Regional Sterilization - BMD - Executive Summary

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This Regional Sterilization facility utilizes ethylene oxide for sterilizing medical devices manufactured by multiple divisions within the C.R. Bard Corporation.    We purchase the ethylene oxide from Arc Chemical (Balchem Corporation) in DOT-5P drums containing 400 pounds per drum.    Each drum is pressurized with nitrogen to maintain the ethylene oxide in a liquid state.    We have implemented specific operating procedures to define the receipt, storage, usage & return of each DOT-5P drum.    These drums are located in 2 locations within the facility:   (1) Drum Storage Area:  contains potentially 25 drums  (2)   Drum Manifold Room:  contains a total of 8 drums. 
 
It is our policy to adhere to all applicable federal, state and local laws regarding our use of ethylene oxide.   If an emergency were to occur, it is our policy to first notify the City of Covington Fire Department and request that they respond to the emergency.    Any release that occurs above the reportable quantity of 10 
pounds is communicated to the National Response Center and the Georgia Environmental Protection Division. 
 
Our worst case scenario is a failure of the DOT-5P drum, resulting in a complete release of 400 pounds of liquid ethylene oxide.    According to the RMP*Comp, the distance to the endpoint is 0.4 miles.   There are no residential areas, no schools, no hospitals or environmental receptors within this 0.4 mile region.   There is a Recreation Area maintained by the Newton County Recreation Department (i.e. baseball field).    The more likely, or alternate scenario, results in a 2/3 release of the DOT-5P drum (i.e. 280 pounds) and a toxic endpoint of 0.1 miles.     The recreation area is greater than the 0.1 mile zone. 
 
Our facility successfully operates under OSHA's Process Safety Management Program, with no current plans to change our safety processes or procedures.
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