The Procter & Gamble Manufacturing Company - Executive Summary

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PREVENTION IS OUR FIRST PRIORITY 
Procter & Gamble (P&G) Iowa City has a long-standing commitment of maintaining a safe work environment for our employees and minimizing the impact of our operations on the environment.  Our safety and environmental programs are managed by qualified employees on site and actively supported by the participation of all employees and management.  In addition, P&G has a strong central staff of safety and environmental experts.  The goal of both our safety and environmental programs is prevention.  Safety is an integral part of every department across this site.  P&G has safety teams which focus on training, technical elements and special projects.  Although P&G's safety record is already among the best in the business, we are constantly striving for improvement.  A recent improvement was to eliminate the use of propane trucks in the plant warehouse by moving to the cleaner, more environmentally friendly, compressed natural gas.   
 
P&G is committed to the saf 
ety and protection of the local community and our neighbors.  P&G employees are active members of the Johnson County Hazardous Materials Team (HAZMAT) and the Local Emergency Planning Committee (LEPC).  The site has thirty employees trained to serve on the P&G HAZMAT Team.  Many P&G employees live near the site and support local community emergency providers.  Ten P&G employees are volunteer firefighters, one is a volunteer Emergency Medical Technician (EMT), and six are trained First Responders.  Furthermore, sixty employees are trained in the American Red Cross certified CPR and First Aid courses. 
 
P&G is also very committed to the safety and health of the environment.  The Iowa City site has had a strong history of reducing waste and emissions.  P&G has actively pursued pollution prevention as a business strategy.  Since 1990 the site has reduced air emissions by 54% despite production output increasing by 80%.  P&G Iowa City site employees have provided environmental training in th 
e local schools and sponsored a junior high school teacher to attend environmental education training at the Keystone Science Institute in Colorado. 
 
 
SYSTEMS AND PROCESSES FOR SAFE USE OF AMMONIUM HYDROXIDE 
The P&G Iowa City site manufactures shampoo, conditioners and mouthwash.  Ammonium hydroxide is one of the raw materials used to make shampoo.  Ammonium hydroxide is delivered to our site by tank trucks and is unloaded into an above ground storage tank.  The tank and unloading area is spill protected such that in the event of a spill the lost liquid material would be contained in a spill pond.   
 
 
MINIMIZING POTENTIAL FOR ACCIDENTAL ATMOSPHERIC RELEASES 
Although this was not required, a detailed hazard assessment study conducted per the OSHA Process Safety Management (PSM) protocol was used to identify potential points from which ammonium hydroxide may be spilled or leaked from the process. These points have received special consideration during the process design, the training of  
operators and maintenance personnel, and in the development of our accident prevention and response systems. The studies are updated at least every 5 years, or when there are significant changes to the equipment, by a team of engineers and other specially trained employees. Training, maintenance, controls, operating practices, and purchasing requirements are updated based on the results of these hazard studies.  
 
A "worst case release" is defined by EPA as an instantaneous release of the single largest vessel (one storage tank), outdoors, during a time of light winds and stable weather conditions. An instantaneous release of this kind could be caused by an earthquake or by an airplane hitting the tank. The worst case release assumes that no emergency response would occur, even though both the site Emergency Response Team and the Johnson County Hazardous Materials Team are trained to respond to this type of spill. The liquid portion of a release of an entire storage tank would be contai 
ned by the existing spill pond.  According to our computer model, vapors from a worst case release could reach off-site residential populations. 
 
The alternative release scenario is defined as a 10 minute release from a leaking storage tank at more typical weather conditions.  Again, the existing spill pond is designed to contain the liquid portion of this leak.  According to computer modeling (following EPAs protocol), the vapors from our alternative release scenario could reach off-site but would not impact off-site residential populations. 
 
 
SAFETY AND PREVENTION  
The first line of defense at our plant is accident prevention.  The ammonia tank has a level indicator on it.  Ammonia will only be unloaded into the tank when there is enough space to allow unloading the entire contents of the tank truck.  This administrative procedure of connecting each tank truck only once minimizes the risk of accidental spills.  In the event of an upset during unloading, there is a manual shutoff val 
ve at the unloading station.  Furthermore, operating procedures require the attendant to maintain visual contact while unloading. 
 
In the event of an accidental release, the site has systems to respond to the spill or leak quickly. Spills or leaks of liquid ammonium hydroxide anywhere in the tank farm would be contained in the spill ponds.  A spill or leak from the system anywhere inside the building would also be contained.  The site wide emergency communication system can be activated both in the tank farm and inside the process building to quickly communicate to site emergency response personnel the location of the incident.  If necessary, the police and fire departments have procedures to manage communications and instructions to the public by means of the emergency siren, TV and radio broadcasts, and by direct communications in the streets of potentially affected neighborhoods.  
 
Procter & Gambles Iowa City emergency response team conducts drills with the aid of the Iowa City Fir 
e Department and Johnson County HAZMAT Team.  The drills train new responders, refresh the skills of the experienced responders, and identify improvements to the communications and response systems.  Equipment that would be used to respond during a real emergency is used during these drills. The Iowa City Fire Department and Johnson County HAZMAT teams are toured through the site on a regular basis to increase their awareness of site layout and knowledge of where potentially hazardous materials are stored.  
 
 
HISTORY OF SAFE OPERATIONS 
The P&G Iowa City site has an excellent safety history with ammonium hydroxide.  The plant has never had a reportable accident involving ammonia or the ammonia system that caused injury or property damage to anyone on site or off site.   
 
 
ALL EMPLOYEES RECEIVE SAFETY AND ENVIRONMENTAL TRAINING 
All technicians using the ammonium hydroxide system are trained and qualified in our standard operating procedures. The operating procedures include steps to be t 
aken in both routine and non-routine operations.  These operating procedures are reviewed at least annually and updated, if necessary.  All ammonia system employees participate in routine emergency response drills and refresher training on the system annually.  The results of hazard assessments and the emergency response drills are communicated to the operating and unloading teams.  
 
 
EMERGENCY RESPONSE PLANS DEVELOPED WITH LOCAL EXPERTS  
An emergency response plan has been developed and coordinated with the LEPC, including the Iowa City Fire Department, Johnson County Hazardous Materials (HAZMAT) Team, and Iowa City Police Department.  The plan is tested by routinely conducting drills
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