OCCUPTIONAL SAFETY AND HEALTH(ERP)

EMERGENCY PLAN AND SAFETY PROGRAM

The employer prepares a process hazard analysis using an expert team that includes at least one employee familiar with the operation. The team identifies, evaluates, and proposes controls for hazards in this analysis. A history of previous incidents at the facility is included. The document anticipates the consequences to health and safety of a system failure. The employer responds to and resolves problems uncovered in the analysis in a timely manner. Management updates the study every five years, and retains these records for the life of the process facility.

How does a team determine the potential hazards at a facility? OSHA does not specify a method. Four approaches are commonly employed, any one of which works 3. An example in the “what if?” approach. The process is broken down into a series of steps, and for each step a series of “what if” questions are asked. What if the valve locked open and flow of this chemical could not be stopped? What if the valve locked closed and the chemical ceased to be added? After the consequences have been predicted, a plan is prepared to deal with each dangerous situation, should it arise.

The employer prepares a set of clear written operating procedures for the process that cover safety considerations. These procedures cover normal operation, but also address startup and shutdown, emergency shutdown, and restart after an emergency shutdown. The document lists operating limits and consequences of exceeding them. The document also includes the hazards of the chemicals, precautions (engineering and administrative) to avoid exposure, and measures to employ if exposure does occur. Similarly, employees who maintain, inspect, and test the equipment require written procedures. These procedures are then available to all employees who work at or maintain the facility.

Employers are responsible for a written emergency action plan so that employees are prepared to handle an emergency. The plan includes escape routes. Responsibilities of specific employees for rescue and medical duties are spelled out. The plan must meet the criteria outlined in 29 CRF 1910.38(a)

OSHA places high importance on training workers. The employer provides workers assigned to the process with training about the process and with follow-up refresher training at least every 3 years. Employees involved with maintenance, inspection, and testing or with emergency response must also be trained. Records of the training include the identity of the workers trained, the date of training, and an indication that the worker understood the training4.

Within 48 hr. the employer must investigate any incident that has occurred at the facility. Investigation must be by a competent team, and a report covering designated aspects of the incident is prepared and retained for 5 years.

This chapter does not include all details of the regulation. Instead it ha presented the flavor and intent of the regulation.