Developing a Chemical Risk Management Program

SAND No. SAND No. 2012-1605C

Sandia National Laboratories is a multi-program laboratory managed and operated by Sandia Corporation, a wholly owned subsidiary of Lockheed Martin Corporation, for the U.S. Department of Energy's National Nuclear Security Administration under contract DE-AC04-

94AL85000

Overview of Presentation

Hierarchy of regulatory controls/industry standards for chemical risk management programs,

Roles in a chemical risk management program, Purpose of a chemical risk management program, Elements of a chemical risk management

program, Examples of site assessment checklists.

Hierarchy of Controls

LAWS

REGULATIONS

INDUSTRY CODES

GOOD BUSINESS PRACTICES

Chemical Management ProgramOrganizational Roles

Culture of chemical risk management should exist at all levels of the organization

Top management sets policy, provides resources

Workers must understand and implement

Many organizational interactions are important for an effective chemical risk management program

Executive Officer

orPresident

Senior Manager

Supervisore.g. Project

manager

Employee

Corporate Safety Officer

and

Corporate Security Officer

Plant Safety and

Security Manager

Designated by the

functional area

Purpose of a Chemical Risk Management Program

Prevent and/or mitigate release of hazardous substances within the facility and in the nearby community◦ Protect people◦ Protect the environment

Prevent theft of chemicals or process information Prevent chemical exposure to workers Comply with laws and regulations Provides for incident management response

Elements of a Chemical Management Program

The written program should include a policy statement endorsed by the plant’s management.

“It is the policy of our company to protect our workers and the public,

prevent incidents, protect the environment through integration of

environmental stewardship and sustainability throughout the life-cycle of

its activities, and ensure regulatory compliance.”

Elements of a Chemical Risk Management Program

Chemical inventory/Material Accountability

◦ Describe the process for tracking chemical inventory:

“All chemicals will be procured through Corporate Process XXX, All chemical containers, process units, & piping will be labeled, All chemical containers/process units will be bar-coded, All chemicals will have safety data sheets, Safety data sheets will be accessible to all employees and regulatory

authorities, Chemicals of concern will be secured and access limited, and Chemical quantities will be tracked from procurement to disposal.”

Elements of a Chemical Risk Management Program

Worker health and safety◦ Describe the process for identifying, evaluating, and

controlling worker exposure: "All chemicals associated with processes will be identified, Potential worker airborne or dermal exposure to identified

chemicals will be evaluated, All workers exposed to hazardous chemicals will be subject

to medical surveillance, and All documented exposures will be controlled by

Engineering controls, personal protective equipment or administrative controls, in that order.”

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Elements of a Chemical Risk Management Program

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Example of Personal Protective Equipment Assessment Form

Elements of a Chemical Risk Management Program

Example of Job Hazard Analysis Form:Date: ____________JHA Number: _________Location of Task:_______________________________________Task # 1 Description:--------------------------------------------------------------------Hazards: ----------------------------------Preventive Measure(s): --------------------------------------------------------------------

Safe Job Procedures: ----------------------------------

Retrieved February 27, 2012 from, U.S. Occupational Safety and Health Administration. http://www.osha.gov/Publications/osha3071.pdf

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Elements of a Chemical Risk Management Program

Exercise:

Describe one of your processes List all chemicals and their hazards, List all possible ways a worker might be exposed, List how the exposure will be controlled, List current procedures to protect the worker

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Elements of a Chemical Risk Management Program

Process Hazard and Threat Risk Assessment◦ Describe the process for identifying, evaluating, and controlling chemical

hazards from catastrophic incidents and security threats:

“All processes will undergo an initial and periodic hazard analysis to include, identification of process chemicals, process conditions (pressure, temperature), fire, explosive and reactivity hazards, process equipment, and measures to control unplanned releases.”

All changes to process chemicals, processes, equipment, or facility modifications will be subject to evaluation through a management of change procedure.”

Note: Indicate industry codes and standards that will be followed; for example, National Fire Protection Association (NFPA), American Society for Testing and Materials (ASTM)

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Elements of a Chemical Risk Management Program

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Hazard Analysis of Fertilizer ProcessProcess Flow Diagram

Elements of a Chemical Risk Management Program

Hazard and Threat Risk Assessment, continued

◦ Describe the process for identifying, evaluating, and controlling security threats from theft and sabotage:

“All processes will undergo an initial and periodic security vulnerability assessment to include, identification of chemicals of concern and their properties, and measures to control their theft or unplanned release.”

All employees procuring, storing, processing, or disposing of chemicals of concern will be subject to a personnel reliability program.

All chemicals of concern will be managed under a material accountability program which will include access control as well as inventory tracking.“

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Elements of a Chemical Risk Management Program

Training program◦ Describe the process for developing, auditing, and

maintaining a safety and security training program: “All employees handling or disposing of chemicals will take

training in hazard communication and if applicable, respiratory protection, confined space, hazardous waste operations, and emergency response.

All employees procuring, storing, handling or disposing of chemicals of concern will take Security 100 training.”

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Training Documentation: Sample

Employee name: ___________________________

Department: _________________________

Date: ______

Training Subject: ______________________________

Training Date: ___________

Re-instruction date: _________

Employee Signature: ______________________________

Date Signed: __________

Supervisor’s signature: _____________________________

Date: __________

Elements of a Chemical Risk Management Program

Emergency and Incident Management Plan

Pre-emergency planning with outside authorities Personnel roles, lines of authority, communication Site security and control Evacuation routes and procedures Personnel protective and emergency equipment Decontamination procedures Emergency medical treatment and first aid Emergency response and alerting procedures Critique of response

Reference: U. S. 29 Code of Federal Regulations, 1910.120. HAZWOPER Standard

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Elements of a Chemical Risk Management Program

Incident Investigations◦ All incidents, regardless of severity, must be investigated

– and lessons learned used for prevention in the future◦ Formal investigation of serious incidents◦ Accountability at all levels

Management, employees, and the investigation team.

Elements of a Chemical Risk Management Program

Facility site inspections:◦ “The chemical shipping and receiving warehouse will be

physically inspected quarterly for potential safety hazards and security threats. The inspection will include a walk-down of the warehouse. The following will be reviewed. Access control, Chemical inventory records, Chemical container labels and SDSs, Chemical storage containment and chemical compatibility, Emergency procedures and signage, Worker PPE, Local exhaust ventilation flow rates and maintenance records, Training records.”

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Elements of a Chemical Management Program

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Example: Facility Site Inspection

Elements of a Chemical Management Program

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Example: Facility Site Inspection

Elements of a Chemical Risk Management Program

Inspection Checklist:

Date of Inspection:_______Conducted by:_______Location (building/process unit):_______Supervisor:_______

Work Practices• Work conducted under ventilation if airborne hazard• Housekeeping• Work instructions present and used

Elements of a Chemical Risk Management Program

Inspection Checklist: General Facility Condition

◦ Egress/aisles/passageways◦ Exit signs◦ Housekeeping◦ Access controls

Hazardous areas Chemicals of concern

Hazard Communication◦ Training documented◦ SDS available for all chemicals◦ All chemical containers/tanks/piping labeled

Personal Protective Equipment (PPE)◦ Available for each exposure identified◦ Respirators and other PPE stored properly and appropriate for identified

hazard

Inspection Checklist: Fire Safety

◦ Evacuation maps◦ Fire pull stations & telephones appropriately placed and posted ◦ Adequate number of fire detection and sprinkler equipment◦ Fire extinguishers tested, inspected, and appropriate type◦ Flammable chemical storage: quantities and containment

Process Safety◦ Mechanical integrity program◦ Emergency shut-down equipment present and routinely tested◦ Emergency chemical release equipment available, maintained and

posted◦ Management of change procedures

Elements of a Chemical Risk Management Program

Summary of Presentation Described the hierarchy of regulatory

controls/industry standards for chemical risk management programs,

Identified the roles in a chemical risk management program,

Listed the purpose of a chemical risk management program,

Described the elements of a chemical risk management program,

Provided examples of site assessment checklists.