Workshop W Passionate about Safety: Love All Your Jobs! Successful - - PDF document

Workshop W

Passionate about Safety: Love All Your Jobs! Successful Integration of Safety & Environmental … Managing Risks for Both

Tuesday, March 24, 2020 3:30 p.m. to 4:45 p.m.

Biographical Information

Anita Evenson, Senior Consultant Trinity Consultants, Inc. 1717 Dixie Highway Suite 900, Covington, Kentucky (859) 341-8100 x 116 aevenson@trinityconsultants.com Anita serves as a senior consultant in Trinity’s Covington/Greater Cincinnati office as an experienced air permitting and compliance expert with more than 15 years of high-level performance in the environmental consulting and engineering fields. This includes project management and technical experience in air quality permitting, emission inventories, regulatory compliance support, multi-media environmental assessments, and complex permitting compliance efforts surrounding CAM plans, several MACTs, Title V renewals, synthetic minor permits (including NSR and PSD analysis), and other engineering

• projects. Routinely assists clients in complying with complex environmental regulations.

Develops air emission inventories for plastics, resins, coating, steel mills, automotive, food and flavoring clients that involves site evaluations, process analysis, extensive records review, and detailed calculations of potential and actual emissions. Anita is a graduate of Rose-Hulman Institute of Technology with a B.S. in Chemical Engineering. Sherry Vaughn, HS&E Manager The J.M. Smucker Company 5204 Spring Grove Avenue, Cincinnati, Ohio (513)482-8035 sherry.vaughn@jmsmucker.com Sherry served our country in the Army and worked as an EMT in Cincinnati prior to beginning her career at The J.M. Smucker Crisco facility in 1997. At that time the

• perations were owned by Proctor and Gamble. In 2001, Smucker purchased the Crisco

and JIF brands. She has expert knowledge of the St. Bernard facility working as a refinery and packing line operator, fire protection technician, IH&S coordinator, and now HS&E manager. Sherry is a graduate of Thomas More with a B.S. in Business Administration.

March 27, 2020 S ession W

Love All Y

• ur Jobs!

Integrating and Managing Risk for S afety and Environmental Programs

Introductions

Anita Evenson – Senior Consultant

˃ S

tarted at Trinity December 2017 via acquisition of QS EM

˃ Experience serving a wide range of industries

and clients across Indiana and Ohio

˃ B.S

. Chemical Engineering Rose-Hulman

˃ Based out of the Covington, KY / Greater

Cincinnati office

Introductions

Sherry Vaughn – HS&E Manager

˃ U.S

. Army Reserves 1991-1998

˃ S

tarted at P&G in January of 1997

˃ The J.M. S

mucker Company acquired the Jif and Crisco brand in 2001

˃ B.S

. Business Administration, Thomas More College

˃ Works for Cincinnati plant in the Ivorydale facility in S

t. Bernard, Ohio

Presentation Agenda

˃ Commonalities

 Training  Audits/ inspections  Recordkeeping and reporting  Regulatory changes

˃ Environmental

 Resources  Regulatory programs  Best practices

˃ S

afety

 Resources  Regulations  Fire S

afety Regulations

 Fire and Environmental Disasters

Environmental and Safety Commonalities

Training Effectiveness

Immediate Use of Learning – 90% Practice by Doing – 75% Discussion Group – 50% Demonstration – 30% Audio‐visual – 20% Reading – 10% Lecture – 5%

Training Basics

˃ Audience ˃ Goals

 Meet OS

HA and EP A regulatory requirements

 Drive positive outcomes- no inj uries, no violations  S

pecific to facility

˃ Types

 Demonstrations  On-line modules  Classroom/ presentations

˃ Frequency

 New hires  Calendar based  As necessary

Training Best Practices

˃ Lead by example ˃ Have an agenda ˃ Know your students ˃ Knowledge/ retention checks ˃ Use technology/ aids ˃ Vary teaching styles ˃ Employee engagement

 Assign individual/ group responsibilities  Incentive programs

Audits and Inspections

Types of Audits

˃ Environmental ˃ Health and S

afety

˃ Management S

ystems

˃ S

upplier/ Vendor Audits

˃ S

tandard Operating Procedures

˃ Cultural Assessment ˃ Due Diligence ˃ Regulatory Inspections

Why Conduct an Audit?

˃ Identify and assess compliance with applicable

regulations and requirements

˃ Identify areas of risk or liability ˃ Identify opportunities to reduce costs ˃ Response to stakeholder requests for increased

disclosure

˃ Audits required as part of enforcement proceedings ˃ Audit privilege/ self-disclosure

Identifying EHS Issues - The Hard Way

˃ Regulatory inspection findings ˃ Enforcement actions against you ˃ Enforcement actions against others

 Other company facilities  Competitor facilities

Identifying EHS Issues –A Better Approach

˃

Voluntary Audits

˃

Routine internal reporting and review

˃

Compliance management system reviews

˃

S elf-inspections

˃

Peer / industry contacts and sharing

˃

Certification

Common Audit Findings

˃ Improper waste handling and

labeling

˃ Lack of permitting ˃ Missing records ˃ S

afety specific findings

 Unguarded equipment  Equipment not secured  Electrical  Ladders  S

afety equipment

Recordkeeping and Reporting

Managing Environmental Records

˃ Example Records:

 Inspection reports  Maintenance records  Log books  Lab/ test reports  Training records  Monitoring records  Report repositories  Processed manifests  Manufacturer’s

procedures

˃ Common Issues:

 Unable to locate  Records kept in

multiple locations

 Multiple sources of

similar data / conflicting records

 Disorganized records  Incomplete records  Inaccurate records

Develop Recordkeeping System

˃ One-stop shop for all safety and environmental records ˃ S

elect technology

˃ Develop S

OP

 Users/ access  File organization

˃ Define key record attributes

 Location or process for locating  Frequency  Owner/ responsible position  Format

˃ Clearly Identify compliance/ regulatory data ˃ Periodic record reviews ˃ QA/ QC process

Compliance Calendar Benefits

˃ Track key deadlines and have a process to keep it current ˃ Alert stakeholders

 Operations  S

upervisors

 Management

˃ Use technology to enhance visibility of deadlines to multiple

interested stakeholders; make it easy for stakeholders

˃ Consider development of interim/ internal milestones or

deadlines for maj or reports or other multi-step regulatory tasks

˃ Implement hierarchy of notifications ˃ Integrate the use of compliance calendar for status and

planning meetings

Best Practices for Reporting Calculations

˃ Multiply & divide numbers as well as units of measure ˃ Carry at least 5 sig figs in intermediate calculations ˃ Report 2 sig figs ˃ Report calculated numbers to either:

 The number of digits required by instructions  The number of sig figs determined by the lowest sig fig

number in the calculation

˃ Rounding: If the 1st digit to be discarded

 is 4 or less do not round up  is >5 or if 5 and the next digit is not 0,then round the last

digit you report up by one

 Is exactly 5 followed by a 0, only round up if an odd number

Recordkeeping Best Practices

˃ Document, Document, Document!

 Always assume that someone with little knowledge of your

processes is going to need to read and understand any chemical inventory determinations ˃ Manage your S

DS in a centralized location that will safe-guard against inadvertent compliance concerns

˃ Cross-check your programs against others that are completed

• n-site

˃ Conduct quarterly (or more!) meetings among program leads ˃ Centralize calculations that are applicable to multiple

programs for maximum efficiency and consistency

˃ Consider a site-specific spreadsheet/ database/ software

solution for automating threshold calculations where possible

Recordkeeping Best Practices

˃ Centralized system ˃ Use EMS ˃ Involve operators

 Train  Assign roles

˃ Date stamp & sign incoming mail ˃ QA all records

Regulatory Changes

Identify Regulatory Changes

˃ Example Changes:

 New federal

regulations

♦EP

A

♦OS

HA

 New state regulations  EP

A memos

 Regulation and policy

changes

˃ Common Issues:

 No knowledge of the

change

 Misunderstanding the

regulatory applicability

 Not incorporating

appropriate and timely changes into processes / training

Develop Regulatory Change Assessment Process

˃ S

creen and evaluate regulatory changes

˃ Develop a standardized process:

 S

creening: categorically not applicable, document non- applicability

 Applicability: complete an applicability assessment  Impact Assessment: understand the regulation  Implementation Plan: Develop and implement change plan

˃ Utilize consultants’ expertise ˃ Ensure any changes are communicated to key personnel ˃ Leverage subscription services ˃ Document findings for future reference

Environmental Topics

Facility Resources

˃ Internal ˃ Corporate ˃ Environmental

management system

˃ File review at local/ state

level

Federal Resources

˃ Environmental Compliance History Online

(ECHO)/ Envirofacts

˃ Federal Register (FR) ˃ Electronic Code of Federal Regulations (eCFR) ˃ TRI Explorer ˃ RS

EI Model

Ohio Digital Resources

˃ Electronic permits ˃ Engineering Guides ˃ Ohio eBusiness

 Air S

ervices

 eDMR  eDrums

Indiana Digital Resources

˃ Electronic permits ˃ Virtual Filing Cabinet ˃ Electronic reports

 EMITS  Tier II Manager  NetDMR

Kentucky Digital Resources

˃ KY One S

top Business Portal

 Electronic S

ubmittals

 EEC eForms  EIS

submittal using ePortal

˃ DEP S

earch Online

 Permit status  Rules under review

˃ NetDMR ˃ Tier II Manager

Louisville Digital Resources

˃ Louisville Metro Air Pollution Control District

“ The District”

˃ S

eparate regulatory entity

˃ Title V permits online ˃ No electronic permit or testing submittal portal ˃ S

LEIS (S tate and Local Emissions Inventory S ystem)

Regulatory Environmental Programs

˃ What programs

apply to my facility?

˃ How are programs

managed?

˃ Overlap between

programs

Air Permitting Programs

˃ Title V facility ˃ S

ynthetic minor source

˃ Minor source ˃ Permit-by-

rule/ exemption

˃ Registration

Wastewater Permitting Programs

˃ Individual ˃ General ˃ Pretreatment ˃ S

tormwater

˃ No exposure

Waste Regulatory Programs

˃ Hazardous Waste Generators Improvement Rule ˃ Hazardous waste category ˃ Use universal waste and used oil programs ˃ Keys to compliance

 Recordkeeping  Training

Facility Plans

˃ S

PCC- S pill Prevention, Control, and Countermeasure Plan

˃ FRP- Facility Response

Plan

˃ S

WPPP- S tormwater Pollution Prevention Plan

˃ RMP- Risk Management

Plan

Community-Right-to-Know Programs

˃ S

ection 302 Emergency Planning Notification

˃ S

ection 311 S DS reporting

˃ S

ection 312 Inventory (Tier I/ II) Reporting

˃ S

ection 313 Toxic Release Inventory Reporting (TRI)

TSCA Chemical Data Reporting (CDR)

˃ 40 CFR 711 ˃ Primary reporting year is 2019 ˃ 2016, 2017, and 2018 production data is also required ˃ NOTE: EP

A proposed revisions on April 25, 2019

 Update the definition of small manufacturers  Add exemptions  Form updates

˃ Electronic reporting through e-CDR and CDX to submit

TSCA Chemical Data Reporting (CDR) Starting the Process

˃ Review the 2016 reports ˃ Were new process streams or chemical substances

added after 2015?

 Consider all intermediate streams

˃ Ongoing tracking sheets for future reporting ˃ New due date November 1, 2020 ˃ https:/ / www.epa.gov/ chemical-data-reporting

Questions to Ask DAILY

˃ Do you know if you are doing

everything you are supposed to be doing?

˃ Can you prove you are doing

everything you are supposed to be doing?

˃ Is all of your compliance

documentation easily accessible?

Safety and OSHA

Occupational Heath and Safety Administration (OSHA)

˃ Develops and enforces regulations for employers to

protect workers in the workplace from health and safety related hazards

˃ Purpose was to “ assure so far as possible every

working man and woman in the nation safe and healthful working conditions and to preserve our human resources”

State OSHA and Federal OSHA

OSHA Resources

˃ OS

HA ’s website https:/ / www.osha.gov

˃

Call OS HA to report emergencies, unsafe working conditions, safety and health violations, to file a complaint, or to ask safety and health questions.

800-321-6742 (OS HA)

Write OS

HA

U.S . Department of Labor Occupational S afety & Health Administration 200 Constitution Avenue, NW Room Number N3626 Washington, D.C. 20210

Email OSHA Go to their website and fill out the form.

https://www.osha.gov/ecor_form.html

Subscribe to OS

HA ’ S weekly newsletter Quick Takes - https://www.osha.gov/quicktakes/#subscribe

Ohio OSHA

State Plans

˃ There are twenty-eight OS

HA-approved S tate Plans, operating state-wide occupational safety and health programs.

˃ S

tate Plans are required to have standards and enforcement programs that are at least as effective as OS HA's and may have different or more stringent requirements.

Kentucky/ Indiana OSHA

Worker fatalities according to Bureau of Labor Statistics FY 2018

˃ 5,250 workers died on the j ob in 2018

which equals more than 100 a week or more than 14 deaths every day.

˃ Out of 4,779 worker fatalities in private

industry in calendar year 2018, 1,008 or 21.1% were in construction —that is, one in five worker deaths last year were in construction.

OSHA Top Ten Citations 29 CFR – FY 2018

˃ Fall Protection, construction (1926.501) ˃ Hazard Communication standard (1910.1200) ˃ S

caffolding Construction (1926.451)

˃ Respiratory Protection (1910.134) ˃ Control of Hazardous Energy (LOTO) (1910.147) ˃ Ladders, construction (1926.1053) ˃ Powered Industrial Trucks (1910.178) ˃ Fall Protection –Training (1926.503) ˃ Machinery and Machine Guarding (1910.212) ˃ Eye and Face Protection (1926.102)

Follow the Right Rules

˃ General Industry (CFR 29 1910) ˃ Construction(CFR 29 1926)

 There are differences in some of the rules

♦Fall protection for General Industry is 4ft ♦Construction it is 6ft

From Construction Deaths

˃ Falls – 338 out of 1,008 total deaths in

construction in CY 2018 (33.5% )

˃ S

truck by Obj ect – 112 (11.1% )

˃ Electrocutions – 86 (8.5%

)

˃ Caught-in/ between – 55 (5.5%

)

OSHA – General Duty Clause

˃ S

ets two (2) duties for employers

 Provide a place of employment free from

recognized hazards

 Comply with OS

HA standards and regulations

˃ S

ets one (1) duty for employees

 Comply with applicable OS

HA standards and regulations

Record Retention

˃ Maintain for 5 years plus current year

 OS

HA 300 log - OS

HA 300 Log must be updated during the five-year storage period for identified new recordables or changes in classification of prior recordables

 OS

HA 300-A summary

 OS

HA 301 incident report

 Privacy case list, if one exists  Requirements for Electronic filing of OS

HA Form 300A (https:/ / www.osha.gov/ inj uryreporting/ )

Fire Safety and Codes

˃ The NFP

A is the leader in Fire and Life S afety Codes.

˃ The S

tate fire codes can also be more stringent than the NFP A.

˃ There are also local fire codes specific to the AHJ

(Authority Having Jurisdiction)

˃ The NFP

A should be considered the bare minimum

Why Follow the Codes?

˃ Because S

herry is a Pain in the neck… … .

˃ S

• me may say yes…

˃ To not repeat tragic fire events of the past

Fire Disaster Case Studies

Triangle Shirtwaist Fire March 25, 1911

Triangle Shirtwaist Fire

Triangle Shirtwaist Fire

Beverly Hills Supper Club

May 28, 1977

Beverly Hills Supper Club

Beverly Hills Supper Club

Beverly Hills Supper Club

How did these events help us?

Triangle Shirt Factory Fire

˃ After this disaster a commission was formed ˃ Out of the investigation some of the first fire safety

regulations were recommended

 Issues of occupancy limits  S

izes and widths of doors, windows, aisle ways, and egress

˃ Fire prevention measures established

 Cover for gas lighting  S

moking prohibition of owners and workers

 Fireproof receptacles  Fire drills

How did these events help us?

Beverly Hills Supper Club

˃ S

tricter rules on flammable wall coverings

˃ Regulations against “ old technology” aluminum wiring ˃ S

tricter enforcement of regulations needed

 S

taircases were enclosed

 Many state and government officials visited

˃ Building was not equipped with sprinkler protection or fire

alarm systems.

˃ Positive results

 Building requirements were enhanced to make night clubs and

• ther buildings with large populations safer from fire

 Designs for improved exiting systems, safer interior finishes,

emergency planning, and installed fire alarms and automatic fire suppression systems

How YOU can help!!

˃ It is important to pay attention to fire

safety, look for the following items or scenarios… .

 Missing Fire Extinguishers  Hot Work Permits when required  S

moking on company property

 Leaking fire sprinklers  Water bubbling up through concrete

(possible broken underground lines)

Fire safety tips we can use everywhere

˃ Look for alternate exits ˃ In hotels count the number of room doors to the fire

exit

˃ Look up at the ceiling for fire sprinklers ˃ Locate emergency pull boxes and fire extinguishers ˃ Ask if the fire alarm system is operational

Environmental Case Studies- “BIG” Accidents

They Make Movies about YOU!

BP’s Deep Water Horizon

Environmental Disasters- Movies and Books!

Erin Brockovich

˃ This film tells the true story of Erin Brockovich, a legal assistant who discovers that the groundwater in Hinkley, California, is seriously contaminated. From 1952 to 1966, Pacific Gas & Electric dumped around 370 million gallons of chromium 6-tainted

• wastewater. The energy company ended up

paying $333 million, the largest settlement in a direct-action lawsuit in U.S . history

Chernobyl 2019 Miniseries

On April 26, 1986, a reactor shutdown was experienced at the Chernobyl Nuclear Facility near the now-abandoned town of Pripyat, in northern Ukrainian S

• viet S
• cialist Republic, S
• viet Union. A

runaway nuclear reaction resulted in a horrific fire and explosion, claiming the lives of 50 personnel instantly and expelling more than 400 times the radiation released during the Hiroshima atom bomb. More than 4000 cancer deaths have been linked with the extensive spread of radioactive substances. Belarus was heavily affected and radioactive contamination was detected as far as the British Isles. Radiation levels at the site are still high and the amount of nuclear materials buried under the debris remains unknown. The series won 2 golden globes in 2020 for best actor and best limited series, 24 years after the accident!

Environmental Disaster Movie

The Exxon Valdez Oil S pill On March 24, 1989, the Exxon Valdez oil tanker hit a reef in Prince William S

• und off the coast of Alaska, causing 11
• f its cargo tanks to rupture and dump 10.8 million gallons
• f crude that eventually covered 11,000 miles of ocean. It

was one of the most destructive human-caused environmental disasters with both long-term and short- term effects. The instant outcome included the deaths of 100,000 to 250,000 seabirds, at least 2,800 sea otters, 300 harbor seals, 247 bald eagles, and 22 orcas, and unidentified numbers of salmon and herring. Cleanup began immediately, but despite thousands of personnel helping over the years, the spill still wouldn’ t be fully cleaned up even decades later.

Environmental Wrap Up

˃ In the area of Environmental, we do not get 2nd chances ˃ Do the right thing FIRS

T

˃ Be aware of surroundings ˃ When in doubt, ask … ˃ Don’ t become a best selling movie or book ˃ Report all incidents

EHS is a Dynamic, Changing Field

Always be certain to obtain the latest forms, policies, and regulations from the appropriate regulatory authority before determining permitting and compliance needs for your site. The information provided in this manual, while up-to-date when printed, is subject to change as regulatory authorities update forms, policies and regulations. Y

• u are encouraged to use this manual as an

educational reference, but it is not a substitute for independent research and verification, and the application of sound professional judgment and analysis in real-time permitting and compliance situations.

Questions?

Anita Evenson aevenson@ trinityconsultants.com Trinity Covington Office 859-341-8100 x 116 S herry Vaughn S herry.Vaughn@ j msmucker.com S mucker-Cincinnati 513-482-8035

?