Plan implementation

In 1966, the Los Angeles Air Pollution Control Board designated trichloroethylene as a photochemically reactive solvent that decomposes in the lower atmosphere, contributing to air pollution. In 1970 all states were requited to submit pollution control plans to EPA to meet national air quaUty standards. These plans, known as State Implementation Plans (SIPS), controlled trichloroethylene as a volatile organic compound (VOC). They were designed to have each state achieve the National Ambient Air QuaUty Standard (NAAQS) for ozone. The regulations were estabUshed to control the emission of precursors for ozone, of which trichloroethylene is one. 

To provide basic geographic units for the air-pollution control program, the United States was divided into 247 air quahty control regions (AQCRs). By a standard rollback approach, the total quantity of pollution in a region was estimated, the quantity of pollution that could be tolerated without exceeding standards was then calculated, and the degree of reduction called tor was determined. States were required by EPA to develop state implementation plans (SIPs) to achieve comphance. 

The bubble may be only used for pollutants in an area where the state implementation plan has an approved schedule to meet air-quahty standards for that pollutant. 

CFR Part 51 (Appendix M) State implementation plans Method 201A Particulate matter of less than or equal to 10 ig (PM 10)... 

The states are required to submit to the federal Environmental Protection Agency (EPA) plans, known as State Implementation Plans (SIP), showing how they will achieve the standards in their jurisdictions within a specified time period. If after that time period there are areas within the states where these standards have not been attained, the states are required to submit and obtain EPA approval of revised plans to achieve the standards in these "nonattainment" areas. EPA also designates certain areas where the standards are being met, but which have the potential for future nonattainment, as Air Quality Maintenance Areas (AQMA). Such regions have stricter requirements than attainment areas for the granting of permits for new sources of the pollutant not in attainment status. 

EPA has 45 days to review each permit and to object to permits that violate the CAAA. If EPA fails to object to a permit that violates the Act or the implementation plan, any person may petition EPA to object within 60 days following EPA s 45-day review period, and EPA must grant or deny the permit within 60 days. Judicial review of EPA s decision on a citizen s petition can occur in the federal court of appeals. The public is guaranteed the right to inspect and review all permit applicahons and documents. There are provisions for three kinds of permit revisions administrative amendment, minor permit modification, and significant modification. 

Accountants, administrators, agricultural commissioners, air monitoring, supervisors, coordinators (environmental health project, grants, quality assurance, special project and state implementation plan), grants analysts, officers (enforcement, hearings, staff services, technical services and training), supervisors, and technical advisors. 

State Implementation Plan (SIP) a collection of regulations used by the state to carry out its responsibilities under the Clean Air Act. 

Implementation plan A plan that makes practical provision to ensure that set environmental standards are met. 

A plan is more than a list of goals, a bar chart, or a schedule of activities. For the business plan to be effective it needs to define how the measures it covers are to be achieved and the resources to achieve them obtained. There may well be supplementary plans for this purpose. The plan or plans also need to define who is to be responsible for achieving the goals and implementing the plans. Once this is done and the provisions communicated to those affected, a method of tracking achievement can be put in place. To track performance effectively the implementation of the plan needs to be phased such that target dates are set for the determination and acquisition of resources, the issue of detail implementation plans, the organization of work, and the completion of individual tasks. 

Having agreed on PSM goals and objectives, your next step is to conduct a more detailed assessment of the present status of PSM activities within your company, to form the basis for your implementation plan. This baseline assessment works against both the model you have selected for PSM and the characteristics that describe a sound management system, such as those described by CCPS. 

Remember that homegrown solutions are frequently better received (and thus more effectively applied) than totally new approaches that seem to be artificially created and imposed. The more transferable ideas you are able to identify and incorporate into your implementation plan, the greater the likelihood of its success. 

Assessment results reflect the method selected. Any assessment you conduct will involve sampling of documentation and interviews with the people involved in program development and implementation. The scope and depth of your fact-finding and verification efforts will determine how detailed an Implementation plan can be developed. 

For example, a facility manager may be confident that PSM policies and procedures are in place, but line personnel may indicate in the same survey that they are unaware of them—suggesting a gap that your implementation plan should address. 

The two reports may be very similan it may be wise to confine reports to facilities to strictly factual findings, leaving interviewers opinions and ideas for review by the PSM tecim to determine their value and potential application to the implementation plan. 

In all cases the preliminary work (obtaining commitment, defining goals, and evaluating the current status) provides most of the information you will need to select and develop an implementation plan. 

If an element has a formal system that isn t followed, this suggests either a problem with the system itself (e.g., flawed design, impractical, insufficient detail or explanation) or a failure of management (e.g., inadequate supervision, lack of training, no followthrough or enforcement, or inadequate resources). Whatever the cause, you will want to make note of it and try to address it in your implementation plan. 

The basis for your program plan should be your team s assessment of the current PSM status (Figure 4-11), which will have yielded a list of deficiencies compared with the required PSM elements. These gaps must now be translated into statements of required tasks, which in turn suggest work products for inclusion in your implementation plan. For example, your assessment shows that the process knowledge and documentation management system needs improvement. To address this gap you need to plan a series of tasks. 

The implementation plan you and your team developed (Chapter 5) provides the framework for the installation phase it defines your strategy, priorities, resources, and timetable. The specific PSM systems you have designed (Chapter 6) provide the substance they ate the activities you plan to install. What remains is the series of tasks requited to translate words on paper into tangible action. 

Schedule. Compare progress to date with timelines established in the implementation plan. 

As part of developing the PSM implementation plan (Chapter 5), you and the team identified benefits unique to the approach you selected, using them to help win management s approval. For example, your plan may focus on priority elements because the assessment you conducted suggests that this method will yield the greatest overall improvement in safety performance. And, as part of the pilot test described in this chapter, you focused on facility-specific benefits to enlist the support of local management and staff. 

Progress report. Where we are today, compared with initial estimates and det ed plan. Use your original presentation (Chapter 2) and the implementation plan (Chapter 5) for comparison purposes, focusing on tasks, timetables, and resource requirements (prelected vs. revised vs. actual). 

An effective implementation plan for any new management system must consider a number of different issues ... 

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