Prevention Program Element Development
Management of Change (MOC)
Management of Change (MOC) provides a path forward for facilities contemplating and executing changes (excluding “replacement in kind”) to a process. The changes to a process requiring an MOC include any change in the process chemicals, technology, equipment, procedures, as well as any other modification affecting a covered process. The MOC program is comprised of written procedures that govern how the proposed changes will be managed by the facility. Per 40 CFR Part 68, the MOC documentation includes the following:
- The technical basis for the proposed change;
- Impact of change on safety and health;
- Modifications to operating procedures;
- Necessary time period for the change; and,
- Authorization requirements for the proposed change.
- Updates to the process Safety Information (if applicable).
The MOC process also requires that any employees involved in operating a process, including contract and maintenance personnel whose job tasks may be affected by the change, are made aware of the change and trained accordingly, prior to the restarting the process.
Operating Procedures Development
The development and use of Operating Procedures is an integral element of a successful safety management system, as it provides individuals with the information to perform a job safely and properly, captures operational best practices, and facilitates consistency in the operating environment. The development of Operating Procedures may also include protocols, instructions, checklists, safe work practices, etc. Risk Management Professionals develops Operating Procedures for a wide spectrum of facilities, ranging in complexity from water treatment to oil and gas processing. Our Team works closely with knowledgeable operating staff to develop procedures that accurately reflect the task requirements and meets applicable regulatory requirements.
Risk Management Professionals develops Operating Procedures that are written in a concise, step-by-step, easy-to-read format that is straightforward and unambiguous. Terminology is consistent with operations and Piping and Instrumentation Diagrams (P&IDs); however, jargon is avoided to maintain clarity.
Risk Management Professionals will work with you to develop an efficient deliverable that meets your operation’s specific needs. Our Team will work with you to develop a template to be used throughout all Operating Procedures, which will be delivered in a modifiable format for ease in completing updates. Additionally, Risk Management Professionals has the capabilities to produce Electronic Operating Procedures using either a web-based technology or your company’s intranet to effectively link Operating Procedures.
Operator Interviews & Shadowing
A critical element for developing usable and accurate Operating Procedures is to involve facility operators at an early stage of the project. Risk Management Professionals conducts operator interviews, as well as operator “shadowing” at the facility to document the step-by-step procedures. At the client’s option, an informal video is utilized to document the interview process and ensure a reference is provided while writing the procedures out of the field. Additionally, photographs are utilized as part of the shadowing process, and relevant critical photographs are included in the Operating Procedures to provide clarity and operational references.
Operating Parameters & Limits
A key component to developing Operating Procedures is to document the normal operating parameters for each piece of equipment referenced in the Operating Procedures, including level, temperature, pressure, flow, and other process parameters. For example, if there is a procedural step to “check the level of the Water Tank (TK-1)”, there is also a reference to the normal operating level of the tank. Additionally, a table listing the operating limits outlines the safe upper and lower operating limits for the operating parameters and clearly indicates what is outside the acceptable operating range. The consequences associated with deviating from the acceptable operating limits are also clearly defined, as well as the steps required to correct or avoid deviations.
Safety and Health Considerations
To ensure the Operating Procedures include necessary safety and health precautions, the following are defined within the Operating Procedures:
- Properties and hazards of the chemicals used in the process
- Precautions to prevent exposure (e.g., engineering controls, administrative controls, and personal protective equipment)
- Response in case of physical/airborne exposure
Dispersion Modeling and Offsite Consequence Analysis (OCA)
Risk Management Professionals (RMP) has extensive experience providing accurate and high-quality dispersion modeling services. Whether for design purposes or compliance with state/federal regulations, RMP’s engineers will assist facilities in their dispersion modeling needs.
RMP has provided dispersion modeling for numerous clients in various industries:
- Chemical Processing
- Oil & Gas
- Water Treatment
- Ammonia Refrigeration
- Power & Energy
- Chemical Plating and Etching
RMP utilizes the most recent software to provide accurate modeling for a wide variety of release scenarios. RMP specifically employs:
RMP’s engineers are highly adept at utilizing site specific data to provide accurate modeling. This includes up-to-date weather, temperature, and terrain data and a customized approach to ensure the correct type of release is modeled.
Additionally, RMP’s engineers have experience addressing releases which incorporate mitigation features including, but not limited to, the following common installations:
- Containment Systems
- Scrubber and Ventilation Systems
We will tailor the dispersion modeling to comply with regulatory requirements. Whether evaluating worst-case or alternative release scenarios, we will ensure the facility’s modeling is in compliance and that accurate modeling is implemented. In all cases, we will provide clients and government agencies with a thorough report of the dispersion modeling, outlining the methodology, assumptions and results.
As necessary, RMP has provided support for facilities during public and regulatory meetings to assist in explanation of the dispersion modeling.
Regulatory Program Training
Risk Management Professionals provides regulatory program training to a variety of facilities and various experience levels of audiences. Regulatory training may be provided as an all-inclusive package (preparation of materials, presentation, and recordkeeping) to very minimal (providing the materials for on-site personnel to conduct training sessions). Training may also be provided remotely and/or pre-recorded for future use.
P&ID Update and Development
Piping and Instrumentation Diagrams (P&ID’s) are not only a requirement of the prevention programs but are also valuable tools that enable the safe operation and maintenance of any system. P&ID’s also expedite employee familiarization and training. Risk Management Professionals’ capabilities include tracing systems and creating Visio drawings for various types of systems. Electronic files are provided (PDF and modifiable versions) at the completion of the project. ACAD needs are contracted to appropriate vendors based on the location and type of facility.
Risk Management Professionals’ capabilities include providing third-party incident investigation support. Whether it’s reviewing existing documentation for quality and completeness or conducting and leading a full investigation, RMP has engineers qualified and capable of meeting the needs of our clients.
Emergency Preparedness & Response
The purpose of emergency preparedness training is to educate personnel about potential hazards and the associated effects and to practice responding to emergency situations. Training is essential to the effectiveness of an Emergency Response/Operations Plan and should be completed in the following cases:
- Initially when the plan is developed
- For all new employees
- When new equipment, materials, or processes are introduced
- When procedures have been updated or revised
- When exercises show that employee performance must be improved
- At least annually
In parallel with the development of Emergency Response/Operations Plans, we provide support training and implementing the plans. Risk Management Professionals has direct experience developing emergency preparedness training programs and assisting clients in the development of emergency drill plans and tabletop exercises, in planning response scenarios, facilitating the drills, and evaluating the outcome of the drills.
Risk Management Professionals has developed several training options for agency personnel to develop a customized emergency response training program. The types of training options vary from Familiarization Training Courses (ERP Overview and SEMS/NIMS) to Full-Scale Multi-Agency Exercises with full field deployment and resource mobilization. The agency may select training options depending on the detail, time investment, and level of participation. A rigorous training program includes all of the training options over a substantial period of time, starting with the familiarization training and concluding with the functional or full scale exercise. However, the agency may decide to mix-and-match the various training options to meet specific needs.
To implement an Emergency Response/Operations Plan, the following training options are available to the agency:
- ERP Familiarization and ICS/SEMS/NIMS Training (including FEMA Certification courses)
- Tabletop Exercise
- Functional Exercise
- Full Scale Multi-Agency Exercise
Hazardous Materials Inventory and Business Emergency Plans
In order to protect the safety and health of the community and facility personnel, along with the environment, facilities handling, storing, or utilizing hazardous materials are required to submit Hazardous Material Inventory and Business Emergency Plan (HMI/BEP) Disclosures pursuant to Health and Safety Code 25503.3. The requirement for an HMI/BEP Disclosure depends on the hazardous material inventory stored, handled, or utilized onsite and for California facilities, includes hazardous materials and waste in quantities equal to or greater than 55 gallons, 500 pounds, or 200 cubic feet of gas at standard temperature and pressure.
The HMI’s provide information on the location, amounts, and storage of hazardous materials. While the BEP focuses on facilities’ emergency response procedures, including procedures for personnel response, training of employees, evacuation and hazardous material location maps, safety systems and identification of alarms. This information assists emergency responders in planning for and handling emergency events involving hazardous materials.
As stated in Health and Safety Code 25503.3, the HMI/BEP Disclosures are required to be recertified annually. If a change at the facility has occurred in quantity of previously disclosed hazardous materials, added hazardous materials previously not disclosed, or
a change in business ownership, address, or name, then the HMI/BEP may need updated on a more frequent basis.
Risk Management Professionals has worked with numerous facilities in completing their HMI/BEP Disclosures.
Our understanding of the regulatory requirements in addition to local requirements allows us to provide a quality HMI/BEP Disclosure to the local Administering Agency or fire department. The key to ensuring a complete HMI/BEP Disclosure is to ensure all hazardous materials onsite are inventoried and verified. We work with facility personnel to identify and locate all hazardous materials onsite. In addition, emergency response procedures are evaluated for adequacy and documented appropriately.
An essential part of the HMI/BEP disclosure is a map indicating location of hazardous materials and evacuation routes. RMP provides drafting services, which allows us to develop and include a concise map, consistent with the requirements of the HMI/BEP Disclosures. In addition, this provides added value to the local emergency responders in your area.
Our previous work with Administering Agencies and completion of HMI/BEP’s allows us to provide a quality product to ensure your facility’s compliance.