Fiskars Inc Wausau Division - Executive Summary

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Executive Summary 
Fiskars is committed to operating in a manner that is safe for our workers, the public, and the environment.  Fiskars has established a system to help ensure safe operation of the process at this facility as part of that commitment.  A component of this system is our risk management program (RMP) designed to help manage the risks at Fiskars.  The RMP complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR part 68, also known as Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule).  This submittal is intended to meet the requirement of the rule to submit a risk management plan (RMPlan) and provide the public with a description of the risk management program at Fiskars. 
The accidental release prevention and emergency response policies at your facility:  Fiskars is committed to the safety of our workers and the public, and to the preservation of the environment.  This commitment is demonstrated by 
the systems developed to prevent accidental releases of hazardous substances. Two components of this system are the process safety management (PSM) of highly hazardous chemicals and the (RMP).  The PSM and RMP components are designed to prevent a release of a hazardous substance.  In the unlikely event of a significant accidental release, Fiskars would evacuate our workers and contact the local fire department (has both Level A & B response teams) to control and contain the release and to prevent and/or reduce the consequences of the release.  Fiskars has established a program to warn the community if a significant release were to occur.  The program has been coordinated with the county Office of Emergency Government and has been in place for over 10 years. 
A description of your facility and the regulated substances handled:  Fiskars is a manufacturer of scissors, rotary cutters, pinking shears and similar products.  Anhydrous ammonia is the only substance regulated by the RMP rule t 
hat is present above the EPA planning threshold quantity.  Anhydrous ammonia is stored at a maximum inventoried amount of 18,500 pounds.  The anhydrous ammonia process is a Program 3 process for RMP rule compliance purposes.  The anhydrous ammonia is dissociated to nitrogen and hydrogen with the nitrogen being used as an inert blanketing gas in curing ovens and the hydrogen used as a fuel. 
Offsite consequence analysis:  A worst-case release scenario and an alternative release scenario analysis are required by the RMP rule.  The worst-case release scenario (extremely unlikely) for the anhydrous ammonia process is failure of a 2,000 gal (9,100 pound) anhydrous ammonia storage tank.  Administrative controls in place limit the filling of the tank to 90% capacity; no passive mitigation controls are in place.  The distance to toxic endpoint for the worst-case release scenario is 1.2 miles.  The alternative release scenario (a more realistic scenario) considers a release of anhydrous ammonia 
during the filling of the storage tank from a tank truck.  The distance to endpoint for this more likely scenario is 0.3 mile. 
Accidental Release Prevention Program and Chemical-specific Prevention Steps:  Fiskars maintains an aggressive safety program keyed to the OSHA PSM standard.  The accident prevention programs in place at Fiskars include: 
Safety information.  Fiskars maintains current material data safety sheets that are used to maintain safe operation of the process. 
Training.  Fiskars provides training for new employees in facility operations, as well as refresher training for current employees. 
Mechanical integrity.  Fiskars maintains a program for the regular inspection and maintenance of critical equipment. 
Incident investigation.  Fiskars maintains a policy that if there is an incident involving the process it is investigated thoroughly. 
Process hazard analysis.  Fiskars has conducted a process hazard analysis and implemented recommended improvements to the process. 
Operating procedures.  Fiskars has developed comprehensive operating procedures for all equipment, which is followed by all employees. 
Five-year accident history:  Fiskars has never had an accident involving the anhydrous ammonia process that caused death, injury, property or environmental damage, evacuations, or sheltering in place. 
Emergency response program:  In the event of an emergency involving anhydrous ammonia, it is our policy to notify our local fire department (has both Level A & B response teams) and request they respond to the emergency.  We have discussed this policy with the fire department. 
Planned changes to improve safety:  Fiskars constantly strives to improve safety of the anhydrous ammonia process.  Our system of incident investigation, mechanical integrity periodic audits and employee suggestions will be used to improve the system.  All recommended improvements from the process hazard analysis have been implemented.
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