MG Industries - Jessup, MD - Executive Summary
MESSER - MG INDUSTRIES |
Jessup, MD Cylinder Gas Production Plant
RMP Executive Summary
Introduction - Messer America's Loss Prevention Program
Loss prevention management refers to the prevention of potential losses to Messer through an effectively designed, administered and implemented Environmental, Health, Safety and Regulatory Compliance Program.
Incorporating an effective loss prevention program requires developing and integrating programs that will assist in reducing losses from accidents. Messer GmbH has developed Safety, Health and Environmental guidelines that have been incorporated in a comprehensive program defined as Loss Prevention Policies. These policies are the minimal standards for Messer America's operations, including the Jessup, MD cylinder gas production facility.
The objective of the program is to achieve an acceptable level of performance in the prevention of the losses to the organization which include but are not limited to accidents, injuries, illnesses,
product liabilities and regulatory non-conformities. To be effective, this management system must be totally integrated in which all levels of employees are involved and held accountable.
The ultimate authority for instituting an effective Loss Prevention Program rests with the senior management of each operating group. Through their words and more importantly through their actions, senior management sets the tone for loss prevention throughout Messer Americas. While senior management set the tone, middle management must create the uniform support and nurture the desired culture to influence the Loss Prevention Program. This strong management commitment culminates with the day to day responsibilities of implementing and managing the Loss Prevention Program by 'line management' (supervisors and lead personnel). Local management is accountable for the effective management of this program through their organization's performance as related to loss prevention and regulatory compliance.
In healthy loss prevention culture, each member of the company participates fully in the program. Loss prevention is no longer an activity that someone else is in charge of. Each manager, supervisor, driver and line worker is personally responsible for insuring 'safe working conditions, safe product for all customers and a safe environment for the citizens of the communities in which Messer operates'.
Simplified Process Description
MG Industries' cylinder gas plant in Jessup, MD fills industrial gases and acetylene gas in compressed gas cylinders. As part of the operation, large quantities of chemicals are stored in bulk storage tanks and acetylene is generated for transfilling into cylinders. Of all the chemicals inventoried in the Jessup plant, only the following chemicals come under Risk Management Plan (RMP) regulations: propane and acetylene.
All the processes in this facility come under Program 3 of the RMP regulations
Worst Case Scenarios
Flammables: Worst case scenarios for both propane and acetylene were analyzed and it was found that propane had a larger consequence distance than acetylene and hence the worst case scenario for propane was reported.
Propane is stored in two pressurized storage tanks adjacent to each other. Because of their proximity to each other, they will be considered to be part of a single process. The default meteorological conditions were assumed and the consequence distances were obtained from the tables given in Off-site Consequence Analysis Guidelines (OCAG) for an unmitigated release of the entire contents of both the pressurized storage tanks in 10 minutes. The consequence distance was estimated as 0.33 miles, which impacts the neighboring commercial and industrial facilities. The Landview III software package was utilized to determine the general environmental and
community impact. There was no impact on any environmental receptors and there was minimal impact on public receptors.
Alternate Case Scenarios
Calculations for the estimation of the consequence distance were done for all the alternate case scenarios. Default meteorological conditions were assumed for all the cases. A task force consisting of employees with different job responsibilities and technical knowledge within the plant was put together. This task force identified, analyzed and evaluated different alternate case scenarios for each of the regulated flammable materials and then chose the 'most likely scenario' for each of the chemicals that would result in a release.
Flammables: The analysis of the alternate case scenarios for both acetylene and propane resulted in the same consequence distance and hence propane's results were reported. The storage of propane in two adjacent pressurized storage tanks is considered to be a single process due to the proximity of the two tanks.
Seven different alternate case scenarios were identified, analyzed and discussed by the task force. The 'transfer hose failure' was chosen to be the most likely alternate scenario for this process. For flammables, the tables from the OCAG were used to estimate the consequence distance. For the alternate case scenario chosen, the consequence distance was estimated as 0.1 miles, which impacts the neighboring commercial and industrial facilities. The Landview III software package was utilized to determine the general environmental and community impact. There was no impact on any environmental receptors and there was minimal impact on public receptors.
General Accidental Release Prevention Program - Loss Prevention Written Policy
The objective of the Messer Loss Prevention Program is to achieve an acceptable level of performance in the prevention of the losses to the organization. The paramount importance of our Loss Prevention Program is assuring safe working conditions of ou
r employees, safe product for customers and a safe environment for the citizens of the communities in which we operate. The program is integrated with a series of Loss Prevention Policies that are the cornerstone of Messer Loss Prevention efforts. These policies form our Loss Prevention Policies manuals. These manuals are maintained by local management and are available for review by any employee upon request during normal business hours. In addition, compliance with local and federal regulations such as DOT, FDA and EPA are required.
Authority and Responsibility for Program Implementation
The Plant Manager has the overall site authority for implementation of the Loss Prevention Program. He or she is responsible for the day to day management of the Loss Prevention Policies as they directly relate to all operational activities.
The Site Safety Advisor is responsible for conducting periodic inspections, serving as the facility spokesperson on loss prevention issues and participation
on the safety committee.
System for Identifying, Evaluating and Preventing Safety and Health Hazards
The system for identifying, evaluating and preventing occupational safety and health hazards has been defined throughout the Loss Prevention Manual and this includes, but not limited to:
- Review of applicable standards to the industry
- Review and availability of Material Safety Data Sheets (MSDSs)
- Ensure the proper labeling of potentially hazardous materials
- Safety work permitting systems
- Investigation of accidents and incidents
- Periodic and scheduled inspection of the general work areas.
Employee Communications and Training
Employee communications and training are also defined throughout the Loss Prevention Manual and these include but not limited to:
- Monthly poster program service by the National Safety Council on a variety of safety and health topics
- Site specific Safety Bulletin Board for posting all environmental, health and safety related information such as
Loss Prevention Policy and safety posters
- Site specific safety committee made up of representative functional positions within the operation
- Monthly safety meetings held on various environmental, health and safety topics
- Safety orientation of all new hires and personnel transferred into new positions
- Regulatory compliance training as it may apply to specific operations and/or exposures such as hearing conservation, HAZCOM (HAZard COMmunications), respiratory protection and fire extinguishers.
Process Safety Features
This facility is manned 14 hours/weekday with routine in-house inspections by plant employees and protected by an alarm system at all other times. The plant has an evacuation plan based on audible signals. The propane storage tanks are protected with excess flow shut off valves and the acetylene plant has a deluge water system. All of the RMP processes come under Process Safety Management (PSM) rules and have been reviewed and audited in the past year.
Five Year Accident History
There were no accidental releases of any of the RMP regulated chemicals from the MG Industries cylinder gas plant in Jessup,MD during the past five years.
Emergency Response Program
The local fire department performs periodic visits to the facility and is a part of the facility emergency action plan. The fire department plays a critical role in this plan. MG Industries relies on the fire department to assist in the control and mitigation of an incident in this site, whereas MG Industries provides the technical expertise with respect to the equipment and the product. A comprehensive Loss Control Program exists at the facility that is managed both locally and at the MG Industries corporate level.
Planned Changes to Improved Safety
MG Industries is committed to continually improve our safety performance for all the operating units of the business. This is reflected in our 'Loss Prevention Policy' which states ' ..... MG is committed to steadily im
proving it's performance in this area and ulitmately to gaining a position among the very safest companies in the various communities in which we operate'.