Eagle Chemicals, Inc. - Executive Summary |
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On July 15, 1999, CSA North America, Inc. (CSA) conducted a compliance safety audit of the Eagle Chemicals, Inc. 2550 Bobmeyer Road, Hamilton, Ohio 45015 facility pursuant to the Clean Air Act Amendments of 1990, Section 112(r). Prior to that, on June 21, 1999 CSA entered original data consistent with "RMP Comp: and RMP Submit". As a result, several data gaps emerged which have been filled since July 15, 1999. The current August 1999 amendents to the June 21, 1999 filing are reflected herein and by this Executive Summary. Eagle Chemicals, Inc. packages and distributes chemicals. The audit provision is contained in and among other requirements of the Risk Management Program (RMP) specified in Section 112(r). This requires a comprehensive management program involving a holistic approach that integrates technologies, procedures, and management practices, which address: Employee Participation, Process Safety Information, Process Hazard Analysis, Operating Procedures, Training, Contractors, Pre-Startup Safety Reviews, Mechanical Integrity, Hot Work Permits, Management of Change, Incident Investigations, Emergency Planning and Response, Compliance Audits, Trade Secrets. The current compliance audit is intended to provide the basis for Eagle Chemicals, Inc. to certify as of the June 21, 1999 filing that it is meeting Program 3 requirements of the RMP. The document herein is Eagle Chemicals, Inc. Plan. Eagle Chemicals' facility is subject to Program 3 of RMP by virtue of the presince of two toxic chemicals in the workplace and SIC 2819. Both hydrogen chloride and hydrogen flouride exceed the RMP threshold levels. There are no flammables at threshold levels. The effectiveness of this program depends entirely on the quality of the procedures and training that accompanies them. Eagle Chemicals' facility has developed and implemented several of the employee participation and operating procedures requirements, including Emergency Planning and Toxic Chemical Release Inventory. Ea gle Chemicals used the Checklist Analysis for assessing hazards, hazard cause, cause level, and hazard effect category pursuant to 7.4.b.2 of its RMP Program 3, Prevention Program. Required modifications should be tracked through the Management of Change Section 3, Paragraph 10 of the Plan. Other than the PHA, the Management of Change section as well as several of the elements necessary to satisfy the Plan should be completed on a scheduled and regular basis established by Eagle Chemicals. It is recommended that a large, loose-leaf binder with separators having tabs corresponding to Plan sections be assembled and integrated with the Emergency Response Plan and Toxic Chemical Release Inventory file. Componants which are complete or partially complete should be inserted. It then becomes a simple matter to compare completed portions with what remains to be added. Sections of this report will help to identify what still needs to be added. Section 2 summarizes provisions of the Plan. Sectio n 3 contains audit findings; Section 4 provides recommendations for complying with the Standard; and Section 5 provides guidlines for preparing documentation and conducting subsequent compliance audits. Tab separators should correspond to the headings presented in Section 5 RMP Audit Guidelines. If this order is followed, compliance tracking will be more easily facilitated. |