Monitoring, contractors

PANELIST BLOOM I don t know of any effort toward expanding an effort like C. F. Braun s. We have a new contractor/monitor of gasification programs, or maybe even broader than that, in the UOP SDC contract with fossil fuel. I don t know what their emission is in this regard. The C. F. Braun studies were part of the... 

Direct and supervise the work of the engineering contractor, monitoring its procedures, staffing, and performance to insure that the quality, cost, and schedule objectives are met without unnecessary expense and within timing constraints. 

The contractor at Site H had established area and personnel sampling consistent with HAZWOPER requirements. A photo ionization detector (PID) and a real-time aerosol monitor (RAM) were used on a daily basis to screen for potentially hazardous levels of contaminants. On a weekly basis, personal air samples were collected and submitted for laboratory analysis. PPE requirements, however, were often not based on this data because the oversight agency had established inflexible minimum PPE requirements. The audit team found many of the PPE requirements on Site H to be excessive in light of site monitoring data and hazard determinations. 

Contractors at Sites B, D, G, I, and J had incomplete sampling practices and as a result were not able to evaluate PPE levels based on monitoring data. Eor example, both contractors SSAHPs at Site I lacked provisions for monitoring site hazards such as metals, pesticides, herbicides, and semi-volatile organic compounds (SVOCs) that could not be evaluated with a PID. Since worker exposures to the range of hazards on site had not been characterized, PPE was not selected based on its performance relative to the nature and level of site hazards. 

The sampling and monitoring frequencies specified in the Site B site contractor s SSAHP were not consistent with HAZWOPER requirements since the plan based monitoring frequency on prior sampling results alone and did not consider other factors such as the performance... 

Site H was the only site at which the contractor had implemented comprehensive and effective site control elements. The Site H contractor had established site work zones, a buddy system, and site communication procedures consistent with 1910.120(d). This contractor had also established exclusion zones and contamination reduction zones to control migration of site contaminants to clean areas of the site when work within these areas introduced the potential for exposure to hazardous contaminants. The audit team supported this contractor s use of flexible and temporary work zone boundaries based on monitoring results and hazard determinations. 

The bench where decontamination took place was only a few feet from the thermal unit and was not isolated from exclusion zone activities employees moved freely between their work stations in the exclusion zone and the decontamination bench. In addition, the subcontractor did not conduct monitoring activities to support work zone designations. Neither Site K contractor used warning signs to delineate exclusion zones, as required by their respective health and safety plans. 

Contractors at Sites C and H had acceptable programs for monitoring the effectiveness of PPE and decontamination procedures. The Site H contractor had established PPE and decontamination programs consistent with HAZWOPER requirements. The Site C contractor developed decontamination procedures that included specifications for periodically evaluating the effectiveness of decontamination methods... 

L. A medical surveillance program must be in place to assess and monitor the health and fitness of employees. A medical surveillance program helps assess and monitor the health and fitness of employees working with hazardous substances. The contractors at Sites A, E, H, and K and one subcontractor at Site I appear to have established medical surveillance programs that with minor exceptions were consistent with HAZWOPER requirements. 

The problem manifested itself as an equipment problem, namely a leaking flange joint. The department broadly responsible for this area (but not for implementing, monitoring, and subsequent recommendations) is the engineering department, as the specialist contractors work for them. The critical event took place during a corrective maintenance operation. From here, two separate root causes were identified, based on the data from the investigation. 

There are legitimate reasons why a contract can fall behind, and some of these are referred to in (1) to (8) above. However, item (8) must not be tolerated, and the contractor should be taken to task early in the contract when this occurs. Close monitoring will show how the contractor is progressing, and where the contractor has fallen down so badly that there seems to be no end to the contract, and then the client should seriously consider determining the contract. 

Reliable contractors should carry out all boiler treatment and cleaning. Boilers are fired pressure vessels and are subject to mandatory insurance inspections. Significant benefits in safe and economic operation, particularly by reducing unnecessary chemical treatment, can be achieved by monitoring the condition of boilers. 

Sponsor Monitoring. Another important oversight process to ensure quality, compliance, and subject safety, monitors may be employees of the sponsor s medical staff or a contract research organization, or may be independent contractors. In each... 

Do you have programs to monitor that contractors are working safely ... 

There was no procedure to evacuate nonessential personnel from the area in the case of a high LET alarm or a power failure. Because the contractors and some other workers in the area do not have radios to monitor unit communications, they would not know to leave the area unless the evacuation alarm was sounded. (Emergency planning and response)... 

AM. Plant fire brigade reaches the emergency location. They see fire engulfing catalyst prep area (automatic deluge sprinkler had actuated, but no water was available) see the lead outside operator down about 40 feet from the catalyst prep area, find the injured (unidentified at that time) service contractor about 120 feet away, Plant fire brigade then tries to activate a fixed monitor, but no water flows, sends one brigade member to fire pump house to check pump status. 

Results on the refinement of protocols for sampling analysis are forthcoming in the report on the EPA/NBS workshop on monitoring. Additional work on statistical design is also in progress to find practical ways to reduce required sample size which in turn leads to reductions in cost and more efficiency in dealing with contractor release after abatement. 

Contractor or vendor upgrades or maintenance activities, especially when performed remotely (i.e., over a network), should be monitored carefully because they can introduce changes that might otherwise go unnoticed and have an adverse effect on a validated system. 

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