Avon Products - Newark Branch - Executive Summary |
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AVON PRODUCTS, INC. - NEWARK, DELAWARE BRANCH RISK MANAGEMENT PLAN (RMP) EXECUTIVE SUMMARY Avon Products, Inc. conducts its business operations in such a manner as to protect the safety and health of our employees, our customers, the public and the environment. This responsibility is of the highest priority to Avon and is embodied in Avon's written Environmental, Health and Safety Policy. The Avon (Newark, Delaware) Branch is a regional distribution facility where product orders from Avon Sales Representatives are processed and shipped. The facility includes a warehouse where among other things, different types of aerosol products are stored - ranging from hair care products to shaving creams and air fresheners. These aerosol products include propellants such as propane, butane, isobutane and methyl ether that are considered flammable materials according to requirements of the Chemical Accident Prevention Provisions (40 CFR Part 68, and is also known as the EPA's RMP rule). When t he flammable materials in each aerosol container are added together, the amount stored on-site can be in excess of the 10,000 pound RMP threshold quantity. There are no listed toxic substances handled at this site in excess of the threshold quantity. The worst-case accidental release scenario, as mandated by EPA requirements, would be the rupture and complete release of all flammable materials from the single largest aerosol container stored at this facility. If all of the aerosol contents were released and formed an explosive vapor cloud, and if a source of ignition caused an explosion, the approximately 0.75 pounds of flammable materials would potentially affect a radius of 0.005 miles, or 26 feet. This distance of impact is referred to as an endpoint, and for this type of release is defined as an overpressure of 1 pound per square inch (psi) caused by the explosion. (One psi is the amount of pressure generally required to break a typical glass window and is considered the thresho ld for potential serious injuries to people as a result of property damage caused by an explosion). No public receptors are located within the 0.005-mile endpoint distance. The endpoint calculation is based on the EPA guidance document number EPA 550-B-00-009, titled "Risk Management Program Guidance For Warehouses", as revised May 26, 2000. Because endpoint distances less than 0.01 miles cannot be entered in the RMP*Submit software, the electronic submittal of this RMP indicates an endpoint of 0.01 miles. These results are very conservative. EPA's own guidance indicates that the EPA considers not only the release of the total quantity of a flammable substance in a vessel or container into a vapor cloud to be highly unlikely, but also that the explosion of such a vapor cloud to be an unlikely event. Further, the guidance states that the endpoint of 1 pound per square inch is intended to be conservative and protective, and does not define a level at which severe injuries would be commonly expected. There have been no accidental releases of propellant or flammable materials at the Avon (Newark, Delaware) Branch in the last five years that have resulted in death, injury, property damage, evacuation, sheltering in place or environmental damage on site or any damages off site. The Avon Newark Branch has never, in its history, had an aerosol release that caused any off site injury. Avon's ongoing goal is to prevent accidental releases of all materials, including regulated materials through the proper design, operation and maintenance of our facilities and the proper training of our employees. Avon's preventive measures include procedures and employee training programs specific to handling aerosols. In addition, the majority of aerosol products are stored in specially designated areas of our warehouse with high-density sprinkler fire suppression systems. If, despite our efforts, such a release should occur, our trained emergency response personnel are on hand t o manage the situation until the local Fire Department and other emergency responders arrive. Avon maintains a written emergency management plan that includes arrangements for immediate response from employees, notification of local emergency response agencies and the public, first aid and medical treatment, evacuations, and post-incident decontamination of affected areas. Avon conducts regular drills and works with the local Fire Department to ensure the proper execution of our plan. Avon's emergency management plan is updated to reflect any changes (in our operations and legal requirements) that would require a modified emergency response. Avon maintains an excellent working relationship with the emergency responders to ensure rapid and effective response. The results of our RMP investigation indicate that the Avon (Newark, Delaware) Branch is classified as a Program 1 facility. A Program 1 facility, as defined by the EPA, presents a minimal risk to the community. |