Injury and Illness Prevention Programs (IIPP)
Cal/OSHA, as of July 1, 1991, 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. The Program shall meet the requirements of 8 CCR Section 3203. IIPP’s vary 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. The common elements of an IIPP include, but are not limited to:
- Hazard Communication
- Hazardous Waste Operations
- Electrical Safety
- Hearing Conservation
- First Aid and CPR
- Emergency Procedures (Fire Extinguishers, etc.)
- Fall Protection
- Confined Space Entry
- Hot Work
- Forklift and Other Industrial Vehicle Operations
- Respiratory Protection Awareness
- Personal Protective Equipment
- Machine Tool Operations
- Facility Site Specific Training
- Supervisor Safety Training
- Heat Stress
In addition to developing a written IIPP, 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 Title 40, Code of Federal Regulations, Part 112 (40 CFR 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. Harmful quantities are defined as “a discharge that violates applicable water quality standards or causes a sheen upon, or discoloration of, the surface of water and may also have the potential to seep, leach, or flow into the navigable waters.”
Storm sewers fall under the definition of “navigable water” as most storm sewers 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. Risk Management Professionals has the capability to provide PE Certification of SPCC Plans where required.
American Petroleum Institute (API) Standards (752,753, & 754)
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.
This third edition of API 752:2009 supersedes all previous editions, including the technical data provided in those documents. Significant research and development of technology pertinent to building siting evaluations has been performed since the publication of the previous editions of API RP 752. Examples of updated technology include prediction of blast damage to buildings, determination of occupant vulnerabilities, and estimates of event frequencies. Prior versions of API RP 752 and the technical data included in them should not be used for building siting evaluations.
The second edition of API RP 752:2003 covered all building types both permanent and portable. This third edition of API RP 752:2009 does not cover portable buildings. Portable buildings are now 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 has assisted 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.
As demonstrated by historical investigations into catastrophic events in high risk industrial settings; process safety incidents are rarely caused by a single failure, but rather by multiple events or failures that coincide as depicted in the figure below.
- Hazards are contained by multiple protective barriers
- Barriers may have weaknesses or “holes”
- When holes align, the hazard passes through the barriers, resulting in the potential incident
- Barriers may be physically engineered containment or behavioral controls dependent upon people
- Holes can be latent, incipient or actively opened by people
Often times the Process Safety Indicators that led up to these catastrophic events were not properly tracked and measured. Management typically measures the the adequacy and effectiveness of their environmental, health and safety programs by the number of slips, trips and falls that have occurred. Most often, Process Safety Indicators are minor near-misses that do not result in an injury, loss of containment or operational upset. Over the years, the normalizing of these risks result in process safety indicators being confused with normal operation.
Indicators that are predictive are considered leading indicators and may be used to identify a weakness that can be corrected before a higher consequence event occurs. The end result is to prevent an event that could result in a Loss of Primary Containment (LOPC). Risk Management Professionals assists out clients with flushing out these leading and lagging indicators by performing the API RP 754 Audit.