ICI Acrylics - Executive Summary |
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OVERALL RESPONSIBILITY Our Site Manager has the overall responsibility for ensuring that our facility operates in a safe and reliable manner. This responsibility includes overseeing the implementation of the elements of our risk management program. To ensure that our risk management program is appropriately developed and implemented, our Site Manager has assigned the role of PSM/RMP Coordinator to a staff member with the necessary background, training, and experience. The PSM/RMP Coordinator, acting with the authority delegated directly from the Site Manager, has the responsibility for the development, implementation, and integration of the EPA RMP elements and the elements of OSHA's PSM program (where applicable) as required under Section 68.15 of the RMP rule. The PSM/RMP Coordinator oversees the implementation of the PSM, and the risk management program. This is done by giving responsibilities to select employees to develop and manage specific elements of our risk managemen t and process safety management programs. The members of this group are assigned by the Site Manager based on recommendations from the PSM/RMP Coordinator and the Environmental Engineer. Currently, the members of the PSM/RMP group include the following: RMP members * PSM/RMP Coordinator - Jesse L. Thompson * Environmental Manager - Hayden Lipp Process Safety Management "Element Champions." * Employee Participation Plan - Phil Nolan, North American SHE Director * Process Safety Information - Ken Case, Senior Engineer, and Doug Bobbitt, Engineering Associate * Process Hazards Analysis - Roger Davey, Site Manager * Operating Procedures and Safe Practices - Kevin Hewlett, Production Engineer * Training and Performance - Jesse Thompson, PSM/Training Coordinator * Contractor Safety - Dentie Doyle, Contractor Specialist * Pre-Startup Safety Review - Jesse Thompson, PSM/Training Coordinator * Mechanical Integrity/Quality Assurance - Mike Hopson, Overhall Planning Coor dinator * Hot Work - Mike Jackson, Maintenance Manager * Management of Change - Kevin Hewlett, Production Engineer * Incident Investigation and Reporting - Danny Schaftlein, Production Manager * Emergency Planning and Response - Floyd Billings, SHE Manager * Auditing - Jesse Thompson PSM/Training Coordinator * Trade Secrets - Ken Case, Senior Engineer The following sections identify the specific responsibilities for each aspect of our risk management and process safety management programs. HAZARD ASSESSMENTS The PSM/RMP Coordinator has the responsibility for (1) ensuring that offsite consequence analysis for each regulated process are consistently performed and documented in accordance with Sections 68.20 through 68.39 and (2) selecting the scenarios that will be reported in the facility RMPlan as required under Section 68.165. The PSM/RMP Coordinator also is responsible for ensuring that the accident history for each covered process is appropriately documented and maint ained in accordance with Section 68.42 and 68.168 of the RMP rule. PREVENTION PROGRAMS The PSM/RMP Coordinator has the responsibility for ensuring that the facility has an integrated, effective, and compliant prevention program that meets EPA RMP (Sections 68.65 through 68.87 of the RMP rule) and OSHA PSM requirements. Although the PSM/RMP Manager has some specific individual responsibilities, many of the responsibilities for specific program elements are assigned to other members of the PSM element champion list (as listed in the following sections). PROCESS SAFETY INFORMATION The responsibility for process safety information (PSI) (Section 68.65 of the RMP rule) is shared between two engineers. Doug Bobbitt, Engineer Associate, has responsibility for process safety information for the monomer and ACH process. Ken Case, Senior Engineer, has responsibility for SAR process. Both of these engineers have the responsibility of ensuring that all of this information is readily acces sible for use. PROCESS HAZARD ANALYSIS In accordance with Section 68.67 of the RMP rule, the Site Manager has ultimate responsibility for ensuring that process hazard analyses (PHAs) are scheduled, conducted, and documented by trained personnel for all regulated processes. The Plant Managers (MMA & Sheeting) identifies the candidate PHA team leaders from within the facility and ensures that they receive appropriate training before leading PHAs. Outside contractors may also be used to lead PHAs when appropriate. The Hazard Study Leader is responsible for (1) ensuring that the information and personnel necessary to conduct PHAs are available according to the PHA implementation schedule and (2) resolving recommendations that are assigned to their respective areas, (CARS). OPERATING PROCEDURES In accordance with Section 68.69 of the RMP rule, the site Production Engineer has the responsibility for ensuring that complete and accurate operating procedures are in place for all regulate d processes. The Production Engineer works closely with the SHE Manager, the PSM Coordinator, and the Maintenance Manager to develop and maintain the facility's safe work practices for both operations and maintenance. TRAINING In accordance with Section 68.71 of the RMP rule, the PSM/Training Coordinator has the responsibility for (1) ensuring that operations employees receive and understand training applicable to their specific jobs and the associated processes and (2) ensuring that all facility employees receive and understand training in safe work practices applicable to their jobs and(3) documenting the training. (The Maintenance Manager addresses training for maintenance workers under the mechanical integrity program.) MECHANICAL INTEGRITY In accordance with Section 68.73 of the RMP rule, the Overhaul Planning Coordinator has the responsibility for the overall mechanical integrity program, with specific emphasis on written procedures, maintenance specific training, the equip ment and instrumentation inspection/test program and documentation, and equipment deficiency resolution. Project Engineering, Maintenance Manager, and the Purchasing work with the Overhaul Planning Coordinator to define and maintain appropriate quality assurance procedures for all types of equipment acquisitions/installations/repairs. MANAGEMENT OF CHANGE In accordance with Section 68.75 of the RMP rule, the Production Engineer has the responsibility for the overall management of change (MOC) program; however, the Production Manager, the Maintenance Manager, the Project Engineering, and the Purchasing each have responsibility for ensuring that the overall MOC program is effectively implemented in their areas. PRE-STARTUP REVIEW In accordance with Section 68.77 of the RMP rule, the PSM/RMP Coordinator has the responsibility for the overall pre-startup review program, which is closely related to the MOC, program. However, the Site Manager has the primary responsibility for ensurin g that this program is effectively implemented before affected operations begin. COMPLIANCE AUDITS In accordance with Section 68.79 of the RMP rule, the PSM/RMP Coordinator has the responsibility for ensuring that compliance audits regularly occur (and are documented) to verify that the prevention program is working and meets EPA/OSHA requirements. Each Element Champion of PSM has responsibility for resolving any identified deficiency in their area. INCIDENT INVESTIGATION In accordance with Section 68.81 of the RMP rule, the Production Manager has the responsibility for designing and managing the incident investigation program, including tracking resolution of investigation findings and recommendations. Part of the this responsibility is ensuring that only trained personnel lead our investigations. The Production Manager and Maintenance Manager each have responsibility for ensuring that all incidents in their areas are reported and investigated, and the investigations findings are resolved, documented, and communicated to affected personnel. EMPLOYEE PARTICIPATION In accordance with Section 68.83 of the RMP rule, the North American Acrylic Safety Manager, working with the site SHE Manager, and PSM/RMP Coordinator, has the responsibility of involving employees in the planning and implementation of the facility's prevention program elements. HOT WORK PERMITS In accordance with Section 68.85 of the RMP rule, the Maintenance Manager, working closely with the Production Manager and the SHE Manager, has the responsibility of developing and maintaining the facility's hot work permit program. CONTRACTORS In accordance with Section 68.87 of the RMP rule, the Contractor Specialist has the overall responsibility for the contractor program; however, the Maintenance Manager, and the Production Manager, are responsible for ensuring that the requirements of the program are implemented in their areas of responsibility. EMERGENCY RESPONSE PROGRAM In accordance with Sections 68.90 and 68.95 of the RMP rule, the SHE Manager is responsible for (1) designing, implementing, and maintaining the facility's emergency response plan, (2) ensuring that all associated training is conducted and documented as necessary, (3) coordinating the site emergency response plan with the community emergency response plan, and (4) responding to local emergency planners/responders when questions arise. RMPLAN PREPARATION AND SUBMISSION The PSM/RMP Coordinator is responsible for preparing and submitting the RMPlan for the facility (after review and approval by the Site Manager) as required under Sections 68.150 through 68.185 of the RMP rule. RMPLAN COMMUNICATION The PSM/RMP Coordinator and the Environmental Manager has the responsibility of providing RMPlan information (other than the required EPA submission) to employees and the public as required under Section 68.210 of the RMP rule. |