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Course Material Overview of Process Safety Compliance with Standards
Process Hazard Analysis Standard Operating Procedures Safe Work Procedures Mechanical Integrity Management of Change Auditing Process Safety Systems Emergency Response Procedures This training on process safety was developed by the Center for Chemical Process Safety (CCPS), which is a Technology Alliance of the American Institute of Chemical Engineers. It was developed under an OSHA “Susan Harwood Grant”. We have just completed Module 8 on “Auditing Process Safety Systems.” This is module 9 of 9 and is entitled “Emergency Response Procedures”. This is the last module of the nine module training program.
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9. Emergency Planning and Response
Process Safety Management for Biofuels 9. Emergency Planning and Response 29 CFR (n) 29 CFR 29 CFR This material was produced under grant SH F-36 from the Occupational Safety and Health Administration, U.S. Department of Labor. It does not necessarily reflect the views or policies of the U.S. Department of Labor, nor does mention of trade names, commercial products, or organizations imply endorsement by the U.S. Government. Emergency Planning and Response procedures are required not only by OSHAs Process Safety standards, but also by other OSHA regulations which are referenced on this screen.
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S.S. Grandcamp Fire Source: Galveston News; Galveston, TX
A tragic example of a very poor emergency response is the S.S. Grandcamp fire in Texas City, Texas. About 8:00 a.m. on April 16, 1947, a fire was discovered by dock workers preparing to resume loading of ammonium nitrate aboard the S. S. Grandcamp at dock in Texas City at Pier "O“. The ammonium nitrate was bound for France and was to be used as a fertilizer for the production of crops in war-devastated Europe. The Texas City Volunteer fire department responded with thirty-one volunteer fireman and all equipment of the fire department. Source: Galveston News; Galveston, TX
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The S. S. GRANDCAMP exploded at 9:12 A. M
The S. S. GRANDCAMP exploded at 9:12 A. M. that morning and destroyed the entire dock area, numerous oil tanks, the near-by Monsanto Chemical Company, and numerous houses and business buildings. The blast killed all volunteer firemen at the scene and destroyed all fire equipment. A second ship also containing ammonium nitrate, the S. S. HIGH FLYER, was set afire by the first explosion. It exploded some sixteen hours later at 1:10 A. M., April 17, 1947. The loss of life was high because hundreds of spectators had gathered on a near-by pier to observe the fire. Practically all the spectators were killed, as were many employees at the Monsanto Chemical Company, and numerous employees throughout the dock area. The official death toll was put at 581. A remaining 113 people were classified as missing. The burning ship had been evacuated, but no attempt was ever made to evacuate the dock areas of spectators. Damage to property outside the dock area was widespread. Approximately 1,000 residences and business buildings suffered either major structural damage or were totally destroyed. Practically every window exposed to the blast in the corporate limits of Texas City was broken. Several plate glass windows as far away as Galveston (10 miles) were shattered. Flying steel fragments and portions of the cargo were found 13,000 feet distant. A great number of balls of sisal twine, many afire, were blown over the area like torches. Burning wreckage ignited everything within miles, including dozens of oil storage tanks and chemical tanks. Drill stems 30 feet long, 6 3/8 inches in diameter, and weighing 2700 pounds, part of the cargo of the S. S. GRANDCAMP, were found buried 6 feet in the clay soil a distance of 13,000 feet from the point of the explosion. Source: TEXAS CITY, TEXAS, DISASTER April 16, 17, 1947 FIRE PREVENTION AND ENGINEERING BUREAU OF TEXAS DALLAS, TEXAS and THE NATIONAL BOARD OF FIRE UNDERWRITERS NEW YORK, New York
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S. S. Grandcamp Anchor This file has been (or is hereby) released into the public domain by its author, Provines at the Wikipedia project. This applies worldwide. A 2 ton anchor of the Grandcamp was hurled 1.62 miles (2.61 km) and found in a 10-foot (3 m) crater. It now rests in a memorial park. The other main 5 ton anchor was hurled 1/2 mile (800 m) to the entrance of the Texas City Dike, and rests on a Texas shaped memorial at the entrance.
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Emergency Planning and Response Requirements for Process Safety Management 1910.119(n)
The employer shall establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR (Emergency Action Plans). In addition, the Emergency Action Plan shall include procedures for handling small releases. Employers covered under this standard may also be subject to the hazardous waste and emergency response provisions contained in 29 CFR (a), (p) and (q).
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Emergency Action Plans under 1910.38
An Emergency Action Plan must be: In writing Kept in the workplace Available to all employees for review An employer who has ten (10) or fewer employees can communicate the plan orally to the employees, but it is recommended to have it in writing. An Emergency Action Plan must be: In writing Kept in the workplace Available to all employees for review An employer who has ten (10) or fewer employees can communicate the plan orally to the employees, but it is recommended to have it in writing.
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Minimum Elements of an Emergency Action Plan 1910.38
Procedures for reporting a fire or other emergency Procedures for emergency evacuation Emergency shutdown procedures Procedures to account for all workers Procedures to be followed by employees performing rescue or medical duties This slide and the next list ten minimum elements that an emergency action plan must include: Procedures for reporting a fire, chemical release, or other emergency; Procedures for emergency evacuation, including type of evacuation and exit route assignments; Procedures to be followed by employees who remain to operate critical plant operations before they evacuate; Procedures to account for all employees after evacuation; Procedures to be followed by employees performing rescue or medical duties;
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Minimum Elements of an Emergency Action Plan 1910.38
The name or job title of every employee who has duties under the plan 7. An employee alarm system Training Review with each employees 10. Practice drills The name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan. The employer must have and maintain an employee alarm system with a distinctive signal for each purpose. An employer must designate and train employees to assist in a safe and orderly evacuation of other employees. An employer must review the emergency action plan with each employee covered by the plan: When the plan is developed or the employee is assigned initially to a job; When the employee's responsibilities under the plan change; and When the plan is changed. 10. Practice drills must be conducted on a regular basis to make sure all employees are aware of the proper evacuation procedures.
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Hazardous Waste Operations and Emergency Response – 1910.120
The following operations are covered by : Clean-up operations required by a governmental body. Corrective actions involving clean-up operations at sites covered by the Resource Conservation and Recovery Act of 1976 (RCRA). Voluntary clean-up at uncontrolled hazardous waste sites. Emergency Response Plans are required for the following operations, unless the employer can demonstrate that the operation does not involve employee exposure or the reasonable possibility for employee exposure to safety or health hazards. Clean-up operations required by a governmental body, whether Federal, state local or other involving hazardous substances that are conducted at uncontrolled hazardous waste sites; Corrective actions involving clean-up operations at sites covered by the Resource Conservation and Recovery Act of 1976 (RCRA); Voluntary clean-up operations at sites recognized by Federal, state, local or other governmental bodies as uncontrolled hazardous waste sites; Operations involving hazardous waste that are conducted at treatment, storage, disposal (TSD) facilities regulated by the Resource Conservation and Recovery Act; or by agencies under agreement with U.S.E.P.A. to implement RCRA regulations; Emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard.
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Examples of Hazardous Waste Streams for Biofuels
Strong acids or bases. Wash water wastes not discharged to an approved wastewater treatment plant. Methanol waste that is not reclaimed. Materials from the transesterification process, such as sulfuric acid. Glycerin (that cannot be reclaimed for further use or is sent off-site). Examples of Hazardous Waste Streams for Biofuels which may be subject to CFR Hazardous Waste Operations and Emergency Response include: • Strong acids or bases (unused excess, off-specification materials or spent materials). • Wash water wastes not discharged to an approved wastewater treatment plant. • Methanol waste that is not reclaimed. • Materials from the transesterification process, such as sulfuric acid. • Paint waste. • Washer solvent. • Sludges from floor drains, sand pits. • Parts washer solvent, sludges or filters. • Aerosol cans. • Glycerin (that cannot be reclaimed for further use or is sent off-site). In addition, the following waste streams may require special handling: • Mercury containing lamps, such as fluorescent or high intensity discharge lamps. • Electronics and Used oil.
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Emergency Response Plan Requirements under 1910.120
Not all biofuel sites will be covered under this regulation. For addition information on the specific requirements of Hazardous Waste Operations and Emergency Response – , and to determine if your site is covered, please visit the OSHA and open the link for regulation Not all biofuel sites will be covered under this regulation. For additional information on the specific requirements of , please visit the OSHA and open the link for regulation
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Emergency Plan Manager
One employee, the Emergency Plan Manager, needs to be responsible for managing the emergency program at your organization. The Emergency Plan Manager maintains all documentation for the plan, works with plant management to schedule all drills, and is responsible for all training records. The Emergency Plan Manager is also responsible for company coordination with local public resources, such as fire department and emergency medical personnel. This position should report to the site’s executive management.
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Emergency Response Checklist
Texas Emergency Action Plan Checklist The Texas Department of Insurance, Division of Workers’ Compensation contracted with the Occupational Safety and Health Consultation Program to prepare a guide to assist employers and employees in complying with the requirements of the OSHA’s Emergency Action Plan standard, 29 CFR A link to the guide, Texas Emergency Action Plan Checklist, is given in this slide. Click on the icon to view a copy of the checklist. This guide is not intended to supersede the requirements of the standard. An employer should review the standard for particular requirements that are applicable to their individual situation, and make adjustments to this program that are specific to their company. An employer will need to add information relevant to their particular facility in order to develop an effective, comprehensive program.
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Incident Commander An incident commander needs to be designated and identified for any incident situation. This person has the responsibility of coordinating all responders, both onsite and offsite. This person should be uniquely identifiable and in communication with the various response team members. This person is responsible for establishing a command post and lines of communication.
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Incident command structure
Your emergency response plan must be a written plan that details the responsibilities of each plant associates that will be a member of the emergency response team. Command and control duties should be clearly specified. The plan should list the specific duties of each individual member of the response team. An Emergency Response Plan (ERP) booklet should be prepared and given to all employees. It should also be readily available at several specific locations throughout your facility. Each ERP position should have a back-up individual designated.
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Emergency Response Equipment
Emergency response equipment should be stored in a readily accessible location on the perimeter of the unit for which the equipment is designated. This equipment should include fire fighting equipment, respirators, and other Personal Protective Equipment (PPE) that would be needed for an emergency.
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Fires Extinguisher Training
P.A.S.S. All employees should be trained in the use of a portable fire extinguisher. A practice session should also be conducted in an open area with the local fire department present. Numerous Internet resources exist on fire extinguisher training. The details of such training are beyond the scope of this course; but you are referred to the OSHA training location listed in this slide for a discussion of the PASS method of fire extinguisher training.
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Fires Extinguisher Training
P = Pull A = Aim S = Squeeze S = Sweep The PASS technique involves the following: Make sure the fire is small enough to be fought with a portable extinguisher. Make sure you know what type of fire is burning and what type of extinguisher should be used for that type fire. You MUST have fire extinguisher training to know this information. Make sure you have an exit at your back. If the first three items are in order, take the appropriate fire extinguisher, make sure it is fully charged, and PULL the pin to release the lever of the extinguisher. AIM the nozzle of the extinguisher at the base of the fire. SQUEEZE the lever to start discharging the fire fighting agent. SWEEP the nozzle at the base of the fire to start extinguishing the fire. You are referred to the OSHA site on the previous slide for more detailed training. The OSHA site includes a short five question test to check your learning experience.
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1. Reporting the Emergency
The first step in reporting a fire, chemical release, or other emergency at a biofuels facility is to activate the alarm. After insuring his own safety, the person activating the alarm should then contact the individual designated in the Emergency Response Plan (ERP). Normally, this would be the Plant Security Center. Plant Security would then activate the response plan by calling or contacting the plant emergency responders. Plant security should have an ERP contact list with the names and phone numbers of the individuals to contact in case of an emergency situation. It is imperative that this list be maintained up-to-date. Since an emergency can occur any time day or night, the plant emergency list should be immediately available to security. A computer terminal is recommended. If a fire or emergency situation occurs after normal business hours, a responsible person should contact all employees not on shift of future work status, depending on the nature of the situation.
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Building alarm system In the event of a fire or emergency situation, the facility should ensure that all employees are notified as soon as possible using the building alarm system. The building alarm system should include both audible and visual alarms, 24 hours a day. Special instructions can be given to employees via a building public address system.
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Employee Alarm Evacuation Fire
The employee alarm system should provide warning for necessary emergency action as called for in the emergency action plan, or for reaction time for safe escape of employees from the workplace. An employee alarm system can be any piece of equipment and/or device designed to inform employees that an emergency exists or to signal the presence of a hazard requiring urgent attention. National Fire Protection Association (NFPA) 72, National Fire Alarm Code, requires a fire alarm signal to be distinctive in sound from other signals and can not be used for any other purpose. Audible alarms include bells, horns, sirens, voice announcement systems, and other devices that can be distinguished above and apart from the normal sound level within the workplace.
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Employee Alarm Evacuation Fire
The standard audible emergency evacuation signal consists of a "three-pulse" temporal pattern. Three successive "on" phases, lasting 0.5 second each, must be separated by 0.5 second of "off" time. Then, at the completion of the third "on" phase there must be 1.5 seconds of "off" time before the full cycle is repeated. Therefore, the total cycle should last 4.0 seconds (0.5 second "on," 0.5 second "off," 0.5 second "on," 0.5 second "off", 0.5 second "on," 1.5 seconds "off”.) A recommended alarm for a fire would be one with an ascending tone. A recommended chemical release alarm would be descending tones. This can easily be remembered by employees as “fire, up” and “chemicals, down”, indicating that fire flames point upward and that most chemicals are heavier than air.
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2. Evacuation Emergency evacuation escape routes Designated assembly areas Emergency evacuation escape route plans should be posted in designated areas throughout the company. Bulletin boards and control rooms are ideal locations. In the event that a fire/emergency alarm is sounded or instructions for evacuation are given, all employees (except those designated to shutdown the processes) should immediately exit the building(s) at the nearest exits as shown in the escape route plans, and should meet as soon as possible at the designated assembly area. Employees with offices should close the doors (unlocked) as they exit the area. Mobility impaired employees and their assigned assistants will gather at the designated area within the building to ensure safe evacuation in the pre-determined fashion.
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Telephones If there are customers, clients, or visitors in the building, they should be advised to stay in the building for their safety. Unless there is an imminent threat, they should then be allowed to call their emergency contacts to let them know where they are and that they are safe. Company employees should turn on their alternative voice mail message. The voice mail recording should indicate that the business is closed, and that staff and visitors will be remaining in the building until authorities advise that it is safe to leave.
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Exit the building In the event that a fire/emergency alarm is sounded or instructions for evacuation are given, all employees (except those designated to perform emergency shutdown) should immediately exit the plant buildings at the nearest exits, and should proceed to the designated assembly area.
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Evacuation and Wind Direction
Wind direction will influence the evacuation route and the employee evacuation area. Always check the wind direction during an emergency evacuation. Evacuate across wind unless you are upwind of the emergency. The next slide will provide an evacuation illustration.
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Evacuation and Wind Direction
X Your Location Release Wind Direction X Evacuation Direction Release point Wind Direction This slide provides an illustration of proper across wind evacuation direction.
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3. Emergency Shutdown In the event that evacuation of the premises is necessary, some equipment may need to be shut down to prevent release of hazardous materials. The designated individuals may remain for the prescribed amount of time to secure the process equipment to which they have been assigned. All individuals remaining behind to shut down critical systems or utilities should be capable of recognizing when to abandon the operation or task. Once the equipment has been secured, or the situation becomes too dangerous to remain, these individuals should exit the building by the nearest escape route as soon as possible and meet the remainder of the employees at the designated assembly area.
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4. Assembly Location To ensure the fastest, most accurate accountability of your employees, make sure you have the following steps in your emergency action plan: Designate an assembly areas or areas where employees should gather after evacuating. Make sure your assembly areas have sufficient space to accommodate all of your employees. Exterior assembly areas are typically located in parking lots or other open areas away from busy streets. All associates should be trained in orderly evacuations and trained to walk, not run, during an evacuation.
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4. Employee Accounting 2. Have designated group leaders to take a head count after the evacuation. The group leaders should have a current list of all employees in their group. Scanned ID badges are invaluable in determining who is on-site. 3. Identify the names and last known locations of anyone not accounted for and pass them to the incident commander. Accounting for all employees following an evacuation is critical. 4. Establish a method for accounting for non-employees such as suppliers, contractors, visitors, and customers; 5. Establish procedures for further evacuation in case the incident expands. This may consist of sending employees home by normal means or providing them with public transportation to an offsite location.
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5. Rescue Duties Your Emergency Response Plan should have written procedures to be followed by employees performing rescue duties. These employees should receive special first-aid training for their assigned duties. Under no circumstances should an employee attempt to fight a fire that has passed the incipient stage (that which can be put out with a fire extinguisher). Neither should an employee attempt to enter a burning building to conduct search and rescue. These actions should be left to emergency services professionals who have the necessary training, equipment, and experience.
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Medical Aid Under no circumstances should an employee provide advanced medical care and treatment to a fellow worker. These situations should be left to emergency services professionals who have the necessary training, equipment, and experience. Untrained individuals may endanger themselves and/or those they are trying to assist.
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6. Sheltering in Place In the event that chemical contaminants are released into the environment in such quantity and/or proximity to the facility, authorities and the Emergency Response Coordinator may determine that it is safer to remain indoors rather than to evacuate employees. The Emergency Action Plan Manager should announce “Shelter in Place” status by public address system or other means of immediate notification available at the worksite. For a “Shelter in Place” location select an interior room above the ground floor, with the fewest windows or vents. The rooms should have adequate space for everyone to be able to sit. Avoid overcrowding by selecting several rooms if necessary. Large storage closets, utility rooms, copy and conference rooms without exterior windows will work well. Avoid selecting rooms with mechanical equipment like ventilation blowers or pipes because this equipment may not be able to be sealed from the outdoors. It is ideal to have a hard-wired telephone in the room you select. Cellular telephone equipment may be overwhelmed or damaged during an emergency. Call emergency contacts and have the telephone available if you need to report a life-threatening condition.
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6. Sheltering in Place All customers and visitors should move immediately to the “Shelter In Place” locations within the building, as designated by their host. A “Roll Call Leader” should write down the names of everyone in the room, and call the Incident Commander to report who is in the room and their company affiliation. A responsible person should monitor radio, television and Internet reports for further instructions from authorities to determine when it is safe to leave the building.
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Disable HVAC In the event that a “Shelter-In-Place” is decided upon, designated employees should quickly lock exterior doors and close windows. Those familiar with the building’s mechanical systems should turn off the heating and air conditioning systems, especially those systems that automatically provide for exchange of inside air with outside air. If there is a danger of explosion, employees should close the window blinds or curtains.
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7. Severe Weather The Emergency Action Plan Manager should announce severe weather alerts (such as tornados) by the public address system. Employees should immediately retreat to the designated areas, away from windows, and stay until the threat of severe weather has passed as communicated by the Emergency Action Plan Manager.
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8. Re-entry Once the plant facility has been evacuated, no one should be allowed to re-enter for any reason, except for designated and properly trained rescue personnel (such as fire department and emergency medical professionals). All employees should remain at the Designated Assembly Area until the fire department or other emergency response agency notifies the incident commander that either: the site is safe for re-entry, in which case personnel should return to their workstations; or the site area is not safe, in which case personnel should be instructed on vacating the premises.
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All clear Workplace Announcement System Speakers can be used to play a live or recorded voice message for the all clear. Radio communication to those that were responsible for employee accounting is another effective way of communicating an “all clear”. More detailed information on OSHA’s requirements for employee alarm systems can be found at the website accessed by clicking on the alarm light in this slide.
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9. Training An employer must designate and train employees to assist in a safe and orderly evacuation of other employees. Items to be reviewed during the training include: proper housekeeping; fire prevention practices; fire extinguisher locations, usage, and limitations; threats, hazards, and protective actions; means of reporting fires and other emergencies; names of Emergency Action Plan Manager and Coordinators; individual responsibilities; alarm systems; escape routes and procedures; emergency shut-down procedures; procedures for accounting for employees and visitors; closing doors; sheltering in place; severe weather procedures; and Emergency Action Plan availability.
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Review Plan An employer must review the emergency action plan with each employee covered by the plan: When the plan is developed or the employee is initially assigned to a job; When the employee's responsibilities under the plan change; and When the plan is changed.
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Fire/Evacuation Drills
10. Practice Drills Fire/Evacuation Drills At least annually In coordination with local police and fire departments Post response evaluation Fire/Evacuation drills should be conducted at least annually, and should be conducted in coordination with local police and fire departments. Additional drills should be conducted if physical properties of the business change, processes change, or as otherwise deemed necessary. Following each drill, responsible management and employee representatives should evaluate the drill for effectiveness and weaknesses in the plan. Needed changes should be implemented to improve the plan.
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Completion of Course Material
Overview of Process Safety Compliance with Standards Process Hazard Analysis Standard Operating Procedures Safe Work Procedures Mechanical Integrity Management of Change Auditing Process Safety systems Emergency Response Procedures We have just completed Module 9 on “Emergency Response Procedures”. This training module was the ninth of nine modules contained in this course. A short summary of the course material will follow. After the summary proceed to the Module Nine review questions to complete the training course.
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Summary of Course Material
Overview of Process Safety Compliance with Standards Process Hazard Analysis Standard Operating Procedures Safe Work Procedures Mechanical Integrity Management of Change Auditing Process Safety systems Emergency Response Procedures In Module 1, Overview of Process Safety, Process Safety Management was defined as “a management system that is focused on prevention of, preparedness for, mitigation of, response to, and restoration from catastrophic releases of chemicals or energy from a process associated with a facility.” In Module 2, Compliance with Standards, the flammability, toxicity, and contact hazards associated with biofuels was briefly discussed. The OSHA regulations and standards that are in place to prevent injuries in the process industries were referenced. In Module 3, Process Hazard Analysis, a technique was introduced for understanding failure events and the consequences of these events on health (including public health), environment, and property. In Module 4, Standard Operating Procedures, the importance of having written procedures for process operations was discussed.
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Summary of Course Material
Overview of Process Safety Compliance with Standards Process Hazard Analysis Standard Operating Procedures Safe Work Procedures Mechanical Integrity Management of Change Auditing Process Safety systems Emergency Response Procedures In Module 5, Safe Work Procedures, the importance of having written procedures for nonroutine work activities that may impact your biofuel process was discussed. In Module 6, Mechanical Integrity, a programmed implementation of activities to ensure that critical equipment will be suitable for its intended application throughout the life of the process was discussed. In Module 7, Management of Change, written procedures to manage changes to process chemicals, technology, equipment, and procedures were discussed. In Module 8, Auditing Process Safety Systems, a management system was introduced to ensure that procedures were in place and functioning in a manner to protect employees, customers, communities, the environment, and physical assets against process safety incidents. In Module 9, we just discussed the importance of having written procedures and an emergency command structure for response to emergency situations.
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