Process Safety Management of Highly Hazardous & Explosive Chemicals Contractor Management & Emergency Planning & Response
Now That We ve Developed Now That We ve Developed Process Safety Information Process Material Toxicity Information Process Hazard Analysis (PHA s) Mechanical Integrity Certificates Management of Change Inspection/Testing/Maintenance Operating Procedures Safe Work Procedures Training Programs Now
Contractor Management Contractor Management 1910.119(h) The employer, when selecting a contractor, shall obtain and evaluate information regarding the contract employer's safety performance and programs.
Contractor Management Contractor Management The employer shall inform contract employers of the known potential fire, explosion, or toxic release hazards related to the contractor's work and the process.
Contractor Pre-Qualification & Authorization The Standard Requires You to: Explain contractor qualification requirements List what is required for contractor pre-bid awareness - pre-qualification List what is required for contractor post-bid awareness - training & orientation Specify contractor responsibilities Describe contractor 300 Log Requirements Evaluate Contractor Performance List documentation requirements for contractors to complete Explain the use of a work authorization system
Contractor Management Typical Pre-Qualification Elements: Years Experience in Work Process Experience Modification Rate (EMR) OSHA Total Recordable Incident Rate and Lost Work day Case Rate Information, DART Safety Programs Training Documentation
Contractor Management EMR s & Loss Ratios - What do They Mean? MOD Rate or EMR: Experience Modifier Rate Modifier for WC: based on loss frequency and severity formula. Developed by NCCI Examples: Unity Rate: 1.0 Debit Mod: 1.2 Credit Mod:.65 Loss Ratios Ratio between losses and premium Used by Underwriters Used by Others Example: $50,000 losses $100,000 premium Answer: 50% Loss Ratio
Contractor Management Incident Rates & DART Rates The incidence rate is a trending number based on your Injury & Illness rates if you had worked 200,000 hours. Why does OSHA use the 200,000 hour benchmark? Quite simply, 200,000 hours are the hours worked by 100 employees, averaging 40 hours per week over a 50 week span (two weeks taken away for holidays). The DART rate stands for "Days Away, Restrictions and Transfers". This number is also based on trending over 200,000 hours but its not based on total injuries. Its based only on those injuries and illnesses severe enough to warrant "Days Away, Restrictions and Transfers".
Contractor Management Contractor Management Let s Review the Standard Contractor Pre- Qualification Form in Your Class Notebooks.
Contractor Management Contractor Management Establish Your Own Company s PQF Requirements and Standards Apply them Uniformly Remember, This Requirement is to Ensure that Only Qualified, Trained and Safe Operating Contractors are Allowed to Perform Work on a Covered Process
Contractor Management Contractor Responsibilities The contract employer shall assure that each contract employee is trained in the work practices necessary to safely perform his/her job. The contract employer shall assure that each contract employee is instructed in the known potential fire, explosion, or toxic release hazards related to his/her job and the process, and the applicable provisions of the emergency action plan. The contract employer shall document that each contract employee has received and understood the training required by this paragraph. The contract employer shall prepare a record which contains the identity of the contract employee, the date of training, and the means used to verify that the employee understood the training.
Emergency Planning & Response Emergency Planning & Response 1910.119(f)(1)(i)(D) The employer shall establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38. In addition, the emergency action plan shall include procedures for handling small releases. Employers covered under this standard may also be subject to the hazardous waste and emergency response provisions contained in 29 CFR 1910.120 (a), (p) and (q).
Emergency Planning & Response Emergency Planning & Response Compliance Directive Has an emergency action plan been established and implemented for the entire plant in accordance with the requirements of 1910.38? Does the plan address the following: [Criteria Reference.119(n) or.38(a)(2)]
Emergency Planning & Response Emergency Planning & Response Compliance Directive - Does it Cover? Escape procedures and routes? Procedures for post-evacuation employee accounting? Preferred means to report emergencies? Duties and procedures of employees who: Remain to operate critical equipment? Perform rescue and medical duties? The names for persons or locations to contact for more action plan information? Employee alarm systems? There is Much More- Review in Your Class Notebooks.
Emergency Planning & Response Emergency Planning & Response Our Written Plan Must: Define an emergency action plan Define an emergency response plan Describe a Minimum emergency response plan Describe procedures for handling small releases List the three levels of emergency response List procedures for emergency evacuation List requirements of alarm systems List training requirements
Emergency Planning & Response Emergency Planning & Response Level I (Disaster) Example - community-wide emergency that seriously impairs or halts the operation of the area. Outside emergency services would be needed. Major policy considerations and decisions would always be required. Examples: Mass casualties. Natural disaster such as earthquake or tornado. Large-scale hazardous material spill.
Emergency Planning & Response Emergency Planning & Response Level II (Major Emergency) A serious emergency that completely disrupts one or more operations of the facility and /or town and may affect mission-critical functions or life safety. Outside emergency services, as well as major efforts from emergency services, would be required. Major policy considerations and decisions would usually be required. Examples: Hostage situation Major fire Civil disturbance Bomb Threat
Emergency Planning & Response Emergency Planning & Response Level III (Minor) A localized, contained incident that is quickly resolved with internal resources or limited help and does not affect the overall functioning capacity of of the Plant or City. Example: Small fire. Small hazardous material incident. Limited power outage.
Emergency Planning & Response Emergency Planning & Response The Standard Requires You to: Develop a Early Warning Method for Releases (Sensors/Alarms) Train on the Meaning of the Alarms (May be Multiple Alarms)
NASA s Alarm Horn - Audible for 30 Miles
Emergency Planning & Response Emergency Planning & Response Warning Systems must: Clearly Notify Employees of the Hazardous Release Employees & Contractors must be Trained in the Meaning of the Alarm(s)
Emergency Planning & Response Emergency Planning & Response Develop Emergency Evacuation Written Plans, Evacuation Maps & Assembly Points based on Release Characteristics
Emergency Planning & Response Emergency Planning & Response
Emergency Planning & Response Emergency Planning & Response Alternate Assembly Points Depending on Prevailing Weather Affecting Release Alternate Assembly Point
Emergency Planning & Response Emergency Planning & Response
Emergency Planning & Response Emergency Planning & Response NASA High Pressure Gas - Muster Area
Emergency Planning & Response Emergency Planning & Response PPE Requirements Hazardous Chemicals May Require Emergency PPE to be Worn FRP Escape Respirators Eye Protection
Emergency Planning & Response Emergency Planning & Response Drills At Least Annual Emergency Preparedness Drills This is not Just an Emergency Evacuation but Could Include HAZWOPR Response Must Document Results
NASA High Pressure Gas Plant Contractor Management & Emergency Response Case Study Team Exercise
NASA High Pressure Gas Plant - Testing for Gas
High Pressure Hydrogen Plant
Team Exercise Team Exercise With the Information to Follow in The NASA Case Study Video, Presentation & Notebook, With Your Team Members, Perform the Following Tasks & Answer the Following Questions.
Case Study Exploration Case Study Exploration 1. What are the Responsibilities of the Employer with respect to Contractor Management? 2. What are the Responsibilities of the Contractor? 3. Can an Unqualified Contractors Perform Work on a Covered Process? 4. What are the three Levels of Emergency Response? 5. How Often Must a Drill be Performed? 6. Team Exercise - Choose One of the Team s Companies and Complete the Standard Contractor Prequalification form. 7. What Did Your Team Learn from the Completion of the Prequalification Form? We will Discuss Findings & Presentations of Each Team in Class
What s Next What s Next Compliance Audits Incident Reports & Trade Secrets