# Presentation: 051173

## RMP PLAN IN HAND TRAINING:  CHLORINE Prevention Program Module

**U.S. EPA**** **
**Chemical Emergency Preparedness and Prevention Office**

## Introduction

- Program 3 prevention program
- Identical to OSHA PSM Standard
- Processes at privately owned facilities
- Processes at publicly owned facilities in states with delegated OSHA programs
- Program 2 prevention program
- Streamlined requirements
- Processes at publicly owned facilities in states without delegated OSHA programs

## Program 3 Elements

- Eleven elements in the accident prevention program
- For more information, refer to:
- EPA’s *General Guidance on Risk Management Programs*
- American Water Works Association Research Foundation’s *Compliance Guidance and Model Risk Management Program for Water Treatment Plants*

## What Do I Need to Report?

- For each Program 3 process, you must provide the following:
- NAICS Code
- Chemical name
- Date of most recent review of safety information

## What Do I Need to Report? (continued)

- Process Hazards Analysis (PHA)
- Date of last PHA
- Technique used
- Date of completion for changes
- List of major hazards
- Process controls
- Mitigation systems
- Monitoring/detection systems
- Changes since last PHA

## What Do I Need to Report? (continued)

- Date of most recent review of operating procedures
- Training
- Date of most recent review of training programs
- Type of training provided
- Type of competency testing used

## What Do I Need to Report? (continued) 

- Maintenance
- Date of most recent review of maintenance procedures
- Date of most recent equipment inspection or test
- Equipment most recently inspected or tested
- Management of Change (MOC)
- Date of most recent change requiring MOC
- Date of most recent review of MOC procedures
- Date of most recent pre-startup review

## What Do I Need to Report? (continued) 

- Compliance Audits
- Date of most recent compliance audit
- Date of completion for changes
- Incident Investigation
- Date of most recent incident investigation
- Date of completion for changes

## What Do I Need to Report? (continued) 

- Date of most recent review of:
- Employee participation plans
- Hot work permit procedures
- Contractor safety procedures
- Date of most recent evaluation of contractor safety performance

## Program 2 Elements

- Seven elements in the accident prevention program:
- Safety Information
- Hazard Review
- Operating Procedures
- Training
- Maintenance Procedures
- Compliance Audits
- Incident Investigation

## Safety Information

- You must compile and maintain up-to-date safety information about propane and related equipment, including:
- Material Safety Data Sheets (MSDSs)
- Maximum intended inventory
- Safe upper and lower temperatures, pressures, flows, and compositions
- Equipment specifications

## Hazard Review

- You must review the hazards associated with the chlorine process:
- Siting
- Vessels, piping, and other equipment
- Human factors
- General hazards
- You may want to consider other problems such as earthquakes, hurricanes, and floods

## Hazard Review (continued)

- You must perform an initial hazard review for each covered process
- Hazard review techniques include:
- Checklist
- What-If/Checklist
- Hazard and Operability (HAZOP) Review

## Operating Procedures

- You must prepare written operating procedures that help your employees safely conduct activities.  Activities you should include are:
- Initial startup
- Normal operations
- Temporary operations
- Emergency shutdown and operation

## Operating Procedures (continued)

- Normal shutdown
- Startup following a normal or emergency shutdown
- Equipment inspections
- Operating procedures must be updated before a major change
- Chlorine Institute’s *Water and Wastewater Operators Chlorine Handbook* (Pamphlet 155)

## Training

- Each of your employees must be trained or test competent in all operating procedures that are part of the job
- The rule does not require a specific kind of amount of training
- Training does not need to be documented, but refresher training must be provided at least every three years

## Maintenance Procedures

- You must develop and implement written maintenance procedures and train your workers to follow them
- You must establish a schedule for inspection and testing of equipment

## Compliance Audits

- A compliance audit is required at least every three years
- The audit team must check each element in your prevention program
- The audit must be performed by someone familiar with the process
- You must develop a report of the findings of the audit, and document any responses to them

## Incident Investigation

- You must promptly initiate an investigation of each incident that resulted in or could have resulted in a catastrophic release
- Summarize the investigation
- Address findings and conclusions
- Keep the report and review with staff

## What Do I Need to Report?

- For each Program 2 process, you must provide the following:
- NAICS Code
- Chemical name
- Safety information
- Date of most recent review of safety information
- Codes and standards used to demonstrate compliance

## What Do I Need to Report? (continued)

- Hazard review
- Date of last hazard review
- Date of completion for changes
- List of major hazards
- Process controls
- Mitigation systems
- Monitoring/detection systems
- Changes since last PHA

## What Do I Need to Report? (continued)

- Date of most recent review of operating procedures
- Training
- Date of most recent review of training programs
- Type of training provided
- Type of competency testing used

## What Do I Need to Report? (continued) 

- Maintenance
- Date of most recent review of maintenance procedures
- Date of most recent inspection or test
- Equipment most recently inspected or tested
- Compliance Audits
- Date of most recent compliance audit
- Date of completion for changes

## What Do I Need to Report? (continued) 

- Incident Investigation
- Date of most recent incident investigation
- Date of completion for changes
- Date of most recent change that triggered a review or revision of safety information, hazard review, operating, or maintenance procedures or training