Process Safety Management Compliance Assurance Audit

Emergency Response Planning Evaluation

Emergency Response Planning is a significant concern from the highest levels of private and public organizations today. This concern relates to the potential for Technological, Natural, and Terrorist disasters. In 1998, the Federal Emergency Management Agency promulgated a program entitled Project Impact. As a result of the havoc caused by El Nino’ in 1998 and now La Nina, the need for thorough and accurate emergency response planning in communities and industrial settings has become an imperative. Project Impact is designed to accomplish this task by bringing together community leaders, industrial facilities, businesses, and citizens to plan for the advent of emergencies

On April 24, 1998, the Occupational Safety and Health Agency promulgated a directive, CPL 2-2.59A-Inspection Procedures for the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard, 29 CFR 1910.120. The stated purpose of the instruction is to establish policies and to provide clarification to ensure uniform enforcement of the HAZWOPER standard, which covers emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard. Within these instructions is an outline of the procedures for reviewing an emergency response plan, procedures for handling emergencies, training of emergency response personnel, medical surveillance of emergency personnel, and emergency equipment. The instructions also include the use of an Employee Interview Questionnaire.

Another consideration in the evaluation of emergency response planning programs must also be in consideration, where applicable, the OSHA’s Process Safety Management as a part of 29 CFR 1910.119 and the EPA’s Chemical Accidental Release Prevention (Risk Management Program) as a part of 40 CFR, Part 68. These programs are inclusive of almost every aspect of emergency response planning related to the potential for a release of highly hazardous chemicals. In fact, a facility to which these standards are applicable must submit no later than June 21, 1999 their plan to manage the risks of an accidental chemical release. This information will become a part of larger community-wide emergency response plans should an incident occur.

The evaluation of a facility’s emergency response planning program is completed inclusive of three separate projects, eventually compiling and analyzing the data gathered from each. These projects include:

Emergency Information Gathering

Facility Survey

Review of Documents

The format used to report the results of the project is to first outline the findings with a separate section outlining the recommendations.

The purpose of the evaluation is to insure preparation in the event of an emergency to insure appropriate emergency response to protect employees, property, the environment, and the public while meeting regulatory guidelines. Specifically, to evaluate the written emergency plan inplace, to develop any additional plans needed to respond to anticipated emergencies, and to devise a separate written document outlining specific actions to be taken in response to specific emergencies by Onscene Incident Commanders.

This evaluation is also conducted to document the efforts and methods used by the 's Management Team to meet specific regulatory standards. Documentation to insure proper emergency response planning research, documentation, implementation, and application as a concerned employer, demonstrating sound environmental stewardship.

Process Safety Management Compliance Audit

The conduction of a compliance audit is a requirement of 29 CFR 1910.119. The audit is required no less than every three years to investigate the employer's compliance with the Process Safety Management (PSM) standard.

The audit involves the verification of that each program element is inplace and implemented. This verification is divided into three parts:

• Records Review
• On-site Conditions
• Interviews

The records review is to evaluate the documentation of the programs as required by the PSM standard. This begins with a preliminary inspection to review the documentation for the entire PSM program to ascertain that all of the elements are developed.

The on-site conditions and interview are to confirm that the programs are implemented. This confirmation involves observing conditions and procedures, and interviewing the operators, maintenance personnel, engineering support staff, contractors and contractor employees, as appropriate, to determine whether the implemented program matches the program outlined by the documentation.

A more detailed investigation will cover all 14 elements. During these detailed assessments a review of the components from a representative number f processes, if multiple processes exist. To confirm implementation, a comparison shall be made of the conditions and the interview results wit both the minimum requirements of the PSM standard and the program outlined the employer's documents.

In order to gather the information needed to audit the program, the same questionnaire used by OSHA compliance officers is used so as to answer the following questions for each element:

An essential part of verifying program implementation is to audit the flow of information activities among the elements. When information in one element is changed or when action takes place in one element that affects other elements, a review of a sample of the related elements to see if the appropriate changes and follow-up actions have taken place.