2004-9-I-GA-1

Develop written procedures that require a comprehensive hazard analysis of new processes, especially those involving reactive chemistry. Ensure the hazard evaluations address critical process controls, overpressure protection, alarms, and other equipment such as vent collection/containment devices to minimize the possibility and consequences of a toxic or flammable release.
Status: C-AA

2004-9-I-GA-2

Provide EPA Risk Management Program regulation and OSHA Process Safety Management program training to affected personnel to ensure that the facility understands the scope and application of each regulation, and implements all requirements prior to receiving and using covered chemicals.
Status: C-AA

2004-9-I-GA-3

Create a comprehensive emergency response plan and provide equipment and training that is appropriate to the duties assigned to employees in the event of an emergency.
Status: C-AA

2004-9-I-GA-4

Implement written tolling procedures using resources such as the CCPS book Process Safety in Outsourced Manufacturing Operations. Ensure effective communication between the toller (MFG) and client throughout the process development, completion of a detailed process hazard analysis, creation of emergency procedures, and dissemination to all parties who would be involved in emergency response situations.
Status: C-AA

2004-9-I-GA-5

Implement written procedures for tolling agreements using resources such as the CCPS book Process Safety in Outsourced Manufacturing Operations. Ensure that tolling agreements provide for: - Direct GPC involvement in new process development, including the detailed process hazard analysis and emergency planning, - Active participation in the first production run, as appropriate.
Status: C-AA

2004-9-I-GA-6

Revise the applicable sections of the Allyl Alcohol Product Safety Bulletin, appendices, and web page, to emphasize the applicability of the EPA Risk Management Program regulation and OSHA Process Safety Management standard. Clearly identify the threshold quantity of allyl alcohol applicable to each regulation.
Status: C-AA

2004-9-I-GA-7

Revise the customer site safety assessment process, clearly addressing both PSM and Risk Management Program applicability before shipping allyl alcohol to a new customer. Include a requirement to review the customer's program documents, including the (draft) RMP, and internal and external safety audit or assessment records. Require that appropriate Lyondell health, safety, and environmental personnel review the written customer safety assessment before approving the shipment of allyl alcohol.
Status: O-ARE/AR

2004-9-I-GA-8

Establish, equip, and train a hazardous materials response team. Work with the Whitfield County Emergency Management Agency to update the Emergency Operations Plan, clearly defining the roles and responsibilities of the response team.
Status: C-AA

2004-9-I-GA-9

Revise fire department and police department procedures and training to clearly define facility and evacuation zone access control responsibilities when hazardous chemicals are involved or suspected in an emergency.
Status: O-ARE/AR

2004-9-I-GA-10

Establish a Local Emergency Planning Committee to assist the Whitfield County Emergency Management Agency to: - Develop site-specific agency emergency response plans and standard operating procedures, - Develop training programs and conduct drills for emergencies at fixed facilities, - Educate the community regarding proper protective actions, such as shelter-in-place and evacuation procedures.
Status: O-ARE/AR

2004-9-I-GA-11

Work with the City of Dalton, representatives from local facilities, and relevant community representatives to review and revise the Emergency Operations Plan to: -Update the list of facilities handling hazardous chemicals, including those covered by the EPA Risk Management Program regulation, -Develop standard operating procedures addressing communication of emergency information, evacuation, and shelter-in-place, -Conduct community training and drills that involve operation of the emergency notification system and potential actions in the event of an emergency, -Implement an automated community emergency notification system.
Status: O-ARE/AR

2004-9-I-GA-12

Clearly designate and define the roles of the agencies responsible for ensuring compliance with all sections of the SARA Title III (Emergency Planning and Community Right-to-Know Act) including review of Local Emergency Response Plans and accompanying attachments, such as standard operating procedures.
Status: C-AA

2004-9-I-GA-13

Designate a responsible agency and develop a system that will encourage and assist local authorities to obtain and use Risk Management Plans for those facilities that are required to develop this information to aid in the development of the site-specific emergency response plans.
Status: O-ARAR

2004-9-I-GA-14

Revise the SOCMA website to simplify locating the link to the CSB website www.csb.gov, such as adding a link in "More Resources" on the SOCMA home page. Ensure that the CSB website and the report Hazard Investigation: Improving Reactive Hazard Management, Report No. 2001-01-H can be easily located using the SOCMA website search engine.
Status: C-AA

2004-9-I-GA-15

Develop a ChemStewards Management System Guidance Module that addresses tolling, including the best practices described in the CCPS book Process Safety in Outsourced Manufacturing Operations, and emergency planning involving new products.
Status: O-ARE/AR

2004-9-I-GA-16

Develop a formal training module for the ChemStewards Management System Tolling Guidance Module and provide appropriate training to SOCMA member companies. Include in the training program a discussion on the tolling issues identified in the MFG report.
Status: O-ARE/AR