Injury and Illness Prevention Programs (IIPP)
The California Occupational Safety and Health Administration (Cal/OSHA) requires every employer in California to establish, implement and maintain an effective Injury and Illness Prevention Program (IIPP). For facilities with more than ten (10) employees, the IIPP must be written and put into practice. Each program must meet the requirements of California Code of Regulations, Title 8, Section 3203 and each IIPP varies greatly depending upon the facility’s operations.
Risk Management Professionals works closely with facilities to develop procedures that fit the facility and offer the easiest implementation. In addition to developing written IIPPs, Risk Management Professionals can also assist facilities in implementing monthly Safety Meetings and/or Safety Committees.
Spill Prevention, Control and Countermeasure (SPCC) Plans
The EPA regulations on oil pollution prevention as listed in Code of Federal Regulations, Title 40, Part 112 require that any facility with oil storage capacity equal to or exceeding 1,320 gallons in all above-ground storage containers (aggregate total), where the capacity of each storage container is 55 gallons or greater, and could reasonably be expected to discharge oil in harmful quantities into “navigable waters of the United States or adjoining shorelines,” must prepare and implement a Spill Prevention, Control, and Countermeasure (SPCC) Plan.
Storm drains fall under the definition of “navigable water” as most storm drains now discharge directly into a natural body of water without being treated at a municipal treatment facility. Risk Management Professionals has the qualifications and experience to assist facilities in developing and implementing SPCC plans in accordance with the above-mentioned regulations. Depending on the SPCC Plan, it may require PE Certification to ensure accuracy of information and adequacy of established containment methods.
American Petroleum Institute (API) Standards
Third Edition API RP 752:2009 & API RP 753:2007
API Recommended Practice 752 serves to assist facilities in appropriately evaluating the siting of structures within the facility confines. Evaluation of the facility siting requires an identification of hazards, modeling of the hazards, and the development of recommendations to reduce risk to personnel and facility structures.
The third edition of API RP 752:2009 does not cover portable buildings. Portable buildings are covered by API RP 753:2007. It is recognized, however, that portable buildings specifically designed for significant blast load represent a potential area of overlap between API RP 753 and API RP 752.
Risk Management Professionals can assist facilities in implementing API RP 752/753 and coordinating with the facilities to implement measures which reduce risks identified by the evaluation.
RMP’s utlizes the following approach to comply with API 752/753:
- Hazard Identification – On-site walk through to identify hazards. Coordination with facility personnel to identify specific areas of concern based on operating experience
- Hazard Modeling – Explosion, fire and toxic modeling to identify risks associated with specific areas of concern
- Report and Recommendations – Developing a report of findings with specific recommendations to ensure the facility complies with API RP 752/753
API 754: Process Safety Performance Indicators Audit
Goal-based (Performance-based) regulations specify the desired outcome required, but leave the method of achieving this to the duty holder. Goals or targets to be met in such regulations are often qualified by “reasonable practicability” and thus demand, from both the regulator and duty holders, some matching of response-to-risk and cost-to-benefit. The best way to properly evaluate your performance based safety program is through a Process Safety Performance Indicators Audit.
The purpose of the API RP 754 Audit is to identify leading and lagging Process Safety Indicators useful for driving performance improvement. Process Safety Indicators drive process safety performance and learning. Risk Management Professionals assists out clients with flushing out these leading and lagging indicators by performing the API RP 754 Audit.