAZWOPER regulations, does the emergency response plan address, as a minimum, personnel roles, lines of authority, training, and communication


If the employer's staff will respond, and the facility is subject to OSHA'S HAZWOPER regulations, does the emergency response plan address, as a minimum, emergency recognition and prevention?

29 CFR 1910.210 (q)(2) (iii)


If the employer's staff will respond, and the facility is subject to OSHA's HAZWOPER regulations, does the emergency response plan address, as a minimum, safe distances and places of refuge?


If the employer's staff will respond, and the facility is subject to OSHA's HAZWOPER regulations, does the emergency response plan address, as a minimum, site security and control?


If the employer's staff will respond, and the facility is subject to OSHA's HAZWOPER regulations, does the emergency response plan address, as a minimum, evacuation routes and procedures?

29 CFR 1910.210 (q) (2) (vi)


97


& ResponseFull

Compliance

29 CFR 1910.120 (q) (2) (x)

Are procecdures for handling emergency response in compliance with 1910.120 (q) (3)?


If the employer's staff will respond, and the facility is subject to OSHA'S HAZWOPER regulations, does the emergency response plan address, as a minimum, decontamination ?

29 CFR 1910.120 (q) (2) (vii)


If the employer's staff will respond, and the facility is subject to OSHA's HAZWOPER regulation, does the emergency response plan address, as a minimum, emergency medical treatment and first aid?

29 CFR 1910.120 (q) (2) (viii)


If the employer's staff will respond, and the facility is subject to OSHA's HAZWOPER regulations, does the emergency response plan address, as a minimum, emergency alerting and response procedures?

29 CFR 1910.120 (q) (2) (ix)


If the employer's staff will respond, and the facility is subject to OSHA's HAZWOPER regulations, does the emergency response plan address, as a minimum, critique of response and follow-up/


If the employer's staff will respond, and the facility is subject to OSHA's HAZWOPER regulations, does the emergency response plan address, as a minimum, PPE and emergency equipment?

29 CFR 1910.120 (q) (2) (xi)



98


& ResponseFull

Compliance

29 CFR 1910.120 (q) (3) (l)

29 CFR 1910.120 (q) (3) (v)

Are back-up personnes standing by with equipment ready to provide assistance or rescue?


Is the senior emergency response official responding to an emergency designated as the individual in charge of a site-speciffic Incident Command System (ICS)? NOTE: The senior official at an emergency response is the most senior official on the site who has the responsibility for controlling the operations at the site.Initially it is the senior officer on the first-due piece of responding emergency apparatus to arrive on the incident scene. As more senior officers arrive (i.e., battalion chief, state law enforcement official, site coordinator, etc.) the position is passed up the line of authority which has been previously established.


Does the senior official have the authority to suspend the use of emergency breathing devices when air monitoring equipment shows that a decreased level of respiratory protection will not result in hazardous exposures to employees?

29 CFR 1910.120 (q) (3) (iv)


Does the senior official have the authority to limit the number of emergency response personnel at the emergency site, in those areas of potential or actual exposure to incident or site hazards, to those who are actively performing emergency operations?


29 CFR 1910.120 (q) (3) (vi)


Are qualified basic life support personnel, as minimum, also available with medical equipment and transportation capability?

29 CFR 1910.120 (q) (3) (vi)


Is a safety officer designated who is knowledgeable in the operation being implemented at the emergency response site, with specific responsibility to identify and evaluate hazards and to provide direction with respect to the safety of operations for the emergency at hand?

29 CFR 1910.120 (q) 93) (vii)


99


& ResponseFull

Compliance

29 CFR 1910.120 (q) (3) (x)

29 CFR 1910.120 (q) (4)

29 CFR 1910.120 (q) (5)


Does the safety officer have the authority to alter, suspend, or terminate activities if he/she feels that an IDLH or imminently dangerous condition exists?

29 CFR 1910.120 (q) 93) ((viii)


Does the safety official immediately inform the individual in charge of the ICS of any actions need to be taken to correct these hazards at the emergency scene?

29 CFR 1910.120 (q) (3) (viii)


Does the senior official implement appropriate decontamination procedures when response activities have been terminated?

29 CFR 1910.120 (q) (3) (xi)


Do all compressed air cylinders used with self-contained breathing apparatus meet U.S. Department of Transportation and National institute for Occupational Safety and Health criteria?


Are skilled support personnel who preform emergency work provided with a briefing that includes the use of appropriate PPE, the chemical hazards involved, and what duties are to be performed?


Do employees who, in the course of their regular job duties, work with and are trained in the hazards of specific hazardous substances, and who will be called upon to provide technical advice or assistance at a hazardous substance release incident to the individual in charge, receive training or demonstrate competency in the area of their specialzation annually?


100


& ResponseFull

Compliance

29 CFR 1910.120 (q)(6) (l)

29 CFR 1910.120 (q) (6) (ii)

29 CFR 1910.120 (q) (6) (v)

29 CFR 1910.120 (q) (7)


Have training requirments for responders, trainers, and refresher training been met according to 1910.120 (q) (6) for first responder awareness level?


Have training requirments for responders, trainers, and refresher training been met according to 1910.120 (q) (6) for first responder operations level?


Have training requirements for responders, trainers, and refresher training been met according to 1910.120 (q) (6) for hazardous materials technician?

29 CFR 1910.120 (q) (6) (iii)


Have training requirements for responders, trainers, and refresher training been met according to 1910.120 (q) (6) for hazardous materials specialist?

29 CFR 1910.120 (q) (6) (iv)


Have training requirements for responders, trainers, and refresher training been met according to 1910.120 (q) (6) for on scene incident commander?


Have trainers who teach any of the above training subjects, satisfactorily completed a training course for teaching the subjects they are expected to teach, such as the courses offered by the U.S. National Fire Academy, or they shall have the training and/or academic credenitals and instuctional experience necessary to demonstrate competent instructional skills and a good command of the subject matter of the course they are to teach?


101


& ResponseFull

Compliance

29 CFR 1910.120 (q) (8)

Is the refresher training or demonstration at least annual? 29 CFR 1910.120 (q) (8) (l)

29 CFR 1910.120 (q) (8) (l)

Is annual refresher training or demonstration documented? 29 CFR 1910.120 (q) (8) (ii)

29 CFR 1910.120 (q) (9)

29 CFR 1910.120 (q) (9)


Does those employees who are trained as First Responders Operations Level, Hazardous Materials Technician, Hazardous Materials Specialist, or On Scene Incident Commander receive refresher training or demonstrate competency?



If applicable, is the refresher training of sufficient duration and content so as to provide adequate confidence that skills are being maintained?



Have HAZMAT team members and hazardous materials specialists received baseline physical examinations and medical surveillance?


Are any emergency response employees who exhibit signs or symptoms which may have resulted from exposure to hazardous substances during the course of an emergency incident either immediately or subsequently, provided with medical consolation as required in 1910.120 (f) (3) (ii)?


102


& ResponseFull

Compliance

106. Interviews 29 CFR 1910.120(q) (6) (l)

107. Interviews 29 CFR 1910.120 (q) (6 (l)

108. Interviews 29 CFR 1910.120 (q) (6) (l)




Based on interviews with employees who are likely to discover hazardous substance releases, do they understand what hazardous substances are, and the risks associated with them in an incident?

Based on interviews with employees who are likely to discover hazardous substance releases, do they understand potential outcomes associated with an emergency when hazardous substances are present?

Based on interviews with employees who are likely to discover hazardous substance releases, do they have the ability to recognize the presence of hazardous substances in an emergency?

Based on interviews with employees who are likely to discover hazardous substance releases, do they have the ability to identify the hazardous substances, if possible?

Based on interviews with employees who are likely to discover hazardous substance release, do they understand the role of the first responder awareness individual in the employer's emergency response plan, including site security and control and the U.S. Dept. of Transportation's Emergency Response Guidebook?

Based on interviews with employees who are likely to discover hazardous substance releases, do they have the ability to realize the need for additional resources, and make appropriate notifications to the communication center?


103


& ResponseFull

Compliance

112. Interviews 29 CFR 1910.120 (q) (6) (ii)

113. Interviews 29 CFR 1910.120(Q) (6) (ii)

114. Interviews




Based on interviews with employees who will take defensive action in containing and controlling a release as part of the response, can demonstrate the conperencies for a first responder operations level?

Based on interviews with employees who will take defensive action in containing and controllng a release as part of the response, can demostrate the knowledge of the basic hazard and risk assessment techniques?

Based on interviews with employees who will take defensive action in containing and controlling a release as part of the response, can demonstrate the knowledge of how to select and use proper PPE provided to them?

29 CFR 1910.120 ((q) (6) (ii)

Based on interviews with a employees who will take defensive action in containing and controllling a release as part of the response, can demonstrate the understanding of basic hazardous materials terms?

Based on interviews with employees who will take defensive action in containing and controlling a release as part of the response, can demonstrate the knowledge of how to perform basic containment, confinement, and control operations within the capability of their unit?

Based on interviews with employees who will take defensive action in containing and controlling a release as part of the response, can demonstrate the knowledge of how to implement basic decontamination procedures?


104


& ResponseFull

Compliance


119. Interviews

120. Interviews

121. Interviews

122. Interviews

123. Interviews

Based on interviews with employees who will take defensive action in containing and controlling a release as part of the response, can demonstrate the knowledge of relevant standard operating procedures and termination procedures for a response?

Based on interviews with employees who will take offensive action in containing and controlling a release as part of the response, can they demonstrate the competencies for a hazardous materials (HAZMAT) technician?

29 CFR 1910.120 (q) (5) (iii)

Based on interviews with employees who will take offensive action in containing and controlling a release as part of the response, can they demonstrate the knowledge of how to implement the employer's emergency response plan?

29 CFR 1910.120 (q) (6) (iii)

Based on interviews with employees who will take offensive action in containing and controlling a release as part of the response, can they demonstrate the knowledge of the classification, identificatiion, and verification of known and unknown materials using field survey instruments and equipment?

29 CFR 1910.120 (q) (6) (iii)

Based on interviews with employees who will take offensive action in containing and controlling a release as part of the response, can they demonstrate the ability to function within an assigned role in the Incident Command System?

29 CFR 1910.120(q) )6) (iii)

Based on interviews with employees who will take the offensive action in containing and controllling a release as part of the responses, can they demonstrate the knowledge of how to select and use proper Specialized Chemical PPE provided to them?

29 CFR 1910.120(q) (6) (iii)


105


& ResponseFull

Compliance

124. Interviews

125. Interviews

126. Interviews

127. Interviews

128. Interviews

129. Interviews 29 CFR 1910.38 (a)

Based on interviews with employees who will take offensive action in containing and controlling a release as part of the response, can they demonstrate the understanding of hazard and risk assessment techniques?

29 CFR 1910.120 (q) (6) (iii)

Based on interviews with employees who will take offensive action in containing and controlling a release as part of the response, can they demonstrate the ability to perform advenced control. Containment, and/or condinement opeations within the capability of their unit?

29 CFR 1910.120(q) (6) (iii)

Based on interviews with employees who will take offensive action in containing and controlling a release as part of the response, can they demonstrate the understanding of how to implent decontamination procedures?

29 CFR 1910.120(q) (6) (iii)

Based on interviews with employees who will take offensive action in containing and controlling a release as part of the response, can they demonstrate the understanding of termination procedures?

29 CFR 1910.120 (q) (6) (iii)

Based on interviews with employees who will take offensive action in containing and controlling a release as part of the response, can they demonstrate the understanding of basic chemical and toxicological terminology and behavior?

29 CFR 1910.120(q) (6) (iii)

Based on interviews with a representative number of operator and maintenance employees, do they know the emergency action plan to protect themselves in an emergency?


106


& ResponseFull

Compliance

Appendix B (CPL) N/A


107


Compliance Audits Questions Comments/Findings/Recommendations

1. Records Review (o) (1)

2. Records Review Have the triennial audits been certified in writting? (o) (1)

3. Records Review Was at least one person knowledgeable in the process? (o) (2)

4. Records Review Was a report containing the findings of the audit developed? (o) (3)

5. Records Review (o) (4)

6. Records Review Are responses and their rationale docomented? (o) (4)


Full Compliance

Was the first audit completed before May 26,1995? NOTE: If the activity was not called an audit but was intended to comply with paragraph (o) then it does not matter what name was given to the activity- it is a PSM audit for the purposes of the regulations?

Was an appropriate response to each of the findings of the audit promptly determined and documented (i.e., can't wait until the next audit to start addressing recommendations)?


108

Compliance Audits Questions Comments/Findings/Recommendations29 CFR 1910.119

ReferenceFull

Compliance

7. Records Review Ae the two most recent compliance audits retained? (o)(5)

No observatiions are required; on-site Conditions will be cited under other paragraphs. .119 (o) (4)

9. Interviews Based on interviews with auditors, are they knowledeable in processes? .119(o) (2)

10. Interviews .119 (o) (3)

(CPL)

Were all elements of the PSM Standard audited? (CPL)


Based on interviews with a representative number of employees and their designated representatives, do they have access to compliance audit information?


Are PSM compliance audits conducted within three years of the certification date of the previous audit?



109

Compliance Audits Questions Comments/Findings/Recommendations29 CFR 1910.119

ReferenceFull

Compliance

Was a field inspection conducted? (CPL)

Were relevant records reviewed? (CPL)

Were interviews conducted with a cross section of salaried and hourly paid personnel? (CPL)

When required, are audit recommendations rejected properly?

Do employees have access to compliance audit information? (CPL)







110


Trade Secrets Questions Comments/Findings/Recommendations

(p) (1)

(p) (3)

Is trade secret information available to personnel developing PSI ? (p) (1)

Is trade secret information available to personnel developing PHAs? (p) (1)

Is trade secret information available to personnel developing operating procedures? (p) (1)


Full Compliance

1. Records Review

Is all information, including trade secrets, available to those persons developing information for PSM?

2. Records Review

Do employees and their representatives have access to trade secret information contained within the process hazard analyses and all other PSM documentation?

3. Records Review

4. Records Review

5. Records Review


111

Trade Secrets Questions Comments/Findings/Recommendations29 CFR 1910.119

ReferenceFull

Compliance

Is trade secret information avilable to personnel developing incident investigations? (p) (1)

(p) (1)

Is trade secret information available to personnel developing compliance audits? (p) (1)

N/A

9. Interviews .119 (p) (1)

10. Interviews .119 (p) (3)

6. Records Review

7. Records Review

Is trade secret information available to personnel developing emergency planning and response?

8. Records Review

On-Site Conditions

Employees involved in specific duties: * Based on interviews with a representative number of employees involved in compiling the process safety information, developing PHAs, developing operating procedures, investigating incidents, planning and responding to emergencies, and auditing compliance, has all information necessary been provided to them without regard to possible trade secret status of such information?

Employees and Representatives: *Based on interviews with a representative number of employees and their designated representatives, do they have access to trade secret information contained within the PHA and other documents required to be developed by the standard? Note; This access is subject to the provisions set forth in 1910.1200 (l) (1)


112


Questions

1 40 CFR 68.10

2 40 CFR 68.10

3 40 CFR 68.10

4 Is the regulated substances used as a structural component of the stationary source? 40 CFR 68.10

5 Is the regulated substances used for the use of products for routine janitorial maintenance? 40 CFR 68.10

RMP Section 68.10:

Applicability40 CFR 68 Reference

Full Compliance

Has the threshold quantity of a regulated (listed in the Final List Rules/68.115) toxic substance been exceeded in a process on-site?

Is a regulated (listed in the final Rule/68. 115) flammable substance in a process on-site in a quanity greater than 10,000 lbs? (Process means any interconnected systems or systems where an event in one area could effect another area even where interconnection does not exist)

Is ammonia used as an agricultural nutrient by a farmer at the stationary source? If so, then the source is completely exempt from the RMP rule for the use of ammonia.


113

Questions

RMP Section 68.10:


Full Compliance

6 40 CFR 68.10

7 40 CFR 68.10

8 40 CFR 68.10

Is the regulated substances used by employees of foods, drugs, cosmetics, or other personel items containing the regulated substance?

Is the regulated substances used for the use of regulated substances present in process water or non-contact cooling water as drawn from the environment or municipal sources, or use of regulated substances present in air or part of combustion?

Has the owner or operator of the stationary source that has more than a threshold quantity of a regulated substance in a process complied with the requirements of this rule no later than the latest of the following dates: June 21,1999; Three years after the date on which a regulated substance is first listed under section 68.130; or The date on which a regulated substance is first present above a threshold quantity in prosess?


114



115



116


Questions 40 CFR 68 Reference Comments/Findings/Recommendations

1 40 CFR 68.10

2 40 CFR 68.10

3 40 CFR 68.10

RMP Section 68.10:

Program Level Screening

(Program 1)Full

Compliance

Does any of the covered processes on-site meet all of the requirments for the five years prior to the submission of an RMP? The process has not had an accidental release of a regulated substance where exposure to the substance, its reaction products, overpressure generated by an explosion involving the substance, or radiant heat generated by a fire involving the substance led to any of the following off-site: (i) Death; (ii) Injury; or (iii) Resonse or restoration activities for an exposure of an environmental receptor.

Do any of the covered processes on-site meet all of the requirements for the distance to a toxic or flammable endpoint for a worst-case release assessment is less than the distance to any public receptor?

Do any of the covered processes on-site meet all of the requirements for emergency response procedures that have been coordinated between the stationary source and local emergency planning and response organizations? (Evidence of coordination might be: meetings held between stationary source and the LEPC, the appointment of a stationary source emergency resoponse coordinator, submission of SARA Title lll data to the LEPC, mutual aid agreements between the stationary source and other local industries, local resonders, and the LEPC, etc. Although roads surrounding a stationary source need not be addressed as public receptors, they should not be considered when coordinating with emergency planners and responders.)


117



1 40 CFR 68.10

2 40 CFR 68.10

3 40 CFR 68.10

4 40 CFR 68.10

RMP Section 68.10: Program Level Screening

(Program 3)40 CFR 68 Reference

Full Compliance

Do any of the covered processes on-site meet any of the following requirments? The process is in SIC code 2611, 2812, 2819, 2821, 2865, 2869, 2873, 2879; or (The owner or operator must deternine the individual SIC code for each covered process to determine whether Program 3 applies. The assigned SIC code should reflect the activity of the process, and will not be the same as the source's overall primary SIC code.)

Do any of the covered processes on-site meet any of the following requirments? The process is subject to the OSHA process safety management standard, 29 CPR 1910.119. If any of the processes on-site can meet the program 3 criteria, list them in the Findings, Remarks, or other appropriate column of the audit worksheets.

Change in Program Level-- At any time has a covered process no longer meets the eligibility criteria of its program level?

Has the owner or operator complied with the requirements of the new Program level that applies to the process?


118



1 40 CFR 68.12

2 Did the RMP shall include a registration that reflects all covered processes? 40 CFR 68.12

RMP Section 68.12: General Requirements

40 CFR 68 Reference

Full Compliance

Regardless of Program level, has the owner or operator subject to this rule submitted a single RMP for all covered processes?


119



1 40 CFR 68.12

2 40 CFR 68.12

3 40 CFR 68.12

4 40 CFR 68.12

5 40 CFR 68.12

RMP Section 68.12: General Requirements (Program 1)

Full Compliance

Did the owner or operator of a stationary source with process(es) eligible for Program 1 accomplish all of the requirements for analyzing the worst-case scenario (WCS) for the Program 1 process(es)

Did the owner or operator of a stationary source with process(es) eligible for Program 1 accomplish all of the requirements documenting that the nearest public receptor is beyond the distance to a toxic or flammable endpoint?

Did the owner or operator of a stationary source with process(es) eligible for Program 1 accomplish all of the requirements submitting the WCS in the RMP?

Did the owner or operator of a stationary source with process(es) eligible for program 1 accomplish all of the requirements completing the five-year accident history for the Program 1 process(es) ?

Did the owner or operator of a stationary source with process (es) eligible for Program 1 accomplish all of the requirements submitting the five year accident history it in the RMP?


120


RMP Section 68.12: General Requirements (Program 1)

Full Compliance

6 40 CFR 68.12

7 40 CFR 68.12

8 Did the certification include the signature, title, and date? 40 CFR 68.12

Describe how emergency response actions have been coordinated with local emergency planning and response agencies in the RMP?

Did the owner or operator of a stationary source with process(es) eligible for Program 1 accomplish all of the requirements certifying the RMP with the following language? "Based in the criteria in 40 CRF 68.10, the distance to the specified endpoint for the worst-case accidental release scenario for the following process(es). Within the past five years, the process(es) has (have) had no accidental release that caused off-site impacts provided in the risk management program rule (40 CPR 68 .10 (b) (1). No additional measures are necessary to prevent off-site impacts from accidental releases. In the event of fire, explosion, or a release of a regulated substance from the process(es), entry within the distance to the specified endpoints may pose a danger to public emergency responders. Therefore, public emergency responders should not enter this area except as arranged with the emergency contact indicated in the RMP. The undersigned certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate, and complete."


121



1 40 CFR 68.12

2 40 CFR 68.12

3 40 CFR 68.12

4 40 CFR 68.12

5 40 CFR 68.12

RMP Section 68.12: General Requirements

(Program 3)Full

Compliance

Did the owner or operator of a stationary source with process(es) eligible for Program 2 accomplish all of the requirements to develop and implement a management system?

Did the owner or operator of a stationary source with process(es) eligible for Program 2 accomplish all of the requirements to conduct a hazard assessment?

Did the owner or operator of a stationary source with process(es) eligible for Program 2 accomplish all of the requirements to implement the program 3 prevention program elements?

Did the owner or operator of a stationary source with process(es) eligible for Program 2 accomplish all of the requirements to develop and implement an emergency response program?

Did the owner or operator of a stationary source with process(es) eligible for program 2 accomplish all of the requirements to submit as part of the RMP the data on prevention program elements for program 3 processes?


122



1 40 CFR 68.15

2 40 CFR 68.15

3 Are PSM and RMP managed concurrently using the same management system where appropriate? 40 CFR 68.15

4 40 CFR 68.15

5 40 CFR 68.15

RMP Section 68.15:

ManagementFull

Compliance

Has the owner or operator of a stationary source with processes subject to Program 2 or Program 3 developed a management system to oversee the implementation of the risk management program elements?

Are there established policies, procedures, programs and practices used to manage the implementation RMP within the organization?

Are formal written procedures to organize and structure requirements for each RMP prevention element and emergency?

Is there leadership for PSM in the organization (strong, effective, continuing, visible, momentum, organizational commitment and direction, reinforcement, rewards for performance, and champions)?


123


RMP Section 68.15:

ManagementFull

Compliance

6 40 CFR 68.15

7 40 CFR 68.15

8 Are the RMP prevention program/emergency response program elements intergrally managed? 40 CFR 68.15

9 40 CFR 68.15

10 40 CFR 68.15

11 Are there well-established lines of authority for each RMP element? 40 CFR 68.15

Is management committed to RMP (policy statement, all levels, communications with personnel, and communications with public)?

Are the boundries and interface within the elements of the RMP management system well-defined, intergrated, and free of gaps?

Is there a designation of responsibilty for the overall program and each element (clear, direct, and unambiguous)?

Are RMP assignments reinforced using-job descriptions, clear measures of job performance, and periodic performance appraisals?


124


RMP Section 68.15:

ManagementFull

Compliance

12 Is accountability established for the overall RMP program, and all its elements and sub-elements? 40 CFR 68.15

13 40 CFR 68.15

14 40 CFR 68.15

15 Are appropriate resourses allocated for RMP (personnel, financial, technical, tools, training, and time)? 40 CFR 68.15

16 Have RMP performance measures and goals been established? 40 CFR 68.15

17 Has the RMP management system been intergrated into the management of the company's operation? 40 CFR 68.15

Are RMP activities intergrated into the ongoing activities of everyone involved in operations (CEO to operators)?

Are there appropriate lines of communication between different parts of the organization that are responsible for RMP? Are they used? Are they effective?


125


RMP Section 68.15:

ManagementFull

Compliance

18 Is RMP part of the company culture? 40 CFR 68.15

19 Is process safety (RMP and PSM) consistently recognized as a priority by the company? 40 CFR 68.15

20 Do all involved parties understand how the RMP management system works? 40 CFR 68.15

21 40 CFR 68.15

22 40 CFR 68.15

23 40 CFR 68.15

Are procedures in place to maintain the RMP management system (process, organization and personnel changes)?

Has the owner or operator assigned a qualified person or position that has the overall responsibility for the development, implementation, and integration of how risk management program elements?

When responsibility for implementing individual requirments of this part is assigned to persons other than the person identified under paragraph (b) of this section, have the names or positions of these people been documented and the lines of authority defined through an organization chart or similar document?


126


Questions 40 CFR 68 Reference

1 40 CFR 68.20

2 40 CFR 68.20

3 40 CFR 68.20

RMP Section 68.20: Hazard Assement

ApplicabilityFull

Compliance

Did owner or operator of a stationary source subject to this rule, regardless of the Program level of the covered process(es) prepare a worst-case scenario (WCS) analysis?

Did owner or operator of a stationary source subject to this rule, regardless of the Program level of the covered process(es) complete a five-year accident history?

Did the owner or operator of a Program 2 and 3 process(es) also prepare alternative release scenarios (ARS)?


127



128



1 Did the off-site consequence analyses use the assumptions and data were the endpoints shall be used? 40 CFR 68.22

2 40 CFR 68.22

3 40 CFR 68.22

4 40 CFR 68.22

5 40 CFR 68.22

RMP Section 68.22: Off-site Consequence Analysis

Parameters

Full Compli

ance

Did the off-site consequence analyses use the assumptions and data where the toxic (the toxic endpoints provided in Appendix A of this rule) shall be used?

Did the off-site consequence analyses use the assumptions and data where the flammables shall be used? The endpoints for flammables vary according to the scenarios studied: *Explosion- and overpressure of 1psi; *Radiant heat/exposure time- a radiant heat of 5 kw/sq m for 40 seconds; *Lower flammability limit- a lower flammability limit- a lower flammability limit as provided in NFPA documents or other generally recongnized sources.

For the WCS (s), did the owner or operator use the following wind speed and atmospheris stability parameters? *Wind speed of 1.5 meters per second; and, *"F" atmosphere stability class; or, * If the owner or operator can demonstrate that local meteorological data applicable to the stationary source show a higher minimum wind speed or less stable atmoshphere at all times during the previous three years, these minimums may be used.

For the ARS (s), did the owner or operator use the typical meteorological conditions for the stationary source?


129



Parameters

Full Compli

ance

6 40 CFR 68.22

7 40 CFR 68.22

8 For the WCS (s), did the owner or operator use assume a release at ground level ((o feet) release? 40 CFR 68.22

9 For the ARS (s), did the owner or operator use a release height determined by the release scenario? 40 CFR 68.22

10 40 CFR 68.22

11 40 CFR 68.22

For the WCS (s), did the owner or operator use the following ambient temperature and humidty parameters? *Highest daily maxium temperture in the previous three years and average humidity for the site, based on temperature in the previous three years and average humidy for the site, based on temperature/humidity data gathered at the stationary source or at a local meterological statioin; or, *25 deg C and 50 percent humidity if the EPA's RMP off -site Consequence Analysis Guidellines were used.

For the ARS (s), did the owner or operator use typical temperature/humidity data gathered at the stationary source or at a local meteorological station?

For the WCS (s) and ARS (s), did the owner or operator use either urban or rural topography, as appropriate? (Urban means that there are many obstacles in the immediate area; and the terrain is generally flat and unobstructed.)

For the WCS(s) and ARS(s) , of toxic substances, did the owner or operator use dense or neutrally buoyant gases modeling techniques as appropriate to the nature of the substance being released? (Tablets or models used for dispersion analysis of toxic substances should account for gas density.)


130



Parameters

Full Compli

ance

12 40 CFR 68.22

13 40 CFR 68.22

For the WCS(s) did the owner or operator assume that liquids (other than gases liguefied by refrigeration only) are considered to be released at the highest daily maximum temperature, based on data for the previous three years appropriate for the stationary source, or at process temperature, whichever is higher?

For the ARS (s), did the owner or operator assume that the substance is released at a process or ambient temperature that is appropriate for the scenario?


131



132



133



134



1 40 CFR 68.25

2 40 CFR 68.25

3 40 CFR 68.25

4 40 CFR 68.25

5 40 CFR 68.25

RMP Section 68.25: Worst Case Release Scenario Analysis

Full Compli

ance

Did the owner or operator analyze and report in the RMP the numbers of WCS (s) for Program 1 processes ,one WCS for each Program 1 process?

Did the owner or operator anlayze and report in the RMP the numbers of WCS (s) for Program 2 and 3 processes: *one worst-case release scenario for the one regulated toxic substance that is estimated to create the greatest distance in any direction to an endpoint provided in Appendix A;and, *one worst-case release scenario for the one regulated flammable substance that is estimated to create the greastest distance in any directiion to an endpoint; and, *additional worst-case release scenarios for a hazard class if a worst-case release from another covered process at the stationary source potentially affects public receptors different from those potentially affected by the worst-case release scenario developed under paragraphs (l) or (ii) above?

Were the releases quantities for WCS (s) defined as the greater for substance in a vessel, the greatest amount held in a single vessel, taking into account administrative controls that limit the maximum quantity?

Were the releases quantities for WCS(s) defined as the greater for substance in pipes, the greatest amount in a pipe, taking into account administrative controls that limit the maximum quantity?

Were the release rates for the WCS(s) of toxic gases determined for regulated toxic substances that are normally gases at ambient temperature and handled as a liquid under pressure, the quantity in the vessel or pipe is released as a gas over 10 minutes? The release rate shall be assumed to be the total quanity divided by 10 unless passive mitigation systems are in place.


135



Full Compli

ance

6 40 CFR 68.25

7 40 CFR 68.25

8 40 CFR 68.25

9 40 CFR 68.25

10 40 CFR 68.25

11 40 CFR 68.25

Were the release rates for the WCS(s) of toxic gases determined for gases handled as refrigerated liquids at ambient pressure? *If the releases substance is not contained by passive mitigation systems or if the contained pool would have a dept of 1 cm or less, the substance is assumed to be released as a gas in 10 minutes; *If the released substance is contained by passive mitigation systems in a pool with a depth greater than 1 cm, the release assumed to be spilled instantaneously to form a liquid pool. The volatilization rate (release rate) shall be calculated at the boiling point of the substance and at the other conditions specified.

Were the release rates for the WCS(s) of toxic gases determined for toxic substances that are normally liquids at ambient temperature, the quantity in the vessel or pipe is assumed to be spilled instantaneously to form a liquid pool? *The surface area of the pool shall be determined by assuming that the liquid spreads to 1 centimeter deep unless passive mitigation systems are in place that serve to contain the spill and limit the surface area. Where passive mitigation is in place, the surface area of the contained liquid shall be used to calculate the volatilization rate; *If the release would occur onto a surface that is not paved or smooth, the analysis may take into account the actual surface characteristics.

Were the release rates for the WCS(s) of toxic gases determined for the volatilization rate that accounts for the highest daily maximum temperature occuring in the past three years, the temperature of the substance in the vessel, and the concentratiion of the substance if the liquid spilled is a mixture or solution?

Were the release rates for the WCS(s) of toxic gases determined for the rate of release to air to be determined from the volatilization rate of the liquid pool? The EPA'S RMP Off-site Consequence Analysis Guidance or any other publicly available techniques that account for the modeling conditions and are recognized by industry as applicable as part of current practices may be used. (Proprietary models that account for the modeling conditions may be used provided the owner or operator allows the implementing agency access to the model and describes model features and differences from publicly available models to local emergency planners upon request.)

Were the release rates for the WCS(s) of flammabled determined as the owner or operator assumed that the quantity of the substance vaporizes resulting in a vapor cloud explosion?

Were the release rates for the WCS(s) of flammables determined as yield factor of 10 percent of the available energy released in the explosion shall be used to determine the distance to the explosion endpoint if the model used is based on TNT- equivalent methods?


136



Full Compli

ance

12 40 CFR 68.25

13 40 CFR 68.25

14 40 CFR 68.25

15 40 CFR 68.25

Were the parameters and assumptions made in the WCS(s) analysis of the methodology provided in the RMP OFF-SITE Consequence Analysis Guidance?

Were the parameters and assumptions made in the WCs(s) analysis of any commercially or publicly available air dispersion modeling techniques, provided the techniques account for the modeling conditions and are recognized by industry as applicable as part of current practices? (Proprietary models that account for the modeling conditions may be used provided the owner or operator allows the implementing agency access to the model and describes model features and differences from publicly available models to local emergency planners upon request.)

Were the parameters and assumptions made in the WCS(s) analysis for passive mitigation systems that may be considered for the analysis of worst case provided that the mitigation system is capable of withstanding the release event triggering the scenario and would still function as intended?

Were the other factors accounted for in selecting the WCS(s)? Notwithstanding the previous requirements for WCS quantities, the owner or operator shall select as the WCS for flammable or toxic substances, a scenario based on the following factors if such a scenario would result in a greater distance to an endpoint than the scenario based solely on maximum quantity in a vessel or pipe: * Smaller quantities handled at higher process temperature or pressure; and, * Proximity to the boundary of the stationary source.


137



138



139



140



1 40 CFR 68.28

2 40 CFR 68.28

3 40 CFR 68.28

4 40 CFR 68.28

5 40 CFR 68.28

RMP Section 68.28: Alternate Case Release

Scenario Analysis40 CFR 68 Reference

Full Compliance

Did the owner or operator identify and analyze the number of ARS(s) with at least one alternative release scenario for each regulated toxic substance held in a covered process(es)?

Did the owner or operator identify and analyze the number of ARS(s) with at least one aleternative release scenario to represent all flammable substances held in covered processes?

For each toxic and flammable ARS, required, did the owner or operator select scenarios based on the criteria that is more likely to occur than the WCS?

For each toxic and flammable ARS, required did the owner or operator select scenarios based on th criteria that will reach an endpoint off-site, unless no such scenario exist.

Did the ARS(s) include, but were not limited to, the types of events where applicable: * Transfer hose releases due to splits or sudden hose uncoupling?


141




Full Compliance

6 40 CFR 68.28

7 40 CFR 68.28

8 40 CFR 68.28

9 40 CFR 68.28

10 40 CFR 68.28

11 40 CFR 68.28

Did the ARS(s) include, but were not limited to, the types of events where applicable: * Process piping releases from failures at flanges, joints, welds, valves and seals, and drains or bleeds?

Did the ARS(s) include, but were not limited to, the types of events where applicable: *Process vessel or pump releases due to cracks, seal failure, or drain, bleed, or plug failure?

Did the ARS(s) include, but were not limited to, the types of events where applicable: * Vessel overfilling and spill, or overpressurization and venting through relief valves or rupture disks?

Did the ARS9s) include, but were not limited to, the types of events where applicable: * Shipping container mishandling and breakage or puncturing leading to a spill?

Were the parameters and assumptions made in the ARS(s) analysis by the same analysis parameters used in the WCS(s) used for the ARS(s)?

Were the parameters and assumptions made in the ARS(s) analysis by the methodology provided in the RMP off-site Consequence Analysis Guideance or any commercially or publicly available air dispersion modeling techniques, provided the techniques account for the specified modeling conditions and are recognnized by industry as applicable as part of current practices? (Proprietary models that account for the modeling conditions may be used provided the owner or operator allows the implementing agency access to the model and describes model features and differences from publicly available models to local emergency planners upon request).


142




Full Compliance

12 40 CFR 68.28

13 Were sources considered in selecting alternative release scenarios for the five-year accident history? 40 CFR 68.28

14 40 CFR 68.28

Were the parameters and assumptions made in the ARS(s) analysis by active and passive mitigation systems that may be considered provided they are capable of withstanding the event that triggered the release and would still be functional?

Were sources considered in selecting alternative release scenarios for the failed scenarios identified in the process hazard analysis (program3) or the hazard review (program 2)?


143



1 40 CFR 68.30

2 Did the population include the residental population? 40 CFR 68.30

3 40 CFR 68.30

4 40 CFR 68.30

5 Was the population data estimated to two significant digits? 40 CFR 68.30

RMP Section 68.30: Defining Off Site

Impacts - Population40 CFR 68 Reference

Full Compliance

Did the owner or operator estimate in the RMP the population within a circle with its center at the point of the release and a radius determined by the distance to the endpoint?

Was the most presence of institutions (schools, hospitals, prisons), parks and recreational areas, and major commercial, office, and industrial buildings noted in the RMP?

Was the most recent Census data or other updated information, used to estimate the population potentially affected?


144



1 40 CFR 68.33

2 40 CFR 68.33

RMP Section 68.33: Defining Off Site

Impacts - Environmental

40 CFR 68 Reference

Full Compliance

Did the owner or operator list in the Rmp environmental receptors within a circle with its center at the point of the release and a radius determined by the distance to the endpoint?

Were local U.S Geological Survey maps or on any data source containing USGS data used to identify environmental receptors?


145


Questions Full Compliance Comments/Findings/Recommendations

1 40 CFR 68.36

2 40 CFR 68.36

3 40 CFR 68.36

RMP Section 68.36: Hazard Assement Review

and Update40 CFR 68 Reference

Did the owner or operator review and update the off-site consequence analyses at least once every five years?

If changes in processes, quantities stored or handled, or any other aspect of the stationary source might reasonably be expected to increase or decrease the distance to the endpoint by a factor of two or more, did the owner or operator complete a revised analysis within six months of the change?

If changes a processes, quantities stored or handled, or any other aspect of the stationary source might reasonably be expected to increase or decrease the distance to the endpoint by a factor of two or more, did the owner or operator submit a revised risk management plan?


146



1 40 CFR 68.39

2 40 CFR 68.39

3 40 CFR 68.39

4 40 CFR 68.39

5 40 CFR 68.39

RMP Section 68.39: Hazard Assement Documentation

Full Compli

ance

Did the owner or operator maintain the records on the off-site consequence analyses for worst-case scenarios, a description of the vessel or pipeline and substance selected as worst case, assumptions and parameters used, and the rationale for selection; assumptions shall include use of any administrative controls and any passive mitigation that were assumed to limit the quantity that could be released? Documention shall include the anticipated effect of the controls and mitigation on the release quantity and rate.

Did the owner or operator maintain the records on the off-site consequence analyses for alternative release scenarios identified, assumptions and parameters used, and the rationale for the selection of specific scenarios; assumptions shall include use of any administrate controls and any mitgation that were assumed to limit the quantity that could be released? Documentation shall include the effect of the controls and mitigation on the release quantity and rate.

Did the owner or operator maintain the records on the off-site consequence analyses for WCS(s) and ARS(s), documentation of estimated quantity released, release rate, and duration of release?

Did the owner or operator maintain the records on the off-site consequence analyses for methodology used to determine distance to endpoints?

Did the owner or operator maintain the records on the off-site consequence analyses for data used to estimate population and environmental receptors potentially affected?


147


Questions

1 40 CFR 68.42

2 40 CFR 68.42

3 40 CFR 68.42

4 40 CFR 68.42

5 40 CFR 68.42

RMP Section 68.42: Five Year Accident

History40 CFR 68 Reference

Full Compliance

Did the owner or operator include in the five-year accident history all accidental releases from covered processes that resulted in on-site or off-site deaths? (The five year period is measured backwards from the date of the RMP submittal.)

Did the owner or operator include in the five-year accident history all accidental releases from covered processes that resulted in on-site or off-site injuries?

Did the owner or operator include in the five-year accidental history all accidental releases from covered processes that resulted in significant on-site injuries?

Did the owner or operator include in the five-year accident history all accidental releases from covered processes that resulted in property damage off-site?

Did the owner or operator include in the five-year accident history all accidental releases from covered processes that resulted in evacuations?


148

Questions



Full Compliance

6 40 CFR 68.42

7 40 CFR 68.42

8 40 CFR 68.42

9 40 CFR 68.42

10 For each accidental release included, did the owner or operator report the chemical(s) released? 40 CFR 68.42

11 40 CFR 68.42

Did the owner or operation include in the five-year accident history all accidental- releases from covered processes that resulted in sheltering in place?

Did the owner or operator include in the five-year accident history all accidental releases from covered processes that resulted in property damage?

Did the owner or operator include in the five-year accident history all accidental releases from covered processes that resulted in environmental damage?

For each accidental release included, did the owner or operator report the date, time, and approximate duration of the release?

For each accidental release included, did the owner or operator report the estimated quantity released in pounds?


149

Questions



Full Compliance

12 40 CFR 68.42

13 40 CFR 68.42

14 For each accidental release included, did the owner or operator report the on-site impacts? 40 CFR 68.42

15 40 CFR 68.42

16 40 CFR 68.42

17 40 CFR 68.42

For each accidental release included, did the owner or operator report the type of release event and its source?

For each accidental release included, did the owner or operator report the weather conditions, if known?

For each accidental release included, did the owner or operator report the known off-site impacts?

For each accidental release included, did the owner or operator report whether off-site responders were notified if known?

For each accidental release included, did the owner or operator report whether off-site responders were notified if known?


150

Questions



Full Compliance

18 40 CFR 68.42

19 Were numerical estimates in the five-year accident history provided to two significant digits? 40 CFR 68.42

For each accidental release included, did the owner or operator report the operational or process changes that resulted from the investigation of the release?


151



152



153



154



155


Questions

1 40 CFR 68.67

2 40 CFR 68.67

3 40 CFR 68.67

4 40 CFR 68.67

5 40 CFR 68.67

RMP Section 68.67: Process Hazard

Analysis40 CFR 68 Reference

Full Compliance

Has the owner or operator performed an initial process hazard analysis (PHA) as soon as possible, but not later than June 21,1999?

Have PHAs been completed to comply with 29 CRF 1910.119 (e), including revalidations of the PSM PHAs used to satisfy the RMP requirement for an PHA? If so, annotate the audit worksheets to reflect that fact.

Have the initial RMP PHAs accounted for the consequences identified and listed in the initial PHA reflect off-site consequences?

Have the initial RMP PHAs accounted for the safeguards (engineering and administrative controls) listed in the initial PHA include those safeguards applicable to off-site impacts?

Have the initial RMP PHAs accounted for the facility sitting analysis in the initial PHA reflect the spatial relationship between the location of the hazards in the process and off-site public and environmental receptors?


156

Questions

RMP Section 68.67: Process Hazard

Analysis40 CFR 68 Reference

Full Compliance

6 40 CFR 68.67

Is there any indication in the PHA report that the PHA team has examined issues (especially changes made since the PSM program was started) that would tend to make on-site risk less but increase off-site risk? (Example: PSV discharges have been routed father away from the locations of on-site workers but closer to the property boundary.)


157



158



159


Questions

1 40 CFR 68.90

2 40 CFR 68.90

3 40 CFR 68.90

4 40 CFR 68.90

RMP Section 68.90: Emergency Response


Full Compliance

If the employees at the stationary source will respond to acciedental releases of regulated substances, and the stationary source has program 2 and program 3 processes, does a written emergency response plan exist?

If the employees at the stationary source will not respond to accidental releases of regulated substances, does the condition exist for stationary sources with any regulated toxic substance held in a process above the threshold quanity? The stationary source is included in the community emergency response plan developed under 42 U.S.C. 11003.

If the employees at the stationary source will not respond to accidental releases of regulated substances, does the condition exist for stationary sources with only regulated flammable substances held in a process above the threshold quanity, the owner or operator has coordinated response actions with the local fire department?

If the employees at the statiionary source will not respond to accidental releases of regulated substances, does the condition exist that appropriate mechanisms are in place to notify emergency responders when there is a need for a response? If all of applicable conditions exist, an emergency response program for RMP is not required.


160



161



1 40 CFR 68.95

2 40 CFR 68.95

3 40 CFR 68.95

4 Does the ERP include training for all employees in relevant procedures? 40 CFR 68.95

5 40 CFR 68.95


Program40 CFR 68 Reference

Full Compliance

Has the owner or operator developed and implemented an emergency response program (ERP) for the purpose fo protecting public health and the environment?

Does the ERP include an emergency response plan, which shall be maintained at the stationary source and contain at least the following elements: * Procedures for informing the public and local emergency response agencies about accidental releases: * Documentation of proper first-aid and emergency medical treatment necessary to treat accidental human exposures; and, * Procedures and measures for emergency response after an accidental release of a regulated substance?

Does the ERP include procedures for the use of emergency response equipment and for its inspection, testing, and maintenance?

Does the ERP include procedures to review and update, as appropriate, the emergency response plan to reflect changes at the stationary source and ensure that employees are informed of changes?


162



Program40 CFR 68 Reference

Full Compliance

6 40 CFR 68.95

7 40 CFR 68.95

8 40 CFR 68.95

9 40 CFR 68.95

10 40 CFR 68.95

Does the written plan comply with other Federal contingency plan regulations? If so, list the federal regulations that the ERP is intended to satisfy in the audit worksheets.

Does the ERP that is intended to satisfy the other federal regulations contain all of the element required above?

Is the ERP consistent with the approach in the National Response Team's Integrated Contingency Plan Guidance ("one Plan")? If so, also apply an appropriate protocol for assessing the ERP with respect to the ICP Guidance.

Does the ERP that is intended to satisfy the ICP/ "One Plan" guidance contain all of the elements required above?

Is the emergency response plan coordinated with the community emergency response plan developed under 42 U.S.C. 11003 (SARA Title lll)? (upon request of the local emergency planning committee or emergency response officials, the owner or operator shall promptly provide to the local emergency response officials information necessary for developing and implementing the community emergency response plan.)


163



1 40 CFR 68.150

2 Was the RMP submitted in the method and format specified by EPA prior to June 21,1999? 40 CFR 68.150

3 Was the RMP submitted to the central point specified by EPA prior to June 21,1999? 40 CFR 68.150

4 40 CFR 68.150

5 40 CFR 68.150

RMP Section 68.150: RMP Submission

40 CFR 68 Reference

Full Compliance

Did the owner or operator submit a single RMP that includes the information for all covered processes?

Has the owner or operator submitted the first RMP no later than the latest of the following dates: *June 21,1999; * three years after the date on which a regulated substance is first listed under Section 68.130; or, * the date on which a regulated substance is first present above a threshold quantity in a process?

Did the owner or operator exclude classified information from the RMP? (Classified imformation means "classified information" as defined in the classified information Procedures Act, 18 U.S.C. App. 3, section 1 (a) as "any information or material that has been determined by the United States Goverment pursuant to an executive order, statute, or regulation, to require protection against unauthorized disclosure for reasons of national security.")


164

Questions Comments/Findings/RecommendationsRMP Section 68.150:

RMP Submission40 CFR 68 Reference

Full Compliance

6 40 CFR 68.150If applicable, has classified information been made available in a classified annex to the RMP for review by Federal and state representatives who have received the appropriate clearances?


165



1 40 CFR 68.155

2 40 CFR 68.155

3 40 CFR 68.155

4 40 CFR 68.155

5 40 CFR 68.155

RMP Section 68.155: RMP Executive

Summary40 CFR 68 Reference

Full Compliance

Did the owner or operator provide in the RMP an executive summary that includes a brief description of the accidental release prevention and emergency response policies at the stationary source?

Did the owner or operator provide in the RMP an executive summary that includes a brief description of the stationary source and regulated substances handled?

Did the owner or operator provide in the RMP an executive that includes a brief description of the worst-case release scenario(s) and the alternative release scenario(s), including administrative controls and mitigation measures to limit the distance for each reported scenario?

Did the owner or operator provide in the RMP an executive summary that includes a brief description of the general accidental release prevention program and chemical- specific prevention steps?

Did the owner or operator provide in the RMP an executive summary that included a brief description of the five year accident history?


166


RMP Section 68.155: RMP Executive

Summary40 CFR 68 Reference

Full Compliance

6 40 CFR 68.155

7 40 CFR 68.155

Did the owner or operator provide in the RMP an executive summary that includes a brief description of the emergency response program?

Did the owner or operator provide in the RMP an executive summary that includes a brief description of the planned changes to improve safety?


167



1 Did the owner or operator complete a single registration form and include it in the RMP? 40 CFR 68.160

2 Did the registration form cover all regulated substances handled in covered processes? 40 CFR 68.160

3 40 CFR 68.160

4 40 CFR 68.160

5 Did the registration include the name and Dun and Bradstreet number of the corporate company? 40 CFR 68.160

RMP Section 68.160: RMP Registration

40 CFR 68 Reference

Full Compliance

Did the registration include the stationary source name, street, city, county, state, zip code, latitude, and longitude?

Did the registration include the stationary source Dun and Bradsteet number of the corporate parent company?


168


RMP Registration40 CFR 68 Reference

Full Compliance

6 40 CFR 68.160

7 40 CFR 68.160

8 40 CFR 68.160

9 40 CFR 68.160

10 Did the registration include the stationary source EPA identifer? 40 CFR 68.160

11 Did the registration include the number of full-time employees at the stationary source? 40 CFR 68.160

Did the registration include the name , telephone number, and mailling address of the owner or operator?

Did the registration include the name and title of the person or position with overall responsibility for RMP elements and implementation?

Did the registration include the name, title, telephone number, and 24-hour telephone number of the emergency contact?

Did the registration include for each covered process, the name and CAS number of each regulated substance held above the threshold quantity in the process, the maximum quantity of each regulated substance or mixture in the process (in pounds) to two significant digits, the SIC code, and the Program level of the process?


169


RMP Registration40 CFR 68 Reference

Full Compliance

12 Did the registration include whether the stationary source is subject to 29 CFR 1910.119? 40 CFR 68.160

13 Did the registration include whether the stationary source is subject to 40 CFR part 355? 40 CFR 68.160

14 Did the registration include whether the stationary source has a CAA Title V operating permit? 40 CFR 68.160

15 40 CFR 68.160Did the registration include the date of the last safety inspection of the stationary source by a Federal, state, or local government agency and the identity of the inspecting entity?


170



1 40 CFR 68.165

2 40 CFR 68.165

3 40 CFR 68.165

4 40 CFR 68.165

5 Did the owner or operator submit the chemical name? 40 CFR 68.165

RMP Section 68.165: RMP Off Site

Consequence Analysis40 CFR 68 Reference

Full Compliance

Did the owner or operator submit in the RMP information, one worst-case scenario for each program 1 process?

Did the owner or operator submit in the RMP information, for Program 2 and 3 processes? One WCS to represent all regulated toxic substances held above the threshold quantity and one WCS to represent all regulated flammable substances held above the threshold quantity.

Did the owner or operator submit in the RMP information for Program 2 and 3 processes? If additional WCSs for toxics or flammables are required, the owner or operator shall submit the same information on the additional WCSs.

Did the owner or operator submit in the RMP information for Program 2 and 3 processes? Information on ARS for each toxic substance held above the threshold quantity and one ARS to represent all regulated flammable substances held above the threshold quantity.


171




Full Compliance

6 Did the owner or operator submit the physical state (toxic only)? 40 CFR 68.165

7 Did the owner or operator submit the basis of results (give model name if used)? 40 CFR 68.165

8 40 CFR 68.165

9 Did the owner or operator submit the quantity released in pounds? 40 CFR 68.165

10 Did the owner or operator submit the release rate? 40 CFR 68.165

11 Did the owner or operator submit the release duration? 40 CFR 68.165

Did the owner or operator submit the scenario (explosion, fire, toxic gas release, or liquid spill and vaporization)?


172




Full Compliance

12 40 CFR 68.165

13 Did the owner or operator submit the topography (toxic only)? 40 CFR 68.165

14 Did the owner or operator submit the distance to endpoint? 40 CFR 68.165

15 40 CFR 68.165

16 Did the owner or operator submit the passive mitigation considered? 40 CFR 68.165

17 40 CFR 68.165

Did the owner or operator submit the wind speed and atmospheric stability class (toxic only)?

Did the owner or operator submit the public and environmental receptors within the distance?

Did the owner or operator submit the active mitigation considered (alternative releases only)?


173



1 40 CFR 68.168

2 40 CFR 68.168

3 40 CFR 68.168

4 40 CFR 68.168

5 40 CFR 68.168

RMP Section 68.168: RMP Five Year Accident


Full Compliance

Did the owner or operator submit in the RMP the following information for each in the five year accident history?

For each accidental release included,did the owner or operator report the date, time, and approximate duration of the release?

For each accidental release included, did the owner or operator report the chemical(s) released?

For each accidental release included, did the owner or operator report the estimated quantity released in pounds?

For each accidental release included, did the owner or operator report the type of release event and its source?


174


RMP Section 68.168: RMP Five Year Accident


Full Compliance

6 40 CFR 68.168

7 For each accidental release included, did the owner or operator report the on-site impacts? 40 CFR 68.168

8 40 CFR 68.168

9 40 CFR 68.168

10 40 CFR 68.168

11 40 CFR 68.168

For each accidental release included ,did the owner or operator report the weather conditions, if known?

For each accidental release included, did the owner or operator report the known off-site impacts?

For each accidental release included, did the owner or operator report the initiating event and contributing factors if known?

For each accidental release included, did the owner or operator report whether-off -site responders were notified if known?

For each accidental release included, did the owner or operator report the operational or process changes that resulted from investigation of the release?


175



1 For each Program 3 process, did the owner or operator provide the SIC code for the process? 40 CFR 68.175

2 40 CFR 68.175

3 40 CFR 68.175

4 40 CFR 68.175

5 40 CFR 68.175

RMP Section 68.175: RMP Prevention Program

340 CFR 68 Reference

Full Compliance

For each Program 3 process, did the owner or operator provide the names(s) of the substance covered?

For each Program 3 process did the owner or operator provide the date on which the safety information was last reviewed or revised?

For each Program 3 process, did the owner or operator provide the date of completion of the most recent PHA or update and the technique used?

For each Program 3 process, did the owner or operator provide the expected date of completion of any changes resulting from the PHA?


176




Full Compliance

6 For each Program 3 process, did the owner or operator provide the major hazards identified? 40 CFR 68.175

7 For each Program 3 process, did the owner or operator provide the process controls in use? 40 CFR 68.175

8 For each Program 3 process, did the owner or operator provide the mitigation systems in use? 40 CFR 68.175

9 40 CFR 68.175

10 40 CFR 68.175

11 40 CFR 68.175

For each Program 3 process, did the owner or operator provide the monitoring and detection systems in use?

For each Program 3 process, did the owner or operator provide the changes since the last PHA?

For each Program 3 process did the owner or operator provide the date of the most recent review or revision of operating procedures?


177




Full Compliance

12 40 CFR 68.175

13 40 CFR 68.175

14 40 CFR 68.175

15 40 CFR 68.175

16 40 CFR 68.175

17 40 CFR 68.175

For each Program 3 process, did the owner or operator provide the date of completion of the most recent review or revision of training programs?

For each Program 3 process, did the owner or operator provide the type of training provided-classroom, classroom plus on the job, on the job?

For each Program 3 process, did the owner or operator provide the type of competency testing used?

For each Program 3 process, did the owner or operator provide the date of the most recent review or revision of maintenance procedures and the date of the most recent equipment inspection or test and the equipment inspected or tested?

For each Program 3 process, did the owner or operator provide the date of the most recent change that triggered management of change procedures and the date of the most recent review or revision of management of change procedures?

For each Program 3 process, did the owner or operator provide the date of the most recent pre-startup review?


178




Full Compliance

18 40 CFR 68.175

19 40 CFR 68.175

20 40 CFR 68.175

21 40 CFR 68.175

22 40 CFR 68.175

23 40 CFR 68.175

For each Program 3 process, did the owner or operator provide the date of the most recent compliance audit and the expected date of completion of any changes resulting from the compliance audit?

For each Program 3 process, did the owner or operator provide the date of the most recent incident investigation and the expected date of completion of any changes resulting from the investigation?

For each Program 3 process, did the owner or operator provide the date of the most recent incident investigation and the expected date of completion of any changes resulting from the investigation?

For each Program 3 process, did the owner or operator provide the date of the most recent review or revision of employee participation plans?

For each Program 3 process, did the owner or operator provide the date of the most recent review or revision of hot work permit procedures?

For each Program 3 process, did the owner or operator provide the date of the most recent review or revision of contractor safety procedures?


179




Full Compliance

24 40 CFR 68.175

25 40 CFR 68.175

For each Program 3 process, did the owner or operator provide the date of the most recent evaluation of contractor safety performance?

If the same information applies to more than one covered process, did the owner or operator provide the information only once, but indicate to which processes the information applies?


180


Questions Full Compliance

1 40 CFR 68.180

2 40 CFR 68.180

3 40 CFR 68.180

4 40 CFR 68.180

5 40 CFR 68.180

RMP Section 68.180: RMP Emergency

Response Program40 CFR 68 Reference

Did the owner or operator provide in the RMP the following information: do you have a written emetgency response plan?

Did the owner or operator provide in the RMP the following information: does the plan include specific actions to be taken in response to an accidental release of a regulated substance?

Did the owner or operator provide in the RMP the following information: does the plan include procedures for informing the public and local agencies responsible for responding to accidental releases?

Did the owner or operator provide in the RMP the following information: does the plan include information on emergency health care?

Did the owner or operator provide in the RMP the following information: the date of the most recent review or update of the emergency response plan?


181

Questions Full Compliance

RMP Section 68.180: RMP Emergency

Response Program40 CFR 68 Reference

6 40 CFR 68.180

7 40 CFR 68.180

8 40 CFR 68.180

Did the owner or operator provide in the RMP the following information: the date of the most recent emergency response training for employees?

Did the owner or operator provide the name and telephone number of the local agency with the plan is coordinated?

Did the owner or operator list other Federal or state emergency plan requirements to which the stationary source is subject?


182



183



184



1 40 CFR 68.185

2 40 CFR 68.185

RMP Section 68.185: RMP Certification

40 CFR 68 Reference

Full Compliance

For Program 1 processes, did the owner or operator submit in the RMP, the requested certification statement?

For all other covered processes, did the owner or operator submit in the RMP a single certification that, to the best of the signer's knowledge, information, and belief formed after reasonable inquiry, the information submitted is true, accurate and complete?


185



1 40 CFR 68.190

2 40 CFR 68.190

3 40 CFR 68.190

4 40 CFR 68.190

5 40 CFR 68.190

RMP Section 68.190: RMP Updates

40 CFR 68 Reference

Full Compliance

Did the owner or operator review and update the RMP and submit it in a method and format to a central point specified by EBA prior to June 21, 1999?

Did the owner or operator of a stationary source revise and update the RMP within five years of its initial submission or most recent update required by paragraphs (b) (2) through (b) (7) of this section, whichever is later?

Did the owner or operator of a stationary source revise and update the RMP no later than three years after a newly regulated substance is first listed by EBA?

Did the owner or operator of a stationary source revise and update the RMP no later than the date on which a regulated substance is first present in in an already covered process above a threshold quantity?

Did the owner or operator of a stationary source revise and update the RMP no later than the date on which a regulated substance is first present above a threshold quantity in a new process?


186


RMP Updates40 CFR 68 Reference

Full Compliance

6 40 CFR 68.190

7 40 CFR 68.190

8 40 CFR 68.190

9 40 CFR 68.190

Did the owner or operator of a stationary source revise and update the RMP within six months of a change that requires a revised PHA or hazard review?

Did the owner or operator of a stationary source revise and update the RMP within six months of a change that requires a revised off-site consequence analysis as provided in Section 68.36?

Did the owner or operator of a stationary source revise and update the RMP within Six months of a change that alters the Program level that applied to any covered process?

If a stationary source is no longer subject to this part, did the owner or operator submit a revised registration to EBA within six months indicating that the stationary source is no longer covered?


187



1 40 CFR 68.200

2 Has the owner or operator made the RMP available to the public? 40 CFR 68.200

RMP Section 68.200: RMP Recordkeeping

40 CFR 68 Reference

Full Compliance

Has the owner or operator maintained records, supporting the implementation of the RMP rule for five years (except for special recordkeeping requirements in the Program 3 prevention program)?


188


Questions

1 40 CFR 68.220

2 40 CFR 68.220

3 40 CFR 68.220

4 Do such explanations include substitute revisions? 40 CFR 68.220

5 40 CFR 68.220

6 Has the owner or operator updated theRMP? 40 CFR 68.220

RMP Section 68.220: RMP Audits

40 CFR 68 Reference

Full Compliance

Has the owner or operator responded in writing to a preliminary determination made during an implementing agency audit of its submitted RMP?

Does the response state that the owner or operator will implement the revisions contained in the preliminary determinination in accordance with the timetable included in the preliminary determination or shall state that the owner or operator rejects the revisions in whole or in part?

For each rejected revision, did the owner or operator explain the basis for rejecting such revision?

Has the owner or operator revised the RMP as required by the final determination by the implementing agency within 30 days, and submitted the revised RMP?


189

QuestionsRMP Section 68.220:

RMP Audits40 CFR 68 Reference

Full Compliance

7 40 CFR 68.220

8 40 CFR 68.220

Following the determination of Program level for each process, the following audit questions should be applied depending for each Program level: program1: 68. 12, 68, 20, 68.22, 68.25, 68.30, 68.6, 68.39, 68.42, 68. 150, 68.155, 68. 160, 68. 165, 68. 168, all of Subpart H (68.200-68.220).

Following the determination of Program level for each process, the following audit questions should be applied depending for each Program level: program 3: 68. 12, 68. 15, all of the subpartB (68.20-68.42), all of Subpart D (68.65-68.87). All of Subpart E(68.90-68.95),68.150,68.155, 68.160, 68.175, 68.180, 68.185, 68.190, all of Subpart H (68.200-68.220).


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191


Blank PSM & RMP Audit Form

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Transcript of Blank PSM & RMP Audit Form