MEDSURG INDUSTRIES INC - Executive Summary

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Introduction 
 
This Risk Management Plan was prepared to comply with Federal Register 40CFR Part68. 
 
1. POLICIES 
 
    - Accidental Release Prevention 
 
     Any accidental release of Ethylene Oxide (ETO) would be detected by strategically  
located ETO monitors. 
     ETO drums are leak tested at the factory after filling, and are tested for leaks upon  
receiving at our facility. 
     The ETO storage area is electronically 24 hour monitored for ETO detection. 
     The ETO storage tank valves are only in the open position during ETO injection into the process.   
They are in the closed position at other times.  
     Three seperate computer controlled  shut-off valves and three  manual shut-off valves are located  
between the ETO storage tanks and the process.  
     ETO storage area is a limited access area.   
     Receiving dock facility is located at the storage room for minimum movement of ETO tanks. 
     SCBA on site for emergency shut down use. 
 
     -Emergency Response 
 
 
An Emergency Response Plan has been prepared and submitted to the Loudoun County LEPC   
and the Sterling Fire Department.  
     Semi-annual emergency response drills are conducted. 
 
2.      STATIONARY SOURCE AND REGULATED SUBSTANCE 
 
     The primary activity is the commercial sterilization of medical products for use in 
surgery in hospitals.    
 
     -Regulated Substance 
       * Ethylene Oxide 
 
3.       RELEASE SCENARIO 
 
     -Worst Case 
      * Toxic Gas 
           ETO tank valve rupture with release of 100% of capacity (400 lbs) in 10 minutes. 
 
     -Alternative Release 
          * Toxic Gas 
           ETO tank valve rupture with release of 100% of capacity (400 lbs) in 22 minutes.   
ETO Manufacturer calculations are 22 minutes for a release of full open valve.  Automatic Electric Eyes and a manual release Deluge system is in place to slow airborne releases to the atmosphere. 
 
4.       PREVENTION 
 
     - Regulated substance in the Sterling Virginia plant is covered b 
y the OSHA Process Safety  
Management (PSM) standard. 
 
5.      FIVE-YEAR ACCIDENT HISTORY 
 
     -There has been no accidental release of the regulated substance during the last five years. 
 
6.       EMERGENCY RESPONSE PROGRAM 
 
     Emergency response activities are coordinated with the Sterling Fire Department. 
Emergency response team information is available from ETO supplier and from the Emergency  
response team hotline in Washington DC and Fairfax County Virginia. 
 
7.       PLANNED CHANGES TO IMPROVE SAFETY 
 
     Safety Preparedness is a part of Medsurg's activities.  Exposure risks to employees and  
the public have been minimized through technologcal improvements and ongoing training.  
At this time, no further improvements have been identified. Medsurg is ISO 9001 Certified and  
is in the process of upgrading it's safety and training procedures 
 
END OF DOCUMENT
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