sand no. sand no. 2012-1605c sandia national laboratories is a multi-program laboratory managed and...
TRANSCRIPT
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.
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.”
8
Elements of a Chemical Risk Management Program
9
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
10
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
11
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)
12
Elements of a Chemical Risk Management Program
13
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.“
14
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.”
15
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
17
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.”
19
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.