Hazard ID & Risk Assessment - symbllc.com Assessment.pdf · Hazard ID & Risk Assessment (HIRA)...
Transcript of Hazard ID & Risk Assessment - symbllc.com Assessment.pdf · Hazard ID & Risk Assessment (HIRA)...
Prepared August 2010
On Behalf of CLIENT
Hazard ID & Risk Assessment Workplace Safety Evaluation & Analysis
Allen D. H. Blanchard
(713) 471-7273
www.symbllc.com
Hazard ID & Risk Assessment (HIRA) Client
Allen D. H. Blanchard 2
Table of Contents
1.0 Introduction ...........................................................................................................................3 2.0 Methodology ..........................................................................................................................3 3.0 Process and Material Review ...................................................................................................4
3.1 Materials ....................................................................................................................................... 4
3.2 Processes ....................................................................................................................................... 4
3.3 Hazardous Chemicals .................................................................................................................... 5
4.0 Site Inspection and Work Observations ...................................................................................6
4.1 Site Inspection ............................................................................................................................... 6
4.2 Work Observations ....................................................................................................................... 6
5.0 Exposure Monitoring (Industrial Hygiene and Hazards) ............................................................7
5.1 Parameters .................................................................................................................................... 7
5.2 Monitoring Results ........................................................................................................................ 7
6.0 Programs and Records Review ................................................................................................9
6.1 Program Review ............................................................................................................................ 9
6.2 Records Review ........................................................................................................................... 10
7.0 Injury and Incident Review .................................................................................................... 10 8.0 Safety Metrics & Industry Comparison ................................................................................... 11 9.0 Compliance Status ................................................................................................................ 12 10.0 PPE Assessment .................................................................................................................... 13
11.1 Primary Hazards .......................................................................................................................... 13
11.2 Radiation Exposures .................................................................................................................... 13
11.3 Assessment ................................................................................................................................. 13
11.0 Quantitative Risk Analysis ..................................................................................................... 14
11.1 Methodology ............................................................................................................................... 14
11.2 Numerical Assignments .............................................................................................................. 14
11.3 Quantitative Safety Risk Assessment .......................................................................................... 15
12.0 Summary & Findings ............................................................................................................. 16 13.0 Addendums .......................................................................................................................... 17
13.1 Site & Desktop Review Items ...................................................................................................... 17
13.2 Radiation Exposure Report Example ........................................................................................... 23
Hazard ID & Risk Assessment (HIRA) Client
Allen D. H. Blanchard 3
1.0 Introduction
This report documents the biennial hazard identification and risk assessment (HIRA) Client
conducts of its non-hazardous oil and gas waste disposal facility in USA. The HIRA is
performed in order to:
Identify worksite hazards and conditions;
Evaluate the adequacy of safety programs and practices;
Determine exposure levels for site physical, chemical and radioactive hazards;
Quantify risk factors for specific hazards; and
Provide insight for improvements.
2.0 Methodology
The HIRA incorporates various desktop reviews, site inspections, interviews, industrial
hygiene and hazard surveys, and analysis. More specifically, the HIRA includes:
Review of currently handled materials, chemicals and wastes;
Review and compilation of site processes, such as waste offloading, vehicle washout, hot work, etc;
Site monitoring of industrial hygiene and/or exposure hazards such as benzene, volatile organic compounds, noise, hydrogen sulfide, carbon monoxide, radiation, and explosive conditions;
Review of existing safety programs, procedures, policies, and records;
Site inspection and work observations
Analysis of safety metrics and comparison to industry averages;
Review of historical incidents and injuries;
Subjective evaluation of the safety compliance status;
Quantitative risk analysis of appropriate process, procedures and/or hazards;
Evaluation of PPE adequacy; and
Prioritized recommendations for safety improvements.
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3.0 Process and Material Review
The following represent the theoretical materials, processes and hazardous chemicals
involved with site operations. See section 4.0, Site Inspection and Work Observations for
onsite processes and items specifically reviewed during this HIRA.
3.1 Materials
Non-hazardous oil and gas wastes o Oil base and water base drilling mud o Completion fluids o Production fluids – Saltwater, BS & W o Production solids – Sand. Tanks bottoms, soil, etc o Work over fluids
Naturally Occurring Radioactive Material
Recyclable iron, scrap and rock
Solid waste – trash, refuse
Compressed gases: oxygen, acetylene, propane, air
Fuels: gasoline, diesel
3.2 Processes
Truck receipt and standby
Container offloading: drums, cuttings boxes
Vehicle & Cargo offloading: tanker trucks, end dumps, roll off boxes, vacuum boxes
Container emptying: drums, cuttings boxes, frac tanks
Waste processing & disposal: mixing, slurrying, pumping, injection
Waste recycling: Transport, mixing, end dump loading
Container and vehicle washouts
Equipment maintenance: pumps, shaker, crane, forklift, backhoe, excavators
Welding, cutting, fabrication
NORM offloading, processing and injection
General tool use: grinding, drilling,
Electrical maintenance
Compressed gas storage and use
Fuel storage and use
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3.3 Hazardous Chemicals
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4.0 Site Inspection and Work Observations
4.1 Site Inspection
A site inspection was performed of the facility on July 27th. Items inspected include those
listed in Addendum 13.1, Site & Desktop Review Items.
4.2 Work Observations
As part of the biennial HIRA, observations were made of work processes such as those listed
in section 3.2 of this report. Over the two (2) days July 26 and 27, the following processes
were observed directly:
Waste receipt and standby;
Truck and cargo offloading;
Waste processing;
Welding and cutting;
General tool use; and
Vehicle and container washout.
Along with the other elements of this report, the site inspection and work observations are
used as input to determining the compliance status and to aid in attributing risk factors for
the quantitative risk analysis documented in section 11.1 of this report.
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5.0 Exposure Monitoring (Industrial Hygiene and Hazards)
5.1 Parameters
Measurements were taken of the following parameters to determine the presence or
absence of actionable exposure hazards:
Benzene
Hydrogen Sulfide
Volatile Organic Compounds
Explosive Compounds
Gamma radiation
Noise
Carbon Monoxide
Oxygen
5.2 Monitoring Results
Exposure & Hazard Monitoring Results
Monitoring Points Result
Benzene
Condensate Tank Head Space 180 ppm
Frac Tank Head Space 125 ppm
V-Tank during saltwater offload 9.7 ppm within 1' of hose discharge
Injection Tank 4.9 ppm within 1' of discharge from V-Tank.
Welding area .3 ppm
Waist level on V=Tank .7 ppm during static no offloading conditions
Waist level on Injection Tank .6 ppm during static no offloading conditions
Laboratory .2 ppm
Saltwater storage pit .3 ppm
Noise
Air Compressor 102.5 db maximum. 82.4 to 99.0 for personnel. 15' radius
for 85 db.
Diaphragm pump 103.8 maximum
Diesel pump 105.3 maximum
Top of V-Tank 77.8 to 92.1 db
Top of Injection Tank 84.1 to 99.8 db
Containment Area around tanks 85.3 to 98.9 db
Between vertical tanks 83.8 to 87.8 db
Washout pit 77.4 to 81.6 db
Maintenance area 71.1 to 73.0 db
Backhoe cab 84.5 db
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Cherry Picker Cab - 76.0 db; Front 76.1 db; Rear 77.6 db
Forklift Cab - 83.8 db; Front - 78.6 db; Rear - 87.8
Excavator Cab - 79.1 db; Engine - 91.1 db; Rear 74 db; 3' radius for
85 db
Semi Trucks 99.8 db at compressor
Trucks side by side 30' radius for 85 db. 83.0 db between trucks.
SW pit perimeter 70 to 72 db
Laboratory 56.3 db to 60.5 db
Sump pump diesel 94.2 db max. 8' radius for 85 db
Around Injection pumps 98.9 to 100.7 db
Ground level inside containment
area
87.7 db to 100.7 db generally
Truck standby and unloading areas 73.0 to 76.1 db
Volatile Organic Compounds (VOCs)
Condensate tank 400 ppm
Washout pit at shale shaker outlet 5 to 18 ppm
V - Tank 180 ppm during saltwater offload.
V - Tank 5 to 18 ppm in dead headed airspaces - no offloading
Injection Tank 15 to 30 ppm. Concentrated in dead air spaces.
Saltwater pit 0 to 1.3 ppm
Frac Tank 250 ppm
Carbon Monoxide
Tanks, pumps , equipment, vehicles None detected
Oxygen
Tank head spaces, vehicle cabs, all
other
20.2 to 20.5 %
Hydrogen Sulfide
Condensate tank head space 3.0 ppm
All other areas None detectable
Explosive Compounds (LEL)
Condensate tank head space 22%
Frac tank head space 3%
Gamma Radiation
V-Tank 35 to 200 uR/hr
Between V-Tank and Injection Tank 8 to 18 uR/hr
Vertical storage tanks 20 to 75 uR/hr
Frac tanks Background
Saltwater pit Background to 40 uR/hr
Injection Tank Background to 15 uR/hr
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6.0 Programs and Records Review
6.1 Program Review
A detailed review of the CLIENT ES & H program has been completed. The primary purpose
was to determine the required and/or appropriate programs, procedures, and policies. The
program review was derived from both regulatory requirements and client and industry
expectations and standards.
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6.2 Records Review
The following records were reviewed in support of this HIRA and the overall
program review and improvements:
Historical OSHA 300 and 300 A logs
Injury and incident reports
Maintenance records
Radiation exposure records
Hazardous chemicals MSDS
Previous audits and inspections
Personnel orientation and training records
Employee Modification Rating (EMR) documents
7.0 Injury and Incident Review
The following incidents, including documents and any investigation reports, were reviewed:
Employee struck by Lightening (non-documented) – 6/13/1999
Mechanic Back Injury – 2003?
White Oak Waste Receipt Incident – 2/6/2010
Leonel Martines Eye Injury – 10/16/2007
H-10 Records Incident – 12/9/2008
Carrie Simon Waste Receipt Incident – 1/23/2009
Gloria Turner – Basic Trucking Waste Receipt Incident – 3/26/2010
Gallion Crane Roll Over Incident – 6/8/2010
Forklift incident – 6/28/2010
Non-documented spill incidents
The above incidents may be summarized as follows:
One (1) eye injury - Flying debris
One (1) back injury – Manual lifting
Two (2) equipment operation incidents
Spill incidents – Non safety
Four (4) waste receipt or administrative incidents – Non safety
One (1) act of god injury
Additional safety issues have arisen related to confined space, slips, housekeeping, gas
cylinders, and traffic.
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8.0 Safety Metrics & Industry Comparison
A reliable indicator of CLIENT Safety status is comparison of safety metrics to industry
averages. Industry averages are obtained from the Bureau of Labor Statistics website.
Summary:
CLIENT has exceeded or met industry averages in safety metrics for every year since
operations began – 1998. Below is the analysis for the past three (3) years
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9.0 Compliance Status
The following represents a snapshot evaluation of the general compliance status of specific
ES & H issues and programs. Comments are based on knowledge levels (Corporate, ES & H,
& Operations), quality of written programs, degree and quality of implementation, and
training levels.
Overall
Are site hazards known? Yes
Are safety regulatory requirements adequately understood? Yes
Are site hazards requirements and controls understood? Yes
Are written programs, policies, etc., in place? Yes
Are management systems sufficient to ensure compliance? Yes
Do written programs, policies, etc., address all areas of safety? Yes
Are all necessary elements of the written programs in place? No
Are corporate commitments in place to empower safety? Yes
Are onsite commitments in place to empower safety? Yes
What is the Corporate and ES & H level of knowledge? Sufficient
What is the ES & H level of knowledge? Sufficient
What is the onsite ES & H level of knowledge? Needs improving
What level of implementation exists for safety programs? Needs improving
What level of training exists for safety programs? Needs improving
Program Status Health & Safety Policy Satisfactory Respiratory Protection Satisfactory Confined Space Program Satisfactory Incident Investigation & Reporting Satisfactory Benzene Awareness Satisfactory Bloodborne Pathogens Satisfactory Responsibilities Needs Improving Stop Work Authority, Disciplinary Action, Waste Management Satisfactory Site (non-office) housekeeping – litter Needs improving Inspections and Audits Satisfactory Injury & Illness Reporting & Recordkeeping Satisfactory Hazard Communication Satisfactory Lock Out / Tag Out Satisfactory - Needs review NORM Management Procedure – Radiation Hazards Satisfactory Spill Prevention Control and Countermeasure Needs upgrading Training Program Needs improving Emergency Action Plan Needs training Electrical Safety Satisfactory-Needs improving Hurricane Action Plan Satisfactory Fire Prevention Needs improving First Aid Program Satisfactory
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Flammable & Combustible Liquids Needs improving Material Handling & Lifting (Non Forklift) Satisfactory Equipment operations, safety & maintenance Needs improving Hand & Power Tools Satisfactory Welding, Cutting & Hot Work Needs improving Personal Protective Equipment (PPE) Satisfactory Slips, Trips & Falls Protection Needs Improving Noise Awareness, Exposure & Conservation Satisfactory
10.0 PPE Assessment
11.1 Primary Hazards
Periodic assessment of PPE selection and adequacy are required by OSHA. At the CLIENT
facility in USA, the main materials or chemicals that PPE must protect against include:
Completion & work over fluids (corrosive or reactive in nature)
NORM – radiation exposure
Sharp and flying objects
Overhead and moving objects
Heavy items, equipment operations
Wet, windy or icy conditions
11.2 Radiation Exposures
CLIENT performed radiation exposure for approximately eight (8) years, during which no
worker approached the level at which annual monitoring is required. As a result, external
beta-gamma dosimetry monitoring was discontinued. As part of the NORM survey
described in section 5.0 of this report, gamma radiation levels were measured, to ensure
that levels are not significantly different than during the period of dosimetry monitoring.
They are not. Per Texas Department of State Health Services requirements, exposure
monitoring records have been maintained and are available for workers. Below is an
example of one exposure report.
11.3 Assessment
Based on the hazards present and the exposure scenarios, the M. B. Environmental Services
PPE policy and requirements is satisfactory.
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11.0 Quantitative Risk Analysis
11.1 Methodology
The numerical risk ranking system incorporates the below factors.
Frequency of Occurrence or Exposure Severity of Incident Compliance Status Historical Occurrence (has previous incident occurred at CLIENT)
The following formula is used to compute the risk factor:
RF = Frequency x Severity + Compliance Status + Historical Occurrence
11.2 Numerical Assignments
Frequency Frequent = 5
Occasionally = 3
Seldom = 1.5
Severity Catastrophic = 4
(May cause death or complete facility loss)
Critical = 3
(Severe injury or illness or major property damage)
Marginal = 2
(Minor injury or illness or major property damage)
Negligible = 1
(< 1 lost work day but a violation of some kind)
Compliance Status Compliant = + 0
Minor improvements = + 2
Major improvements = + 4
Historical Occurrence Never = + 0
1 occurrence = + 2
> 1 occurrence = + 4
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11.3 Quantitative Safety Risk Assessment
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12.0 Summary & Findings
The purpose of the biennial hazard identification and risk assessment (HIRA) is to identify worksite hazards and conditions; evaluate the adequacy of safety programs and practices; determine exposure levels for site physical, chemical and radioactive hazards; quantify risk factors for specific hazards; and provide insight for improvements.
HIRA methods generally included desktop reviews of programs and records, site inspections and observations of work practices, monitoring of worker exposure parameters and hazards, and quantitative risk evaluation of hazards.
Materials of interest include non-hazardous oil and gas wastes, NORM, recyclable iron, scrap and rock, solid waste, compressed gases and fuels. Work over and completion fluids may pose the greatest skin hazard to workers. Produced saltwater, BS & W and condensate pose s significant flammability and explosion hazard.
Processes of direct interest include vehicle traffic, container offloading, dumping and washing, waste processing and vehicle washouts. Equipment maintenance and hot work, along with flammable source management are also of primary concern.
Exposure and hazard monitoring was performed onsite for benzene, volatile organic compounds, explosive compounds, noise, hydrogen sulfide, radiation, oxygen, carbon monoxide. Benzene and VOC measurements indicate significant hazards inside vertical tanks and frac tanks, in addition to posing worker exposures in process areas. Explosive conditions exist in vertical tank head spaces. Hydrogen sulfide is present in vertical tanks but below action levels. Noise levels warrant management in areas around injection pumps, processing and the air compressor. Noise levels in the vicinity of semi trucks can also be significant. Oxygen and carbon monoxide measurements do not indicate areas of concern. Radiation levels are negligible.
Historical injuries and incidents have included One (1) eye injury, one (1) back injury, two (2) equipment operations incidents, one (1) act of god, four (4) waste receipt or administrative incidents, and miscellaneous non documented spill, traffic, confined space, and slip incidents.
Safety Metrics indicate CLIENT has met or exceeded Industry averages since operations began in 1998.
The overall safety program compliance status is satisfactory with reservations. Management and resource commitments are satisfactory. Requirements are known and written programs and management systems are in place. Corporate and ES & H knowledge levels are satisfactory. Improvement is needed in program implementation and training, along with site knowledge levels. See section 9.0 for specific program evaluations.
The periodically required PPE assessment indicates that, based on current hazards, ppe requirements and policies are satisfactory.
A Quantitative safety risk analysis was performed of 28 safety programs or elements, incorporating frequency of occurrence or exposure, severity of incident, compliance status, and historical occurrence into the following formula: RF = FO x SI + CS + HO
The highest risk programs, in descending order, included: Material Handling – Forklift/Backhoe operations; Fall Protection – Process Tank; Fire Hazards/Prevention; Traffic; Welding & Cutting; Material Handling – Heavy Equipment Operations; Electrical Safety – Hazardous Areas; Electrical Safety – Maintenance Areas; Confined Spaces; and Slips & Trips.
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13.0 Addendums
13.1 Site & Desktop Review Items
Program Site & Desktop Review Items
All Programs
Initial and Annual Training
Annual Reviews
Benzene Awareness
Quantitative Monitoring every two (2) years
Bloodborne Pathogens
Review, maintain, update Exposure Control Plan at least annually
Review to reflect technological changes
Ensure BP supplies are available (ppe, labels, red bags)
Annual program review
Engineering controls examined on a regular basis
Hand washing facilities. Antiseptic with clean cloth or paper towels.
Containers that prevent leakage. 'Biohazard' labels.
Gloves, lab coats, face shields or masks and eye protection (goggles)
Gown, apron, lab coat, clinic jacket or similar
Fluorescent orange or orange red labels. Red bags may be substituted.
Records of occupational exposure.
Record of medical evaluation following exposure.
Electrical Safety
Separate training - Qualified & Un-qualified workers
Shiftly inspections of portable equipment
Inspect plugs and receptacles
Safety Signs to warn employees of electrical hazards
Emergency Action Plan
Ready list of emergency contact numbers
Ready list of employees for emergency accounting
Hand held blow sirens @ key Locations. Tested every two months.
Document siren tests every two months
Environmental & Waste Management Policy
Steel trash bins with covers.
Onsite litter & spillage.
Review waste streams, storage, recycling, etc. practices
Disposal documentation. Authorized wastes only.
Environmental Program
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Waste Acceptance documentation
Waste recycling documentation
Periodic review of waste streams, recycling potential, current practices
Facility Environmental Inspections
Equipment Safety, Operations, Maintenance
Qualified operators must be specified
Manufacturer's Manuals available
Inspection records. Certification records as appropriate
Unattended equipment at night - light reflectors or barricades with lights
All cab glass is safety glass
Parked equipment must have parking brake engaged. If on incline, must have wheel chocks.
Seat belt on backhoe and forklifts
BH/FL Earth moving equipment must have service brake system
Forklift and BH must have horns AND reverse signal alarms
Reverse signal if have obstructed rear view
BH & Forklift must have rollover protective structures. 52" from deck to top
ROPS must have affixed label - manufacturer, model of ROPS, Model/SN designed to fit
Crane Load rating chart securely fixed in the cab
Frequent inspections performed daily to monthly
Periodic inspections at 1 to 12 month intervals or per manufacturer
Monthly running rope inspections. Certification record must be maintained
Monthly certifications of brakes, crane hooks and ropes
Fire extinguisher in cab or vicinity of the crane
FL Label must be attached showing certification by testing organization
Sufficient clearance must be maintained for passage and handling
Regular workplace safety inspections
Road and travel surfaces should be smooth and secure
Fire Prevention Plan
Periodic inspections to assess combustible material risk - ES & H
Periodic program review
Signage: Tanks (waste, diesel, sw, gas), breaker panels, trash
Electrical equipment and circuitry will be numbered/identified.
Designated smoking areas - signage
Secured storage of cylinders; valve protectors/caps/guards
Good housekeeping
Fire extinguishers inspected monthly. Annual maintenance. With records
First Aid Program
First aid provider onsite during waste operations
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FA providers qualified by Red Cross or equivalent
First aid supply kit
Assess supply kit annually
Eye and body flush facilities
Flammable & Combustible Liquids
No onsite fiberglass or polyethylene tanks for flammable-combustible liquids
Tanks must be at least 3' apart
Tanks must be apart at least 1/6 th of the sum of their diameters. When one tank is < ½ the diameter of another, the two tanks shall not be closer than ½ the diameter of the smaller.
When unstable flammable/combustible liquids are stored, spacing shall not be < ½ the sum of the tank diameters.
At least 10 feet must exist between storage tanks and any building.
Tank areas must be diked with volume at least that of largest capacity tank
Earthen walls must be at least 3' high and include at least 3' on the top
Combustible material may not be present inside diked areas
Flammable storage cabinet rooms must have ventilation, at least 10' from entrances (if upgrade) or 20' from entrances (if downgrade)
Unloading areas must be 25' (class 1) and 15' Class 2 from ASTs
FE within 10 to 25' of ASTs and Unloading areas
General Waste Management
Periodic site inspections
Evaluate hazards with waste practices --- with Hazard ID
Hand & Power Tools
Safety glasses being used
Power cords away from heat, oil, sharp edges
Tools disconnected when not in use
Cords and electrical outlets in good condition.
No excessive dust on motors. Stored in clean area.
Safety guards for equipment with hazardous moving parts: Saws, grinders
Momentary contact on-off switches on: drills, grinders, sanders, saws, similar
Constant pressure switches on saws > 2"
Electrical - 3 prong ground, double insulated or powered by low voltage isolation transformer
Tools stored in dry place. Not used in wet place. Work areas well lighted.
Wheels shall be free from cracks or defects. Well fitted.
Portable grinding tools must have safety guards,
Hazard Communication
MSDS onsite
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Chemical hazard list current
HazCom Poster - Both trailers
Hazcom signage on vertical tanks
Non-managed hazardous chemicals?
Hazard Identification & Risk Assessment
Qualitative & Quantitative Hazard ID every 2 years
Industrial hygiene monitoring every 2 years
Periodic site hazard inspections
Job Safety Analysis or Job Hazard Analysis
Review of written plans, regulatory status, incidents, accidents, injuries
Health & Safety Policy
Written procedures; Annual reviews; Hazard ID & Risk Assessments;
Inspections; Audits; PPE, Resources
Hurricane Action Plan
Internet access
Incident Investigation & Reporting;
NA
Injury & Illness Recordkeeping
OSHA 301 completed within 7 days
OSHA 300 log signed
OSHA 300 Log posted in conspicuous place by February 1st
Inspection, Measurement & Test Equipment
List of IMTE. Calibration dates.
Lock Out / Tag Out
Supplies: Tags, locks/keys, cable ties
Material Handling & Lifting
Rigging material inspection
Documents, tags or labels specifying lift limits
Rigging material stored in safe place
Hooks only of closable, lockable type
Motor Vehicle Safety & Defensive Driving
Periodic assessment of drivers licenses
Vehicles < 10 mph must have seat belts
Noise Awareness, Exposure & Conservation
Noise exposure assessment every 2 years
Change in process require updated assessment?
Signage: Air compressor, injection pumps
Ear plugs
Procedures in both trailers
NORM Laboratory Procedures
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NA
NORM Management Procedure
NA
Personal Protective Equipment (PPE) Program
Personnel wearing boots, hard hats, gloves, eye wear?
Hazard assessment every 2 years. Documented
Respiratory Protection Policy
IH Monitoring every 2 years
Short Service Employee
List of SSEs. Assigned mentor.
Visual means to differentiate
Slips, Trips & Falls Protection Procedures
Site assessments - every 2 years
Clean and orderly facility.
Conditions maintained dry as possible.
Protection in wet areas to the extent practical and effective.
Safe clearances for material handling. Clear aisles, no obstructions, even ground.
Open pits must have guard rails or covers.
Standard Rails, Toe Boards
Spill Prevention Control and Countermeasure
System hoses capped or flanged when not in use
Drain valves that could result in spill must be locked shut unless frequently cycled operationally
Pumps that could cause spill must be starter's deactivated if they are used only infrequently
Lighting must be sufficient to identify spills
Accumulated water must be removed
Warning signs at unloading area to prevent vehicle departure before transfer complete
Program review every 3 years
Monthly SPCC inspections
Internal inspections of tanks annually - performed & documented when open
Stop Work Authority
Document stop work interventions
Training Program Documentation
Waste Acceptance Policy
NA
Welding, Cutting & Hot Work Procedures
Written permits for Hot Work
Cylinders legibly marked with stencils, stamps or label
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Must have valve protection cap or collar
Stored away from heat
Oxygen not store near combustible material, near fuel gas or likely to cause fire
Welding blankets or shields if combustible material within 35'
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13.2 Radiation Exposure Report Example