Revising Required Procedures

The review and approval process for procedures for the toll needs to be clearly understood between the toller and their client. This can be addressed in the management of change system. A preliminary process or batch procedure may be written or proposed as part of the toller selection process or may be included in the initial 

The individuals and firm most familiar with the technology should review the intermediate and final procedures to assure both safety and commercial interests are satisfied. In many batch operations the procedure(s) can be a substantial portion of the process technology package. The procedures represent both a major safety system as well as a propriety technology. The pre-startup review should assure both PHA related and other changes proposed to the procedures have been approved and implemented. 

The types of procedures to be developed or revised for a new toll can be organized into the following major categories  

Process specifications will typically be set forth in the process technology package. However, a process hazard analysis (PHA) in preparation for startup may reveal additional useful measurements or sample points. These may be analyses or measurements for the startup period or for the life of the toll. 

If the technical staff from the client company recognizes that a toller may be asked to perform new analyses and make operating decisions based upon the results, the client may help the toller develop the needed procedures and skills required to make these decisions. Typically a round robin laboratory qualification exercise will be performed. Samples of known standards and unknown concentrations of the materials to be analyzed for the toll will be prepared and sent to both laboratories. This can help ensure that equipment calibration is synchronized and that the toller is capable of performing accurate measurements. In some cases, the toller may be the party with the chemical, process, or synthesis specific expertise. 

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A consensus body consisting of volunteer safety professionals who create or revise documents on test requirements, procedural methods, and product specifications. It... 

The employer must ensure that the employees who will be in or near a PRCS can demonstrate proficiency in the duties required, including new and revised PRCS procedures. 

BS OHSAS 18001 2007. Occupational Health and Safety Management Systems— Requirements, a British Standards Institution pubhcation. In the 2007 revision, requirements for risk assessments are more explicit. The guidehnes now say The organization shall estabhsh, implement and maintain a procedure(s) for the ongoing hazard identification, risk assessment, and determination of necessary controls. Significantly, the term tolerable risk was replaced by acceptable risk. ... 

Restart Criteria 3 and 5 require procedure development for, or revision to, the programs listed in Attachment L The items listed in Attachment 1 are specific Charlotte and WISR commitments, which are identified to assure that these activities are tracked and included in the procedures work scope. 

As discussed in Chapter 2, The Toller Selection Process, evaluating the site s safe work practice procedures should have been a part of the review during the toller selection process. Still, new materials may indicate a need to revise or develop special procedures to address unique chemical and physical hazards. New hazards such as vacuum, ciyogenics, ultra-high pressure, or new rotating equipment could be introduced. Medical monitoring requirements or special handling and spill response procedures for the toll s raw materials and products may indicate a need to write or revise safe work practices. 

The tolling team has analyzed the hazards, addressed the risks and modifications using a management of change system, revised and written procedures, trained the workers, performed a PSSR, and completed any required test runs. The pre-startup phase is complete at this point. 

The standard requires that a master list or equivalent document contol procedure identifying the current revision status of documents be established and be readify available to preclude the use of invalid and/or obsolete documents. It is important to note that this requirement only applies to documents and not to data. 

These common requirements were then used to develop management standards, guidance documents, and new or revised procedures and work instructions for integrated ESH activities. In some cases, the integration went beyond ESH boundaries and also included engineering, maintenance, and technology centers. 

Some situations, however result in the form of second-order diffferential equations, which often give rise to problems of the split boundary type. In order to solve this type of problem, an iterative method of solution is required, in which an unknown condition at the starting point is guessed, the differential equation integrated twice and the resulting solution compared with a known boundary condition, obtained at the end point of the calculation. Any error between the known value and the calculated value can then be used to revise the initial starting guess for the next iteration. This procedure is then repeated until... 

The conditions under which the material is tested are crucial. The top of the exposure chamber must be sealed and the tank should contain no free air space. A stirring mechanism in the tank keeps the leachate mixture homogeneous and a heater block keeps it at an elevated temperature as required for the test. Stress conditions of the material in the field should also be simulated as closely as possible. The original U.S. EPA Method 9090 test included a rack to hold specimens under stress conditions but was revised when some materials shrank in the leachate. Due to the hazardous nature of the material, testing should be performed in a contained environment and safety procedures should be rigorously followed. 

Random selection of sequences and generation of new solutions using a crossover procedure. The location of crossover in the sequences is also chosen randomly. Since the crossover may result to an impossible sequence, a checking and revision procedure is required. The type of this procedure depends on the type of process synthesized. 

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