PARKE-DAVIS COMPANY - Executive Summary |
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SECTION 1 - REGISTRATION INFORMATION Parke-Davis, a division of Warner-Lambert, manufactures a variety of life-saving and life-enhancing pharmaceuticals at its facility located at 188 Howard Avenue, Holland, Michigan. Parke-Davis uses two chemicals that are regulated by the EPA Risk Management Plan (RMP) rules (40 CFR Part 68) to manufacture several pharmaceutical products including: Neurontin and Dilantin (seizure control); Benadryl (anti-histamine); Cognex (cognition enhancer); and Accupril (anti-hypertension agent). These chemicals are phosgene and anhydrous hydrogen chloride, and they are also regulated by the OSHA Process Safety Management (PSM) standard (29 CFR Part 1910.119). This Executive Summary introduces the key components of Parke-Davis' risk management program including a description of the regulated substances, hazard assessments, accident prevention program, and emergency response program. Specific elements of Parke-Davis' risk management program are presented in t he attached Risk Management Plan. Parke-Davis has always acknowledged its civic responsibility to provide its colleagues and the residents of the Holland community with a safe facility. Parke-Davis strives to meet or exceed applicable EPA and OSHA rules and regulations, and periodically evaluates the quality of its environmental and safety programs. The facility's accident prevention and emergency response procedures have been designed to protect our colleagues, the community and environment, and Parke-Davis properties, to the greatest extent possible. Parke-Davis maintains extensive on-site emergency response equipment and trained personnel, and has integrated its emergency response procedures with those of the Holland Township Fire Department and the Ottawa County Local Emergency Planning Committee. The designated representative and contact person for environmental matters and this Risk Management Plan at the Parke-Davis facility is Mr. Tom Bauer, Director of Materials Managemen t and Environmental Control. He can be contacted at the facility at (616) 392-2375. SECTION 2 - SUBSTANCE PROPERTIES, RMP PROCESSES, AND WORST CASE HAZARD SCENARIO Phosgene and anhydrous hydrogen chloride are critical to the manufacture of several pharmaceutical products at the Holland, Michigan facility. Both chemicals require careful storage and handling due to their potential toxic hazards. A detailed description of the chemical properties, regulated processes, process safety and control features, and the worst-case hazard scenario are provided below. Chemical Properties Phosgene is a toxic and corrosive liquid with a boiling point of 47 oF. Phosgene evaporates to form a gas at temperatures above the boiling point. Exposure may cause severe irritation to the respiratory system, skin and eyes. Inhalation of high concentrations of phosgene may cause headache, olfactory fatigue, respiratory irritation, difficulty breathing, lung congestion and, under extreme conditions, death. In addition, symptoms may be delayed for a period of from 24 to 48 hours after exposure. It is critical that persons exposed to phosgene seek immediate medical attention for prompt treatment. The threshold quantity for phosgene is 500 pounds under the EPA RMP rules and 100 pounds under the OSHA PSM standard. Hydrogen chloride is a corrosive gas. Exposure may cause severe irritation to the respiratory system, skin and eyes. Inhalation of high concentrations of hydrogen chloride can cause respiratory irritation and corrosive burns, lung congestion, lung damage and, under extreme conditions, death. The threshold quantity for anhydrous hydrogen chloride is 5,000 pounds under both the EPA RMP rules and OSHA PSM standard. The EPA rules define a toxic endpoint for both phosgene and hydrogen chloride by reference to the Emergency Response Planning Guideline 2 (ERPG-2), developed by the American Industrial Hygiene Association (AIHA). The AIHA ERPG-2 is defined as "the maximum airb orne concentration below which it is believed nearly all individuals could be exposed for up to 60-minutes without experiencing or developing irreversible or other serious health effects or symptoms that could impair an individual's ability to take protective action". The AIHA ERPG-2 for phosgene is 0.2 parts per million (PPM) while the ERPG-2 for hydrogen chloride is 20 PPM. Phosgene Process Safety Phosgene is used at the Parke-Davis facility to make three pharmaceutical products. Phosgene is stored in 2,000-pound cylinders located in a secured storage area. When needed in the manufacturing process, phosgene cylinders are transported about 25 feet to a dedicated phosgene charging building. Phosgene is then charged to a process reactor through a completely isolated system. At no time during normal process operation is phosgene released to the atmosphere. The phosgene process includes: cylinder storage; the phosgene charging building, distribution system and components; proces s equipment; process control and safety systems; and process scrubber systems. Since 1986, Parke-Davis has had the following safety measures in place to minimize the risk of an accidental release of phosgene. These measures include: 1. Phosgene cylinders are stored in a secure and fenced location that is dedicated to the storage of phosgene and hydrogen chloride cylinders. Full cylinders are stored on a concrete pad and protected from direct exposure to sunlight. The cylinder storage pad is isolated from other manufacturing activities. Only DOT-approved shippers, or trained and certified Parke-Davis colleagues, are allowed to move and handle phosgene cylinders. 2. Phosgene cylinders are constructed of 13/32" thick steel in accordance with DOT regulations for over-the-road transportation. The cylinder ends are concave so that the two cylinder valves do not protrude beyond the end of the cylinder. The two cylinder valves are capped to prevent leakage. A flanged and gasketed lea k-proof bonnet then covers the two-capped cylinder valves, protecting the valves from damage and providing an additional barrier to prevent leakage to the environment. 3. A dedicated phosgene cylinder charging building was constructed in 1986. This building eliminated the need to transport and use phosgene cylinders in process areas. The building is located near the storage pad to minimize on-site transportation. Phosgene cylinders have been used in this building since 1986 without an adverse spill or leak incident. 4. The phosgene cylinder charging building contains a sump area designed to hold the contents of one phosgene cylinder. If a liquid phosgene spill were to occur, it would be contained within the charging building, and transferred from the sump to a process vessel for neutralization by the Parke-Davis Hazardous Materials Response Team. The sump area is also vented to a dedicated scrubber system that would destroy any vaporized material. 5. The phosgene cylinder rests s ecurely within a steel cradle with the cylinder head inserted through a collar into a glove box located in the phosgene charging building. The operator can remove the bonnet and make process connections to the cylinder only when the cylinder head is inserted into the glove box. The air inside the glove box is continuously vented to a dedicated phosgene scrubber system. The scubber destroys the small amount of phosgene that can be released into the glove box when the cylinder is disconnected from process piping. If a leak occurred, phosgene would be vented to the scrubber system and not released to the environment. 6. Liquid phosgene is piped to two reactor vessels through a double walled piping system. An inner welded steel pipe is contained within an outer glass pipe that is protected from damage by a metal protective guard. The annular space between the steel and glass pipes is vented to the dedicated phosgene scubber system. In addition, all phosgene valves are contained wit hin valve boxes that are vented to the phosgene scubber system. The design of the valve boxes and double piped distribution system provides for phosgene containment from the cylinder valve to the reactor. If a leak occurred, phosgene would be vented to the scrubber system and not released to the environment. 7. Nitrogen, an inert gas, is used to push phosgene from the cylinder through the double walled piping system to the reactor. Nitrogen is supplied from a dedicated bulk tank. Bottled nitrogen provides a backup source should the primary nitrogen source fail. Nitrogen pressure is controlled and process interlocks prevent phosgene from entering the nitrogen supply systems. Nitrogen is also used to pressure test phosgene piping and reactor systems prior to each phosgene use. 8. A 16-point phosgene monitoring system continuously samples plant and process areas likely to be affected by a phosgene leak. The system will activate an alarm and automatically stop the phosgene charge. The monitoring system minimizes any potential leak by automatically closing all phosgene feed control valves when the leak is detected. 9. Phosgene is used in only two reactor vessels. Both reactors are glass lined and meet the American Society of Mechanical Engineers (ASME) codes for pressure vessels. Phosgene is charged while the reactor is being vented through the scrubber system to the thermal oxidizer. Reactors are equipped with high and low-temperature sensors that stop the phosgene charge if unusual process conditions occur. A high-pressure sensor stops the phosgene charge if reactor pressure exceeds 1 pound per square inch (PSI). Emergency cooling can be provided to the reactor jacket to help slow or stop an unusually fast phosgene reaction. Manual emergency stop buttons are provided in the phosgene cylinder charging building and near each reactor. 10. Phosgene reactors are protected with emergency relief devices to prevent vessel over-pressurization. Multiple rupture d isks prevent leakage to the environment. A safety relief valve would stop vessel venting after excess pressure was vented from the reactor. Emergency venting would also activate a pressure sensor and phosgene monitor located in the vent line that would stop the phosgene charge. 11. Phosgene scrubbers are equipped with high and low-level alarms, and a low caustic flow alarm that stops the phosgene charge if the scrubber caustic circulation stops. 12. All manufacturing facilities have been designed to minimize the potential for fire. The phosgene storage pad, cylinder charging and process buildings are constructed from non-combustible materials. These facilities are equipped with Class 1, Division 1, Group D, rated electrical equipment. The cylinder charging building is isolated from the storage and use of flammable liquids and plant process areas. A fixed fire protection system with aqueous film forming foam has been installed in all plant process areas. All hot work is contr olled through a permit system. 13. Detailed annual mechanical and electrical system inspections and tests are conducted on the phosgene charging and distribution systems, process control and safety equipment. Phosgene piping and process vessels are pressure tested immediately prior to phosgene use to minimize the potential for a process leak. 14. Process operators working with phosgene have been trained and certified by Parke-Davis in accordance with OSHA PSM standard requirements. Process operators are required to follow written process operating procedures contained in batch cards that cover phosgene charging, processing, and emergency response. 15. Parke-Davis maintains a colleague staffed and fully trained Hazardous Materials team. The Haz-Mat team is equipped and trained to use full body Level A protective suits and self-contained breathing apparatus. An emergency cylinder capping and patch kit is also available. The Haz-Mat team has conducted emergency response drills for potential phosgene leaks and emergencies. Hydrogen Chloride Process Safety Hydrogen chloride is stored in 600-pound cylinders adjacent to phosgene cylinder storage. The total amount of hydrogen chloride contained in the cylinder storage area at any given time may exceed the applicable RMP rule threshold quantity of 5,000 pounds. At this time, hydrogen chloride is not used in any batch process operation in an amount greater than the applicable threshold quantity of 5,000 pounds. Consequently, the storage area is the only hydrogen chloride process currently subject to regulation under the RMP rule. Parke-Davis has implemented a number of safety measures to minimize the risk of an accidental release of hydrogen chloride. These measures include: 1. 600-pound hydrogen chloride cylinders are stored in a secure, fenced, dedicated area on a concrete pad. The storage pad is isolated from other manufacturing activities. Only DOT approved shippers or trained and certified Parke- Davis colleagues are allowed to move and handle hydrogen chloride cylinders. These precautions help to prevent cylinder mishandling and damage. 2. Hydrogen chloride cylinders are constructed of steel in accordance with DOT regulations for over-the-road transportation. The cylinder valve is capped to protect it from damage during transportation. Cylinders are mounted and secured onto steel carts prior to transportation into process areas. All colleagues who use fork trucks to move hydrogen chloride cylinders are trained and licensed by Parke-Davis. 3. The hydrogen chloride cylinder storage pad and process buildings are constructed from non-combustible materials. These facilities are equipped with Class 1, Division 1, Group D, rated electrical equipment. The cylinder storage pad is isolated from the storage and use of flammable liquids and plant process areas. A fixed fire protection system with aqueous film forming foam has been installed in all plant process areas. All hot wor k is controlled through a permit system. 4. Process operators working with hydrogen chloride have been trained and certified by Parke-Davis in accordance with OSHA PSM standard requirements. Process operators are required to follow written process operating procedures contained in batch cards that cover hydrogen chloride charging, processing, and emergency response. 5. Parke-Davis maintains an on-site colleague staffed Hazardous Materials team and a separate fire brigade. The Haz-Mat team is equipped with Level A protection. An emergency cylinder capping and patch kit is also available. All colleagues not on the Haz-Mat team, contractors and visitors, would evacuate the plant if a hydrogen chloride release were to occur. Parke-Davis is evaluating and may make two significant modifications involving the storage and use of anhydrous hydrogen chloride in 1999. 1. Parke-Davis will significantly reduce its use of the 600-pound cylinders through use of a bulk hydrogen chloride stor age and distribution system. Hydrogen chloride will be stored in six 3,500-pound cylinders supported by a flat bed trailer. The facility will have unloading facilities for three trailers; however, only one cylinder of one trailer will actively supply the facility's bulk hydrogen chloride distribution system at one time. The second trailer will be in backup status while the third will be in route to and from the supplier. The use of the bulk system will result in improved plant safety due to the increased use of automated control systems and feed interlocks, reduced transfer pressures, and a significant reduction in the handling and use of the 600-pound cylinders. The bulk storage and transfer facilities have been installed and are awaiting completion of pre-startup qualification inspections and tests. 2. The amount of anhydrous hydrogen chloride used in one product may be increased to a quantity greater than 5,000 pounds as part of an increase in the product batch size. Parke-D avis will submit revisions to this Risk Management Plan as necessary prior to implementation of these new or modified processes. Worst-Case Release Scenario The EPA rules required the development of worst-case release scenarios that assume the entire contents of the largest container of a highly hazardous chemical are released in ten minutes under adverse weather conditions. Parke-Davis developed worst case release scenarios for phosgene and hydrogen chloride based on the maximum cylinder quantities of 2,000 pounds and 600 pounds, respectively. Weather conditions assume a 98 oF ambient temperature, 73% relative humidity, 3.4 mile per hour (1.5 meter per second) wind speed, and F class atmospheric stability. The worst case modeling was conducted using the EPA approved SLAB model for dense gases. Model results are contained in the checklist portion of this plan. The phosgene worst-case scenario resulted in a greater downwind distance to the toxic end point than the hydrogen chlori de scenario. Public and environmental receptors are located within the radius of the worst-case release scenario. These receptors include homes; small businesses; commercial, office and industrial areas; schools; hospitals; churches; public parks and recreational areas. Parke-Davis believes that the EPA-defined worst case phosgene scenario can not occur due to the high level of phosgene process safety, and the process safety management and emergency response programs that have been implemented at Parke-Davis. SECTION 3 - ALTERNATIVE RELEASE SCENARIOS Recognizing that a worst-case scenario is extremely improbable and that companies like Parke-Davis have many safeguards in place to prevent and respond to accidents, the RMP rules also require that alternative release scenarios be developed. Conservative Estimates Used for Alternative Release Scenarios The described alternative release scenarios are extremely conservative. Parke-Davis believes that the described scenarios for phosgene and hydrogen chloride are highly unlikely to occur due to the high level of process safety and the associated Parke-Davis process safety management and emergency response programs. Parke-Davis believes that any phosgene or hydrogen chloride release would have substantially less impact on potential environmental and public receptors than the described alternative scenarios. Specifically, the phosgene alternative release scenario requires the simultaneous failure of multiple process control and safety systems, and the complete release of reactor contents without any response by chemical operators or the Haz-Mat team to minimize or respond to the release. Phosgene Phosgene is used in two processes. In one process, an initial 440-pound charge of phosgene is made to the reaction mixture. The reaction undergoes a small temperature increase as the reaction is initiated. Once initiated, phosgene reacts as it enters the reactor and does not accumulate in an appreciable quantity. The only potential for any significant phosgene release is during the period of reaction initiation. The alternative release scenario assumes that the full 440-pound phosgene charge is released through the reactor emergency vent as a gas at a temperature of 149 oF and an elevation of 22 feet under typical weather conditions. Weather conditions assume a 48 oF ambient temperature, 62% relative humidity, 9.1 mile per hour (4.1 meter per second) wind speed, and D atmospheric stability. A ten-minute release is assumed. This is consistent with the worst case release period and approximates the time required to vent the reactor contents through a safety relief valve which is assumed to open and close to maintain reactor pressure between relief valve set points. Please note that Parke-Davis has never experienced a phosgene release such as described in this alternative scenario. The alternative case modeling was conducted using the EPA approved SLAB model for dense gases. Model result s are contained in the checklist portion of this plan. Public and environmental receptors are located within the radius of the alternative release scenario. These receptors include homes; small businesses; commercial, office and industrial areas; schools; churches; public parks and recreational areas. Hydrogen Chloride The hydrogen chloride alternative release scenario assumes that the valve and protective cap is sheared off of a full 600-pound hydrogen chloride cylinder during transportation. Hydrogen chloride is released as a liquid at ground level under normal weather conditions and rapidly evaporates. Weather conditions assume a 48 oF ambient temperature, 62% relative humidity, 9.1 mile per hour (4.1 meter per second) wind speed, and D atmospheric stability. The release is estimated to last about 3 minutes. Please note that Parke-Davis has never experienced a hydrogen chloride release such as described in this alternative scenario. The alternative case modeling was cond ucted using the EPA approved SLAB model for dense gases. Model results are contained in the checklist portion of this plan. Public and environmental receptors are located within the radius of the alternative release scenario. These receptors include homes; small businesses; commercial, office and industrial areas; schools; churches; public parks and recreational areas. SECTION 4 - FLAMMABLES: WORST CASE Parke-Davis does not use any of the listed flammable substances in an amount above the threshold quantity. SECTION 5 - FLAMMABLES: ALTERNATIVE RELEASE Parke-Davis does not use any of the listed flammable substances in an amount above the threshold quantity. SECTION 6 - ACCIDENT HISTORY During the five-year review period, Parke-Davis experienced only one chemical release from a regulated process that resulted in one on-site non-lost time injury to a contractor employee. On April 26, 1999, a phosgene release occurred due to a pipe leak located in the phosgene scrubber syst em immediately outside of the manufacturing building. Continuous air monitoring equipment confirmed the presence of phosgene inside the manufacturing building at a peak concentration of about 0.65 parts per million. Several colleagues who worked in the general area of the release were sent to a medical clinic for observation but no injuries were reported. It was estimated that less than one pound of phosgene was released. The incident was investigated and corrective actions were taken. On April 27th, a contractor employee experienced respiratory irritation and chest tightness and stated that he had smelled phosgene the previous day. The contractor was sent to a local medical clinic as a precaution. He was given a prescription medication and returned to work. Parke-Davis is including this incident in the RMP since the injury is OSHA recordable due to the employee's receipt of a prescription medication. Parke-Davis has not experienced any other accident from a regulated process th at resulted in on-site deaths, injuries, or significant property damage, or known off-site deaths, injuries, evacuations, sheltering in place, property damages, or environmental damage. To the best of current management's knowledge, Parke-Davis has never had any chemical release that resulted in colleague or contractor deaths, or any off-site injury to the public. SECTION 7 - PREVENTION PROGRAM 3 (PROCESS SAFETY MANAGEMENT PROGRAMS) Parke-Davis maintains an OSHA Process Safety Management program consisting of the following elements: A. Colleagues participate in programs related to facility and process safety. PSM program participation includes hourly and supervisory colleagues from chemical operations and maintenance crafts, safety and environmental engineers, Parke-Davis and contract engineers, departmental managers, and Warner-Lambert corporate safety professionals. B. Parke-Davis maintains an active program to retain and manage process safety information. The SAP Maintena nce program contains a database that stores basic information for process equipment such as reactors, tanks, pumps, safety relief valves, etc. The Engineering Department retains preventative maintenance, inspection and test records along with process equipment and/or engineering project files that contain equipment drawings and specifications, P & IDs, manufacturer's literature, etc. Detailed manufacturing batch records contain information regarding process substances and chemistry, and detailed step-by-step manufacturing and safety instructions. The Hazard Laboratory maintains calorimetry and other test data for raw materials and process chemistry. Equipment qualifications (inspections and tests) are conducted prior to start-up to confirm equipment capabilities. The Engineering and Automation Departments retain qualification documents. The Safety Department maintains material safety data sheets and toxicity data. Additional databases and process safety files are maintained by Par ke-Davis. C. Parke-Davis conducted the following process hazards analyses (PHA) for RMP regulated processes: 1. Original Phosgene PHA (1986) 2. Second Phosgene PHA (1993) 3. Original Hydrogen Chloride Cylinder PHA (1995) 4. Phosgene PHA Revalidation (1998 - 99) Parke-Davis maintains a laboratory facility to test and evaluate the hazardous properties of new raw materials, intermediates, and process reactions. Process hazards are formally reviewed prior to pilot plant production, prior to transfer to manufacturing, or whenever the process is changed. PHA recommendations are tracked to their resolution. D. Parke-Davis develops and maintains comprehensive operating procedures describing the manufacture of all pharmaceutical products. These operating procedures, called batch records, include the safety and emergency information required by the OSHA PSM standard. E. Parke-Davis maintains a comprehensive training program for new mill and chemical operators, and maintenance crafts-pe rsons. These colleagues receive safety training in hazard communication, personal protective equipment, process safety, hot work, confined space entry, line opening and other subjects. New mill and chemical operators also receive computer based safety training. New mill operators receive 40 hours of classroom operator training and additional on-the-job training and performance appraisals. New chemical operators receive an additional 40 hours of classroom operator training and additional on-the-job training and performance appraisals. In addition, all chemical operators were process safety re-certified in 1998. F. Parke-Davis maintains safe work procedures for confined space entry, hot work, line breaking and equipment lockout. All such activities conducted on-site by Parke-Davis colleagues or contractor colleagues require the completion of a safe work permit. The permit assures that proper safety procedures are followed and that proper equipment is used. G. Parke-Davis mainta ins a contractor safety program to inform contractors of facility hazards and emergency procedures. Parke-Davis project engineers control contractor work and contractors are required to use Parke-Davis safe work permits. Contractor safety records are evaluated periodically. H. Parke-Davis maintains equipment qualification inspection and test procedures to assure that new or modified process equipment and facilities are safe to operate before hazardous substances are introduced into these systems. I. Parke-Davis maintains a mechanical integrity program that includes preventative maintenance, and the inspection and testing of process, safety and control equipment. Phosgene and hydrogen chloride process equipment is specifically covered by the mechanical integrity program and preventative maintenance procedures. J. Parke-Davis maintains change control programs and procedures to evaluate the potential effect of a change to facility and process equipment, process chemistry, and op erating procedures, on plant and process safety. K. The Safety Department investigates all colleague injuries and illnesses that are recorded on the OSHA log as well as any substance release, fire or near miss involving a highly hazardous substance. All safety recommendations resulting from an accident investigation are tracked to resolution on a Safety Recommendation Tracking Database that is updated quarterly. L. Parke-Davis participates in a compliance audit program maintained by Warner-Lambert corporate regulatory staff to assure audits of the Parke-Davis process safety management program, safety program, industrial hygiene program and environmental program on a three-year schedule. All safety recommendations resulting from a safety or process safety audit are tracked to resolution on a Safety Recommendation Tracking Database that is updated quarterly. In addition to the described process safety and risk management programs, Parke-Davis maintains comprehensive health and s afety programs to control other potential colleague hazards. These programs include fire protection, hazard communication, respiratory protection, personal protective equipment, industrial hygiene, medical surveillance, safety inspections, laboratory safety, and others. SECTION 8 - PREVENTION PROGRAM 2 Parke-Davis does not have any RMP Program Level 1 or 2 processes. Due to the application of the OSHA PSM standard, the phosgene and hydrogen chloride processes are Prevention Program Level 3. SECTION 9 - EMERGENCY RESPONSE PROGRAM Parke-Davis maintains a comprehensive emergency response program that includes a colleague-staffed Hazardous Materials (Haz-Mat) Team, Fire Brigade, Confined Space Rescue Team, and Medical/First Aid Team. Team members are trained as described below: 1. Fire Brigade - 25 Parke-Davis colleagues serve as members of the Fire Brigade. Team members receive monthly training, participate in periodic drills and have the opportunity to attend a 40-hour industr ial fire fighting course offered at Texas A & M. Annual testing of team members is performed. Two colleagues, who serve as fire chief, have received substantially more training including courses on command and have at least 10 years of fire brigade experience. 2. Haz-Mat Team - 10 Parke-Davis colleagues serve as members of the Haz-Mat team. All members have been certified at the OSHA Hazardous Materials Technician level. Team members receive monthly training and participate in periodic drills. Many team members have attended a 40-hour hazardous materials course at the University of Nevada in Reno. Annual testing of team members is performed. Parke-Davis maintains a hazardous material truck and trailer fully equipped to respond to potential site emergencies. Team members can perform emergency response activities in fully encapsulating Level A protective suits and self-contained breathing apparatus. 3. Confined Space Rescue Team - 10 Parke-Davis colleagues serve as members of th e rescue team. All members have attended a 24-hour confined space rescue course at Texas A & M. A rescue team member must be present during all Type I confined space entries. 4. Medical/First Aid Team - Over 45 colleagues are members of the medical response team. All members receive an initial 8 hours of first aid/CPR training, an annual CPR re-certification course, and a first aid re-certification course once every three years. In addition, Parke-Davis employs a part-time physician, plant nurse, 3 colleagues licensed as Emergency Medical Technicians, and 4 colleagues licensed as Medical First Responders. Parke-Davis maintains a written Emergency Response Plan describing facility evacuation and emergency response programs and procedures. Specific emergency response actions have been defined for a variety of hazardous chemicals including phosgene and hydrogen chloride. The pharmaceutical batch record also contains a detailed description of potential phosgene and hydrogen chloride releases and the appropriate emergency response actions. Parke-Davis maintains a good relationship with the Holland Township fire department. Township fire fighters normally tour the Parke-Davis facility once per year. Parke-Davis colleagues work closely with the Ottawa County Local Emergency Planning Committee (LEPC) and currently the Parke-Davis Director of Safety is the LEPC Vice-Chairman. The LEPC has developed an emergency response plan for the Parke-Davis site that was last updated in May 1999. Parke-Davis has also provided RMP information and plant tours to local community leaders. PLANNED CHANGES TO IMPROVE SAFETY Parke-Davis proposes to upgrade the existing phosgene process control system hardware and software. The upgrade will be complete in the second quarter, 2000 and will better inform chemical operators of potential emergency conditions and provide improved process control. PARKE-DAVIS HOLLAND - RISK MANAGEMENT PLAN, EXECUTIVE SUMMARY Page 9 of 9 PARKE-DAVIS HOLLAND - RISK MANAGEMENT PLAN |