MEDSURG INDUSTRIES INC - Executive Summary |
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 |