Hazard Audits

The use of audit (inspection) instruments can help determine whether controls are in place and are utilized. It will convey to some extent the overall effectiveness of your hazard control process. Audits will provide information on control processes and techniques that are not functioning correctly. The effectiveness of yonr hazard control procedures can only be accomplished if they are implemented. Therefore, periodic reviews and audits will confirm or disavow that employees are familiar and following the hazard control processes and procedure that the company has implemented. These audits will help identify hazards and issues that have transpired since the previous audit or inspection (see Chapters 7 and 14). 

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The scope, organization, format, review method, final report, and frequency are discussed as they apply to research projects. The concept of tailoring the review method to the degree of hazard involved is explained and an example of a Process Hazards Review and a Pre-Startup Review/Process Hazards Audit are given. 

The ultimate objectives of the Du Pont Company s Process Hazards Reviews, and Pre-Startup Reviews/Process Hazards Audits, are to ... 

The terms Process Hazards Review and Pre-Startup Review/Process Hazards Audit have been mentioned and are defined. 

Process Hazards Reviews comprise formal committee meetings where hours are spent intensively examining, by one of the methods described later, a chemical reaction or process, with a report, documentation, and follow-up. Pre-Startup Reviews/Process Hazards Audits are no less intensive, but the time spent is less, because the complexity of the process or equipment being examined is less. Reports, documentation, and follow-up are also a part of the Pre-Startup Review/Process Hazards Audit. An equipment acceptance safety inspection would be considered a Process Hazards Audit. 

These guidelines are not meant to be all inclusive and there are cases where a combination of less hazardous conditions can create a need for a Process Hazards Review or a Pre-Startup Review/Process Hazards Audit,... 

The next example is of a Pre-Startup Review or a Process Hazards Audit held on a piece of purchased processing equipment, a Haake Rheocord Torque Rheometer and Laboratory Twin-screw Extruder. The organization responsible for this extruder has a standard checklist of eleven pages of items to be considered by the technical person or persons in charge of the equipment or process, before the review is held. Copies of the completed checklist are then sent to each committee member before the meeting for review. Generally, in a review of this type, the group will convene at the location of the equipment rather than in a conference room to go over the material provided. In this case, the committee consisted of ... 

Process Safety Analysis This part treats the analysis of a process or project from the standpoint of hazards, risks, procedures for making potential damage estimates, and project reviews and audits. It can be helpful to management in assessing risks in a project. It consists of the following ... 

Facilities Reviews There are many lands of facilities reviews that are useful in detec ting and preventing process safety problems. They include pre-start-up reviews (before the plant operates), new-plant reviews (the plant has started, but is stiU new), reviews of existing plants (safety, technology, and operations audits and reviews), management reviews, critical instrument reviews, and hazardous materials transportation reviews. 

Management Operating policies and procedures Training for vapor release prevention and control Audits and inspections Equipment testing Maintenance program Management of modifications and changes to prevent new hazards Security... 

Does the facility evaluate (for example, audit) the off-site waste management facilities used to manage hazardous wastes If yes, do the evaluations ensure that wastes will be handled safely, without causing harm to waste handlers, the public, or the environment Flave the reviews been documented ... 

A basie safety audit eovering design and system of work features to be eovered for the loading/ unloading of non-pressurized hazardous liquids to/from tankers of tank eontainers is given in Table 15.18. 

Table 15.18 Basic safety audit checklist for loading/unloading non-pressurised hazardous liquids tankers or tank containers...

Now you can reconsider the material balance equations by adding those additional factors identified in the previous step. If necessary, estimates of unaccountable losses will have to be calculated. Note that, in the case of a relatively simple manufacturing plant, preparation of a preliminary material-balance system and its refinement (Steps 14 and 15) can usefully be combined. For more-complex P2 assessments, however, two separate steps are likely to be more appropriate. An important rule to remember is that the inputs should ideally equal the outputs - but in practice this will rarely be the case. Some judgment will be required to determine what level of accuracy is acceptable, and we should have an idea as to what the unlikely sources of errors are (e.g., evaporative losses from outside holding ponds may be a materials loss we cannot accurately account for). In the case of high concentrations of hazardous wastes, accurate measurements are needed to develop cost-effective waste-reduction options. It is possible that the material balance for a number of unit operations will need to be repeated. Again, continue to review, refine, and, where necessary, expand your database. The compilation of accurate and comprehensive data is essential for a successful P2 audit and subsequent waste-reduction action plan. Remember - you can t reduce what you don t know is therel... 

The safety status of the process should be periodically reviewed against the guiding principles for the original design. Monitoring of add-ons can detect potentially dangerous modifications. Process hazards analysis or process safety audits are useful tools for this review. Documentation of inherently safer principles is critical to ensure that future changes don t nullify the positive features of the initial installation. 

We put a lot of effort into improving safety by adding protective equipment onto our plants, new and old gas detectors, emergency isolation valves, interlocks, steam curtains, fire insulation, catchment pits for LPG storage tanks, and so on. We also introduced new procedures, such as hazard and operability studies and modification control, or persuaded people to follow old ones, such as permits-to-work and audits. 

The audit/inspeetion form that you should use ean be developed from the safety plan. A qualified person should examine the safety plan and eome up with a eheeklist that should serve as an audit/inspeetion form. Allowanees should be made to inelude items not speeifieally noted in the safety plan but that may be observed during field walk-throughs. Certain highly pertinent seetions of what OSHA uses when performing a eomplianee inspeetion of hazardous waste sites is ineluded in Appendix D. This inspeetion/audit form eovers many of the basies and ean be used a general guide. 

In the last chapter we discussed the importance of well-defined roles. This holds true for the inspection team. For many larger sites a union contract may exist that may specify who participates in the inspec-tion/audit process. At smaller sites, this may be open-ended. We believe that the personnel make-up of an inspection team should depend on the size, complexity, number of employees, and on-site hazards at the site in question. Again, preplanning coupled with a common-sense approach should be the driver. 

The audit team found that at Sites B and H, safety and health personnel had suflfieient authority in most eases to thoroughly implement the safety and health plans. To faeilitate safety and health eom-plianee, anyone who entered Site H, ineluding delivery personnel, was required to view a brief video that summarized the site history and remediation operations, identified the hazardous substanees monitored on site, and deseribed site evaeuation proeedures. Site B s SSAHP did not mention speeifie subeontraetors and their roles and responsibilities however, it did indieate that the prime eontraetor had oversight responsibility for all safety and health aetivities and the authority to diseontinue or modify site operations when unsafe eonditions were deteeted. 

The OSHA audit teams found program defieieneies in two related areas the development of task- and operation-speeifie hazard analyses and the eonduet of monitoring programs designed to eharaeterize employee exposures to hazardous materials. These defieieneies are dis-eussed in more detail below. 

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. 

Requirements for written safety and health SOPs are found in paragraphs (b)(4)(I) of the HAZWOPER standard. None of the sites audited had developed comprehensive, site-specific SOPs that specify the controls necessary to complete each task. The contractor s SSAHP at Site B did discuss generic task-related hazards and SOPs however, the task-specific SOPs lacked detail. Eor example, the SOPs did not specifically identify the site locations where hazards were likely to occur, nor did they specify the appropriate types of controls. 

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. 

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