Management Leadership and Employee Involvement

Management Commitment:

1. Ensure employees have access to safety and health meeting minutes via computer and/or hard copy to include a review check list.
2. Reduce injury/illness rates below the BLS national average.
3. Provide more opportunities for employees to communicate with top management, including the Plant Manager.
4. Increase visibility of the Plant Manager and the safety department staff in the plant.
5. Address attitude among employees that a different safety and health program exists during second and third shifts, and weekend shifts.
6. Ensure all members of management are setting a good example for appropriate safety and health behavior by wearing all appropriate PPE, following all safety and health procedures and policies, etc.
7. Ensure employee compliance with safety and health rules/policies and procedures through appropriate enforcement by managers and others assigned safety and health responsibilities.

VPP Commitment:

1. Ensure employees site-wide have knowledge of their rights and responsibilities within OSHA’s VPP.
2. Consider allowing employees to receive Special Government Employee (SGE) training.
3. Develop a manual to address all elements and sub-elements for the federal register for VPP to accurately reflect the policies and procedures currently in place at this site.
4. Ensure all employees understand the VPP and the partnership between management, labor, and OSHA.

Authority and Resources:

1. HSE Managers must be provided authority to carry out safety and health responsibilities.  Plant Managers must support the efforts of the HSE Department and support their efforts within each plant.
2. Ensure all safety coordinators are provided the authority to carry out safety and health duties.  Unit managers must support the efforts of the coordinators.

Accountability:

1. Enhance safety awareness/accountability concerning PPE, traffic controls, etc.
2. Expand discussion of safety in performance evaluation.
3. Accountability of managers should include appropriate disciplinary action for violations of safety rules/procedures by employees under their control when appropriate.  Only holding managers accountable during the yearly performance review is insufficient.

Employee Involvement:

1. Develop additional opportunities for associates to become meaningfully involved in the safety and health program, and ensure that all associates are aware of current methods of participation in the safety and health program.
2. Track and trend employee involvement in the various safety programs and activities.  Use the results as a tool to continue to improve the existing degree of participation.
3. Insure employee involvement includes contractors.
4. Consider including other employees on committees to increase employee involvement.

Contractor Program:

1. Ensure that the contractor’s area is inspected on a quarterly basis.
2. Develop and implement written guidelines for the selection of onsite contractors based on their previous safety and health performance.
3. Perform an annual audit of the contractor’s safety program.  Also develop a procedure to account for contractors by having them sign in and out for emergencies.

Worksite Analysis

Industrial Hygiene:

1. Establish a written sampling strategy and program that identifies necessary information including, but not limited to, the contaminants to be sampled including air contaminants, noise, etc., frequency of sampling, shift/job to be sampled, etc. (X 2)
2. Conduct microwave oven testing to ensure equipment is not leaking radiation.
3. Complete baseline assessment of industrial hygiene related hazards.
4. Determine the need for conducting monitoring of contractor employees while onsite.
5. Review gas/vapor testing requirements for work that may be done on small or large vessels in the shop or in the plant.  The current procedures are not absolutely clear as to what is required if and when such may be done.
6. Insure that all stationary monitors for Hydrogen Sulfide are set to alarm at 20ppm.
7. Install O2 alarms in the QC lab area.
8. Install chlorine detectors at the Water Treatment.
9. Improve the IH sampling strategy by developing more detailed job description which include all job duties with exposure to hazardous chemicals, and document controls for any exposures not previously identified/monitored.
10. Develop a system to track IH monitorin completed throughout the year.
11. Perform baseline sampling at hand soldering operations with a representative of shift exposure conditions and provide feedback to employees of the results and of any related actions.

Routine Inspections:

1. Consolidate numerous self-inspection programs to ensure entire site is inspected quarterly, findings are documented and that corrective actions are tracked to timely completion.
2. Information discovered through the baseline hazard analysis, accident/incident investigations, employee concerns, sampling results, etc. needs to be incorporated into the self-inspections. (X 3)
3. Hazard recognition training should be administered to all employees conducting safety and health audits. (X 4)
4. Audit teams require additional hazard recognition training to identify hazards, i.e., machine guarding, guarding of sprockets and chains, guarding floor and kettle openings, and all of the electrical problems found during the VPP audit.
5. Improve the documentation of fire extinguisher inspections.
6. Combine all efforts of several groups making routine inspections into a single team to simplify tracking action items.
7. Document daily inspections of material handling equipment such as, but not limited to, cranes and forklifts.
8. Routine inspections are conducted using a checklist that limits the identification of hazards in the workplace.  It is recommended that the checklist be modified monthly to include hazards discussed at monthly safety meetings, training, etc., to increase hazard recognition.

Trend Analysis:

1. Utilize the current data being collected to implement a more effective method for analyzing trend data. Based on the trend information, develop actions to control potential hazards that are causing or likely to cause injury/illness to employees.
2. Perform statistical analysis on occurrences of injuries and illnesses versus job rotation times, i.e., review occurrences of injuries with respect to the afternoon of the second day when the rotation occurs from night to day with only one day between the change (The effects of circadian rhythm on the occurrence of injury and illness to personnel).
3. Formalize system for setting goals/objectives to correct trends.
4. Complete industrial hygiene monitoring and trend sampling data.

Hazard Analysis:

1. Complete SOPs, JHAs, and/or JSAs for maintenance operations and any operation or task where LO/TO is utilized as a means to de-energize.  Also complete all written programs as it relates to all hazard controls being documented for all tasks using appropriate procedures, safety and health concerns/rules, inspections and training.
2. Develop a plan for conducting comprehensive and systematic safety analysis of the following systems or operations: semi-bulk oxygen storage and distribution; natural gas distribution; chlorine storage and use (cylinder storage and use); Test line process.  Utilize an established hazard analysis technique, e.g., Hazard and Operability, and an appropriate team of technical and operations personnel.
3. Ensure written programs, JHAs, SOPs, and other programs are reviewed and/or revised on an annual basis.
4. Need to perform a hazard analysis of handling die boards to eliminate employees from lifting long and heavy die boards.

Pre-use Analysis:

1. Ensure all new equipment brought onsite is evaluated for hazards prior to exposure by employees. (X 2)
2. Develop a method that includes safety and health decisions in the procurement procedure for new materials.
3. Implement a pre-use analysis committee which will include members from each division within the company to include, but are not limited to, HSE and Purchasing.

Employee Hazard Reporting System:

1. Develop an anonymous reporting system for reporting safety and health hazards
2. Feedback for anonymous reporting of hazards should be posted on unit bulletin boards as well as on the intranet.
3. Communicate to all employees where the formal system is located in order to report hazards and other safety items.
4. Ensure that employees are notified of the status of their reported items.
5. Ensure that the hazard reporting system results in hazards being addressed, and responded to, in a timely manner and that interim measures are noted when required.
6. Implement a system for communicating feedback to the anonymous reports made to the Hotline.
7. Consider using multi-sheet form for reporting hazard to allow employees to keep a copy of the submitted report.

Hazard Prevention and Control

Engineering Controls:

1. Develop and implement engineering controls for the rotary drum to alleviate the necessity of employees having to enter and don level A PPE.

Work Practice Controls/Safety and Health Rules:

1. Ensure that the hard copy of emergency operating procedures are current and reflect what is contained in the electronic system.
2. The site needs to have specific written procedures for each piece of equipment taken out of service for maintenance, etc.
3. Incorporate existing contractor’s line breaking procedure into the plant policy.

Hazard Control Programs:

1. Review the LO/TO program and make sure that all elements of the standard are followed.
2. Consider adding the LO/TO plant to the LO/TO box for easy review by employees/contractors involved on the job.
3. Conduct additional training with permit writers to eliminate/minimize minor discrepancies in reports.
4. Implement a procedure to enforce the use of locks in the company’s LO/TO program.
5. Develop a written heat stress program. (X 2)
6. Notify the plant rescue team anytime a confined space entry is going to be conducted.
7. Implement a plan to control the locks used in the LO/TO program. (X 2)
8. Continue working on and implement an isolation list as part of the permit for LO/TO program.
9. Review the BBP exposure control plan and ensure all elements of the standard are addressed.  The exposure control plan must include an exposure determination, methods of implementation for hepatitis B vaccination, post exposure evaluation and follow-up, communication of hazards and recordkeeping.  Develop a tracking system to ensure employees complete their HBV series.
10. Review and revise permit required confined space entry procedures to include: allowing crew supervisor and employees to witness the intial testing results from the monitoring of permit required confined space; review procedures for properly logging entrants in and out of permit required confined space entry.
11. Ensure any work orders to the Safety Department suggestion line are documented to closure, with notification to the originator.  This can be done through bulletin board postings or other ways.

PPE:

1. Reevaluate your PPE requirements for work that must be performed on energized equipment, e.g., electrical diagnostics (observed electrician using multi-test meter on open live panel without insulated gloves).
2. Reevaluate the need for respiratory protection (required vs. voluntary use) in the assembly areas after additional personal sampling is for metal fumes is conducted.  Investigate the use of local exhaust ventilation to collect welding fumes.  Specify the cartridge change out requirement in the written procedure.

Certified Professional Resources:

1. Utilize the certified professional resources more frequently to identify safety and health hazards at the facility.

Hazard Correction Tracking:

1. Consider combining existing recommendation tracking systems into one consolidated system.
2. Establish specific timelines that clearly indicate when hazards are to be corrected. (X 2)
3. Develop method to track hazards identified during routine inspections that are corrected immediately so that trends can be found and corrected.
4. Improve tracking system to ensure all open items identified through various inspection systems, accident/incident investigations, etc., are tracked to completion.  Improve the system to make it simpler to trend hazards identified through these systems to identify proactive means for preventing future occurrences.

Ergonomics:

1. An ergonomic review needs to be conducted throughout the facility by brining in the corporate ergonomist.  Include training for employees and chair quality review.

PSM:

1. Enroll the PSM Manager and the PSM Coordinator in a formal classroom-training program that addresses all elements of the OSHA 1910.119 Process Safety Management of highly hazardous chemicals.
2. Hire a PSM Coordinator working under the direction of the PSM Manager for the purpose of conducting the following activities:
   1. Monitor MOCA program and recordkeeping to assure accuracy of process safety information, procedures and process drawings;
   2. Develop and conduct audits to assure compliance with the company standards and the OSHA PSM rule;
   3. Assist with the employee training sessions on Management of Change and the other aspects of PSM as needed;
   4. Assist with the incident investigation process that involves any aspect of mechanical and/or process failures.
3. Audit the PSM program to verify that procedures and practices in place meets and/or exceed the OSHA requirements.  This audit will be a team approach utilizing the most knowledgeable experts within the company and at least one knowledgeable individual that is not a company employee.
4. Ensure that site emergency response team and neighboring facility with adjoining operating unit have pre-planned the necessary steps that will be taken by the company in the event there is an emergency that affects or is caused by the neighboring unit.
5. Environment, Safety and Health approval should be on all PSM documents, i.e., MOCs, P&IDs, etc.
6. Complete PHA recommendations from revalidations. (X 2)
7. Ensure all recommendations from PHA revalidations that are listed as “closed” or actually closed.
8. Develop a MOC procedure for personnel changes to ensure an adequate evaluation is conducted when there is a change in the number of personnel in a covered process.
9. Verify all buildings are adequately protected from damage during a catastrophic event including windows in trailers.
10. Determine in ASME code storage tanks and heat exchangers in the isopentane system require thickness testing periodically, and include that testing in the mechanical integrity program.
11. Develop and implement policy requiring employee working on flammable processes to wear FRCs.

Preventive/Predictive Maintenance:

1. Develop a piping replacement schedule that focuses on the highest potential problem area and sets definite goals to reach in the replacement of the piping.
2. Ensure that the preventive maintenance system adequately detects hazardous failures before they occur.

Accident/Incident Investigations:

1. Accident investigation training for employees, plant leadership teams and supervisors need to be improved to ensure root causes are addressed. (X 2)
2. Ensure through retraining and the adoption of a recognized methodology, that investigations identify root causes and that the team’s composition is such that the primary members represent a cross-section of disciplines throughout the facility.
3. Add recommendation to all investigation and include data for closure.
4. Action items from accident/incident investigations are not being completed in a timely manner. (X 2)
5. Review accident investigation procedures with all associates involved in conducting investigations to ensure blame is not unnecessarily placed on associates.  Do not over-rely on associate behavior in root cause analysis.
6. Implement a systematic investigation process such as TapRoot, Rootquest,, Kepner Tregal, etc., that will help identify multiple causal factors such as management system failures, supervisor control, etc.
7. Include employees in accident/incident investigations.
8. Include a review of accident investigations by qualified management and/or appropriate safety and health professionals to ensure the form was completed properly and appropriate corrective actions were identified and taken.

Medical Program:

1. Continue to evaluate methods that would prove effective in reducing soft tissue illnesses, such as the physical therapy pilot program.
2. Implement the use of AED’s, and provide appropriate training for employees.
3. Develop a system to adequately track the first aid supplies being used.  Trends and near misses should be identified partially from this information. (X 2)
4. Provide additional training to employees wishing to pursue the emergency care attendant level of first aid training.
5. Consider implementing wellness and awareness related training at the monthly safety meetings.  Topics can include: diabetes, heart attacks, and prostate or breast cancer.

Emergency Preparedness:

1. Include tornado drills in the emergency action plan. (X 2)
2. Provide protection for security guards required to stand outside at gates without shelter from weather, lightening, heat stress, etc.
3. Modify emergency action plan to ensure and document annual participation by all personnel in at least one emergency evacuation drill. (X 6)
4. Ensure that all that all employees who miss emergency evacuation drills are walked through the drills upon their return to the site.
5. Adopt a procedure of sign in/sign out for all maintenance and contractors that enter and exit an operating process unit at any time for any reason. (X 4)
6. Develop a system to ensure contract employees working in outlying areas performing lawn maintenance while wearing hearing protection, are able to detect the emergency alarms when sounding. (X 2)
7. Ensure employees have emergency shut-down capabilities when running fixed equipment, i.e. drill presses, mills, saws, lathes, etc.
8. Identify critical SOPs, written instructions, and emergency procedures and provide hard copies for use by operations/maintenance staff in the event of computer failure.
9. Perform detailed written critiques of emergency evacuation drills or actual fire alarms to ensure quality performances. (X 2)
10. Develop a “Shelter-in-Place” procedure.
11. Initiate actions to re-enforce a consistent understanding by all plant employees/personnel of the emergency reporting procedure.

Safety and Health Training

1. Ensure hands-on evaluations are included during certification of employees operating forklifts.
2. Evaluate the new training program to determine the effectiveness of its efforts.
3. Provide refresher training on the operation and proper use of Drott Cranes.
4. Implement a system to verify all employees complete the required safety and health training each year.
5. Improve competency verification process for required safety and health training.
6. Add the participation in evacuation drills to the training matrix for each individual employee.
7. Ensure employees are made aware of the reasons specific safety and health changes are implemented.

Miscellaneous:

1. Provide lighting in employee parking lot.
2. Ensure taglines are used by employees who load and/or offload heavy equipment.
3. Review the grounding requirements of NFPA 33, Standard for the Spray Application of Flammable and Combustible Liquids (Section 4.5), and compare to actual operations.  Upgrade as required.  Evidence of grounding of nozzles and other equipment could not be determined.
4. Improve vent hood to include an anemometer detector to alarm when capture velocities are less than 100 fpm.
5. Install an electrostatic grounding system in the forklift propane fill up area for filling propane tanks.
6. Install inertia reel-type life lines in the railroad loading area.
7. Survey the site for inadequate coupling covers.
8. Develop a clamp and patch tracking system where the information is required to be entered into a system prior to application of the device.
9. Install lit EXIT signs throughout the facility.
10. Record all activities in the operations log.
11. Fabricate/purchase railcar chocks with a handle approximately 24-30 inches high to facilitate placing chocks on railcars to prevent/minimize back injuries.
12. A survey needs to be conducted of conveyor crossovers to ensure they are needed, and the crossovers need to be made of solid 12 inch wide metal plate to replace the 3 inch metal strips that are now used.
13. The switch over valve in the starch area needs to be repositioned close to the catwalk to eliminate employees from standing on the containment container to reach the valve.
14. Install guards on listed equipment…
15. Install eye wash/shower wher needed.
16. Evaluate the possibility of improving the guarding on the rubber hot mill machine.
17. Review and revise fall protection and scaffolding procedures.
18. Take appropriate steps to remove multi-outlet plugs throughout the plant including the laboratory.
19. Incorporate the use of hair nets around all free standing fans to prevent the hazard of employee’s hair being pulled into the fan housing.
20. Evaluate best method for providing fall protection for upper floors.  Currently a single chain is being used.
21. Evaluate hazard associated with steps providing access to equipment.  Several areas have unusually large distances between steps.
22. Improve access to the top of railcars in the loading/unloading area.  Until permanent  access can be obtained the site must develop temporary procedures to provide fall protection for employees working on top of rail cars.
23. Evaluate the need for electronic sensors for the drag-line system to provide automatic shutdown capabilities in case of emergencies, etc.

Recommendations, Contingency Items, Merit/Conditional Goals

FY ‘02

Management Leadership and Employee Involvement

Management Commitment:

1. Management must ensure all members of management are committed to the safety and health program, and always place safety and health of the employees above production.
2. Develop a site-specific strategic plan to include safety and health goals.

VPP Commitment:

1. The facility needs to ensure contractors working on site are made more aware of, and become more involved in, the VPP process.
2. Allow more members of the Safety Team to attend regional and national VPPPA conferences.  By doing so these employees will be able to learn about other VPP facilities and their safety/health programs and bring those ideas back into this facility.
3. Allow more people from the facility to pursue the Special Government Employee program.  (X4)
4. Allow employees to visit other VPP sites to broaden their knowledge of the program.
5. Allow more people to attend the VPP and VPPPA conferences and Behavioral Scientific Training.  By doing so these people will come back with better ideas and concepts on how to handle issues at this facility.  Allow people at this facility to enter into the Special Government Employee program and begin mentoring other companies.

Authority and Resources:

Accountability:

1. Ensure all site managers are held accountable for safety and health performance.  Accountability should not simply rely on whether or not the manager’s department had a recordable injury/illness, but instead rely on the effectiveness the manager has shown at encouraging safety and heatlh among the employees through their participation in safety and health activities, i.e., safety meetings, inspections, etc.

Employee Involvement:

1. Audit safety training/meeting records to determine effectiveness.

Contractor Program:

1. The facility needs to implement a system to document findings from routine inspections of contractors performed to ensure they are meeting the requirements of the mill.
2. A hazard assessment and air monitoring program for contractors need to be addressed.
3. The embedded contractors who work along side of the company’s employees in high noise areas should be given baseline audiograms.  These tests should be continued on a yearly basis.
4. Although contractors are not currently used, add a contractor evaluation form/sheet to appropriately evaluate the contractors if the occasion arises.
5. It is recommended that all material safety data sheets used by the contractor on site be reviewed and updated as necessary.  When needed current sheets should be obtained from the host company or from the company who sold the chemical.  If the new sheets have been revised, employees should be retrained as to their contents.
6. Insure contractor utilizes quantitative measurements for face fit factor assessment.
7. Ensure that all contract employees and temporary employees have participated in a site emergency evacuation drill.  This will include those employees who work not only on day shift but those who also work after normal work hours, i.e., janitorial.

Worksite Analysis

Industrial Hygiene:

1. Maintain vent hood drops from vent fume header in the breezeway in good working condition.
2. The facility needs to conduct a sound survey of the workplace and take appropriate action if any areas are found to exceed 100 dBA.
3. The facility needs to conduct baseline monitoring for all products used at the facility that could potentially cause an overexposure.
4. In the laboratory where styrene in analyzed, personnel monitoring needs to be conducted.
5. Develop and implement a sampling strategy for the abrasive blasting operations, both outside and inside.  Once this sampling has been completed, revisit and, if necessary, revise the abrasive blasting hoods available for employee use.
6. Develop and implement a sampling strategy for assessing respiratory hazards in welding operations.  This will included such chemicals as, but not limited to, lead, cadmium, calcium fluoride (fluorspar), chromium, cobalt, nickel, etc.  Once this sampling has been completed, revisit and if necessary, revise the blasting hoods available for employee use.
7. Utilize biological data from water analysis of cooling towers for trending to ensure control of bacteria.
8. Develop a more aggressive IH sampling strategy for employees performing stainless steel welding and gouging.
9. Ensure employees using lead containing solder are familiar with the OSHA Lead standard’s Appendices A and B.
10. Qualitative assessments for industrial hygiene exposures were done.  Improve the baseline by having an quantitative assessment (personal air monitoring) to determine employee exposure to such chemicals as lead (solder and paint), chromates (paint), and isopropanol.
11. Complete Carbon Monoxide sampling as per sampling strategy for the facility and adopt an assurance audit program addressing the sites sampling strategy program to ensure continued compliance.
12. Reevaluate and if necessary resample for carbon monoxide exposure on forklift drivers using 15 minute STEL’s.  This reevaluation would include those operations inside shipping and receiving.
13. Have temporary employment agency conduct baseline audiograms on those employees who work at the site for longer than 2 months.  These employees do the same type of work as the site employees and are exposed to the same noise levels.
14. It is recommended that calcium fluoride sampling be conducted for employees using welding rods in the 7000 series.  If needed the site should develop and implement the appropriate policies, procedures, and safe work practices. (X2)
15. It is recommended that industrial hygiene monitoring be conducted in those areas where gouging of stainless steel occurs.  If needed the site should develop and implement the appropriate policies, procedures, and safe work practices.
16. Since the site does not have an IH on site, it is recommended that an employee(s) attend Industrial Hygiene training such as that offered by TEEX institute, Mesquite, TX.  This training would help the company recognize health hazards associated in their work environment.
17. Assure personal washing facilities are in place for all employees including contractor employees.
18. Assure bulk sampling is performed on all sandblasting agents, i.e. “Black Beauty”.
19. During removal of pressure relief devices limit monitoring of pressure gauges by personnel to one shift.
20. Tthe facility should monitor for SO₂ in the spent acid loading area of the plant.
21. The Audit Team recommends that the facility improve the arrangement of the change room, the access foyer to the change room, and the lunchroom.
22. The facility needs to monitor for mercury exposure levels when a cell is first opened.
23. Boot/glove container near the tool room needs to be covered, and the area monitored for mercury.
24. The Audit Team recommends that the facility verify the area sampling data obtained with the Jerome meter for mercury by using appropriate badges.
25. The Audit Team recommends that the facility require employees to don hearing protection while using pneumatic tools.
26. Allow at least one of the nurses be allowed to attend Industrial Hygiene training, such as that provided by TEEX Institute, Mesquite, TX.  This training would help the nurses to recognize the health hazards in the work site where employees are working.

Routine Inspections:

1. The facility needs to provide improved hazard recognition training for employees conducting routine safety and health inspections of the facility.
2. It is recommended the site enhance the hazard recognition training for its employees at this site.
3. The employer should provide comprehensive hazard recognition training to employees performing the routine safety and health inspections of the workplace.
4. Provide additional hazard recognition training to employees.
5. Different employees should be put on audit teams and eliminate and all checklist inspections. Improve hazard recognition at the site for comprehensive audits. Consider including guards in HAZCOM training (even though they do not go into the plant proper). The guards make perimeter rounds and have detected leaks and spills during these rounds.

Trend Analysis:

1. Find opportunities to trend other safety and health related information besides injury/illness data that can improve the site’s ability to proactively identify safety and health hazards.

Hazard Analysis:

1. Complete BJA on welding operations.
2. The facility needs to conduct a job safety analysis on opening cells to reevaluate the PPE and engineering controls used to limit employee exposure.
3. The Audit Team recommends that the facility conduct a job observation on the individual with highest BEI in the cell maintenance group to possibly find ways to minimize exposure to mercury.

Pre-use Analysis:

1. Ensure all equipment which is new to the site is reviewed for safety and health issues, i.e., rental equipment.

Employee Hazard Reporting System:

1. Perform awareness training for all employees, including contractors, on the anonymous reporting of hazards to HES.

Hazard Prevention and Control

Engineering Controls:

1. During the annual evalution review jobs utilizing PPE for employee protection and reevaluate for possible replacement with feasible engineering controls.

Work Practice Controls/Safety and Health Rules:

1. Develop procedures for ensuring managers are adequately held responsible for safety and health rules violated by their employees.

Hazard Control Programs:

1. The facility needs to conduct a review of the site’s Energy Control Program to ensure that it is comprehensive and covers every possible source of energy for each piece of equipment at the site.
2. Ensure employees in units where Craft specific procedures for addressing LOTO are used have access to the procedures on the computer.
3. It is recommended that all units of the plant that do not have Craft-specific procedures for addressing LOTO be allowed to develop and implement them.
4. It is a recommendation that the refinery energy control procedures be evaluated to ensure adequacy of the procedures.  Blind lists and other energy isolation points should be included in this.
5. The audit team recommends that the facility conducts an evaluation of the site’s Energy Control Program and insures that locks are the preferred choice and used wherever possible.
6. The employer must establish a means to clearly and uniformly implement the site-specific written Lockout/Tagout procedures used at this facility.
7. The Confined Space Entry written procedures need to address site-specific options in the form of addendums.
8. The employer should consider establishing a confined space rescue team to help facilitate rescue activities.
9. The proper tags need to be used to improve the site’s Lockout/Tagout system.
10. The facility needs to conduct a survey to ensure that all confined spaces are properly labeled.
11. Review the lockout/tagout system to simplify procedures to eliminate unnecessary administrative tasks.

PPE:

1. A PPE Hazard Assessment must be done to determine if a safety toe shoes are necessary when operating cranes in your facility (per 1910.136).

Certified Professional Resources:

1. It is recommended that a corporate ergonomist or other certified professional visit the site and conduct an ergonomic survey.

Hazard Correction Tracking:

1. The site must ensure all safety and health items identified during self-inspections are tracked to completion.
2. Have a qualified person from the *** plant visit the *** site and train employees on the new tracking system.
3. Track and trend open actions items monthly and set realistic target dates.  Also close out the item after completion by notifying the employee who opened the item.
4. Complete tracking to completion of all PHA items.
5. Refine the SAP system.  Reclassify work orders to ensure the system is fully utilized and the number of outstanding work orders is minimized.  Safety related work orders should be identified in some manner such that the database can be queried and the status of safety related work orders determined.  All process critical equipment PMs and safety related work orders must be completed in a timely manner and not allowed to go uncompleted.

Ergonomics:

1. Utilize ergonomically-correct railcar chocks.
2. Ergonomic assessment should be prioritized for employees complaining of pain or discomfort.
3. Complete the full Ergonomic Program scheduled planned.

PSM:

1. The site must ensure necessary steps are taken to comply with PSM standard (29 CFR §1910.119) for Co-Generation unit.
2. Review P&ID’s in *** to ensure they are accurate. (X2)
3. Develop a plant-wide system to ensure that operators needing/requesting PSM refresher training are able to obtain the information they need for their job.
4. Change Training Needs Analysis (TNA) policy for PSM operator refresher training done annually to validate 33% of TNA’s on emergency procedures, and increase validation on normal procedures.
5. Allow for changing or extended due dates for action items (such as PHA action items), if necessary and legitimate reasons exist, so due dates which pass are undesirable.  Ensure action plans and/or interim steps to protect employees are developed.
6. Process Hazard Analysis for the Polypropylene Resins unit needs to be communicated to the affected employees, so they can better understand hazards and controls within the unit better.
7. Facility wide – an evaluation needs to be conducted to determine which personnel in each plant would benefit by being required to learn the findings and answers to the RC/PHAs done in their plant and the HAZOPs.
8. Need to analyze for dust during worst-case scenario in the Dry lab.
9. The audit team recommends that the facility consider conducting a process hazard review revalidation of the plants caustic process.
10. Continue the implementation of the Dakota Tracking System for PHA recommendations and populate the database with all outstanding PHA recommendations.  All PHA recommendations must be completed in a timely manner.
11. Identify a system that can be implemented sitewide to effectively manage the MOCs.   Ensure all MOCs can be appropriately tracked and are closed timely.  The system selected should allow for easy review of all open MOCs.

 

Preventive/Predictive Maintenance:

1. Develop a system to reduce the period of use of temporary leak repairs (ie, pipe clamps) whenever possible such as pre-fabrication of line, etc. and have it ready in a lay yard for a scheduled or unscheduled shutdown.
2. Ensure that the Risk Based Inspection Program is completed in the 2 year schedule that is outlined in the Mechanical Inspection System and be proactive in your external coatings program (painting program) by a) completing the initial assessment this year, b) follow API and RBI (American Petroleum Institute and Risked Based Inspection) recommendations as soon as possible and c) set the cycle to be completed every 5 years thereafter.
3. Complete preventive maintenance of all machines in the facility and adopt an assurance audit program addressing the sites predictive/preventive maintenance program ensuring compliance will continue.
4. Track and trend area calibration Preventive Maintenance deviation changes using confidence limits criteria.

Accident/Incident Investigations:

1. The Audit Team recommends that the facility develop written procedures to provide instructions and information on how to do a comprehensive root cause analysis for use by the facilities incident investigation team.

Medical Program:

1. It is recommended that employees be trained annually on the bloodborne pathogen’s exposure control plan.
2. It is recommended that all employees who do abrasive blasting have chest x-rays taken.  These x-rays should, as a minimum, be taken as a baseline and then at the termination of the operation for the employee, i.e., retirement, advancement, termination, etc.  A B-reader technician should read these x-rays.
3. The audit team recommends that the facility provide a current plan of action to be followed if a bloodborne pathogen exposure should occur at the site.
4. Investigate an eyewash for the sink in the UMS lab.  If eye wash is needed, then install a plumbed eye wash instead of small eye wash bottles.
5. Retrain employees on bloodborne pathogens.  This training would include how to properly respond to an emergency situation, how to properly protect themselves against the pathogens and how to properly clean up the effected area.
6. Verify preexisting disorders through medical prior to transferring employees from one section/area of the plant to another.

Emergency Preparedness:

1. Establish a system to communicate with the *** Operator working alone at night.
2. Establish system that allows truck drivers to call for help while unloading/loading hazardous materials.
3. The facility needs to develop a means to ensure that the egresses within the site meet the requirements of NFPA 101.
4. Replace all the tornado shelter signs.
5. It is a recommendation that in addition to the red paint indicating the location of a fire extinguisher that a sign with the legend “Fire Extinguisher” also be installed. Not all people can distinguish the color red from the color green.
6. Lighted exit signs are not working or need to be installed in…
7. When employees miss a scheduled drill or evacuation, they need to be verbally told about the drill and then physically walked through the exercise to the muster point.
8. It is recommended that the company devise a more efficient method for locating site personnel following emergency situations.  A card system or an electronic badge reader could accomplish this.
9. The audit team recommends the facility account for employees that are not present for an emergency evacuation drill and provide them with a suitable substitute.
10. The audit team recommends the facility develop specific procedures to inform employees of the proper action to take for the various emergencies that could occur at the site.
11. Develop an emergency action plan to reflect the sites current status.
12. Need to conduct the current annual evacuation drill.
13. Emergency procedures should have a provision created for inclement weather.
14. Upon their return, employees who miss a scheduled emergency evacuation drill should be walked through an individualized drill to the designated muster/shelter-in-place point.  The appropriate supervisor should record such activity.
15. All temporary employees be taken through a drill during the time they are on site.  This can be done either by an actual site-wide drill or by an individualized drill.
16. The site should conduct a tornado drill on an annual basis to ensure that employees can properly distinguish between and respond to various emergency drills.
17. Ensure that all employees are aware of the procedure for tornado emergencies.
18. Recommend that man down buttons be included on the radios.
19. Conduct weather emergency drills.

Safety and Health Training

1. Update the Training Management Plan to reflect only those employees currently remaining on site.
2. Evaluate operator training to ensure trainer/operators ensure trainees (operators in training) understand written operating procedures and ensure that the training materials cover all aspects of the operations.
3. Develop some method or training so employees can understand accessibility to safety and health information on the intranet.
4. Ensure employees understand how they can access information/status on the “Spot the Hazard Program”.

Miscellaneous:

1. The facility needs to develop a procedure to ensure contractors are setting up and operating cranes safely while they are working on site.
2. The team recommends that the facility install refrigerated air stations for employees that must work in high heat conditions.
3. A barrier must be placed in front of the electrical boxes where mobile cranes are parked.
4. The eyewash station must be removed or maintained.
5. All flammable aerosols must be stored in a flammable storage cabinet.
6. Policies or procedures must be put in place to cover the handling, storage, and maintenance of all slings.
7. It is a recommendation that the Powered Industrial Truck check-off sheets be reinstated at the beginning of each shift.
8. It is a recommendation that all cranes should have a check-off list addressing movement in all directions and travel of hoist including the upper limit switch. It should also cover cable condition and pendant cord condition.
9. It is a recommendation that signs indicating “Warning! Overhead Crane” be posted near/on all outside doors that enter into a crane bay area.
10. Guards for several drill presses need to be installed.  These guards have ordered.
11. Catalyst drum rotation device has exposed chain and sprockets.
12. Eye wash station SS#5 has restricted flow.
13. Level access to the remote robot in the additives area needs to guarded per 1910.212.
14. Copper tubing from A/C drain needs to be secured.
15. Fat drum area housekeeping needs to be completed.
16. The audit team recommends that the facility develop a systematic method for safe storage of compressed gas cylinders. The audit team recommends that the facility conducts a survey of the workplace to identify possible confined space situations with known hazards or which could develop a hazardous atmosphere.
17. Whenever possible, reduce the time period that temporary leak repairs (pipe clamps) are allowed to stay in place by pre-fabricating replacement lines so that they would be available for replacement during unscheduled downtimes.
18. Develop a safety procedure for welding.
19. Ensure documentation of grounding checks.
20. Welding cutting torch (acetylene and oxygen) needs to be removed or stored properly, since it hasn’t been used in years.
21. Recommend that electrical work being performed in isolated area be conducted by two employees.
22. Forklift training must be equipment specific for the type and size of equipment.
23. Repair the ladder next to the baler.
24. Cascader:  Extend the platform where employees work.
25. Install a guard on the C-Flute where the hot rollers are located.  This guarding would also include any other area where there are rotating parts. It is recommended that “bump” caps be mandatory in areas where employees are exposed to overhead hazards.
26. Review and if necessary replace the solid crossover strips on the conveyor systems.  These strips, which measure approximately 4 inches in width and are below the top of the rollers, are considered too small for safe passage over the system.  Employees use these crossover areas on a daily basis and also in an emergency situation.  Conveyors for the machines need to be stopped before employees cross over the system.
27. The employer needs to improve housekeeping in the maintenance shops.
28. Extend the walkway to the valves at the Emulsion Tank Farm from Tank 21 to Tank 23.
29. Evaluate and remove old catwalk on Solution Tank.
30. Evaluate the use of 5-gallon buckets used for mixture sampling on the truck loaders to eliminate possible tripping hazard on the walkway.
31. Use non pressurized solvents for cleaning/degreasing parts.
32. Add Harness and Sling inspection program to routine audit inspection covering items for all employees, including contractors on site.
33. Weigh all CO2 fire extinguishers quantitatively.
34. All drill presses to be guarded.
35. Assure radial arm saw retracts and is in complete compliance.
36. Review the existing MOC for the emergency lighting request in the Pharmaceutical Lab and install lighting as necessary.
37. Determine what is causing the water leak in the hallway next to the Special Lab and repair as necessary.
38. Develop and implement a plan for the installation of the new hoods in the Pharmaceutical Lab.  This plan should include which hood will be first and what precautions will be taken to protect the employees during the installation process.  It should also include the target installation date for all the hoods.
39. Review in plant traffic safety for compliance.