PSM Final Exam

What are the five primary activities involved in conducting a Preliminary Hazard Analysis?

1. what - if 2. Check list 3. Hazardous Operability study (HAZOP) 4. Failure Mode and Effect Analysis (FMEA) 5. Fault Tree Analysis FTA

What are the four primary benefits of training?

1. reinforcement goals of the organization 2. improve performance 3. less accidents 4. reduce cost

PSM standard went to effect in:

May, 1992

Where in the Code of Federal Regulations (CFR) can the PSM standard be found?

29 CFR 1910.119 - PSM Standard

Where in the CFR can you find OSHA's PSM Standard?

29 CFR 1910.119f

What is the preferred source for obtaining the information necessary to determine the hazards of the chemicals used in a process?

29 CFR 1910.1200

Where in the CFR would find the criteria used to evaluate trade secret informatin

29 CFR 1910.1200(b)

The EPA proposed that, within _________________ of the date of publication of the final rule, all facilities register with EPA if they have regulated substances in a quantity that exceeds the threshold quantity. (Amount of time)

3 Years to comply

The PSM standard requires the employer to initiate the accident/incident investigation within ____ hours of the accident/incident occurring.

48 hours

For explosive substances the threshold quantity established by the EPA is _________.

5,000 pounds

Define "catastrophic release" according to the PSM Standard?

A major uncontrolled emission, fire, or explosion, involving one or more highly hazardous chemicals that presents serious danger to employees in the workplace.

What are some of the sources you can use to obtain reliable and accurate information regarding inspection methodologies for process equipment?

Using generic tool methodology for assessing the off-site impacts would allow a more direct comparison among facilities of potential off-site consequences.

A ___________________________release is any accidental release of a regulated substance that has caused or has the potential to cause off-site consequences such as death, injury, or adverse effects to human health or the environment or to cause the public to seek shelter or be evacuated to avoid such consequences.

Significant Accidental Release

OSHA's PSM standard requires initial training for each employee. What are the three primary areas of emphasis for training?

Specific Safety Practices, Emergency Shutdown, Safe Work Practices

Investigations of major accidents concluded that most of the incidents were caused by one or more of four key factors:

Technology Management Systems Human error External Events

Paragraph (m) (6) of the PSM standard requires that the accident report be retained ____ .

The report shall be reviewed with all affected personnel whose job tasks are relevant to the incident findings including contract employees where applicable.

Why retail facilities are exempt from 29 CFR 1910.119?

The retail facilities packages are small not enough quantity to equal a hazard. All of the hazardous products are also separated far enough not to considered combine or close proximity.

The PSM standard refers to secondary lines of defense. What are some examples of secondary lines of defense?

The secondary lines of defense would include fixed fire protection systems like sprinklers, water spray, or deluge systems, monitor guns, etc., dikes, designed drainage systems, and other systems which would control or mitigate hazardous chemicals once an unwanted release occurs.

What is the purpose of including previous incidents when conducting the process hazard analysis?

To identify if they had previous incident which likely lead to catastrophic consequences in the workplace.

What are the characteristics of the team that is assembled to develop a written management of change program?

Under the proposed rule, the owner or operator of a facility would be required to evaluate every change in equipment (except change that satisfy the design specification of the device replaced), processes, chemicals, or procedures to ensure that the technical basis of the change is documented and that the changes does not create new hazards; if new hazards are created or if the change results in different procedures being needed, these hazards and changes would need to be addressed prior to implementation. Training, SOPs, and maintenance programs may need to be revised as a result of changes; the process hazard analysis and hazard assessment may need to be revised as well.

In addition to the worst-case release scenarios, EPA would require facilities to analyze other more likely significant accidental release scenarios for each process in which the regulated substance is used above the threshold quantity. In doing these analyses, what are the assumptions that can be made relative to passive mitigation systems and active mitigation systems?

When examining these potential release scenarios, facilities would be allowed to assume that passive mitigation systems, such as containment dikes, functioned properly. Active mitigation systems, such as excess flow valves, fail-safe systems, scrubbers, flares, deluge systems, and water curtains, would be assumed to fail. The agency plans to issue guidance on the evaluation of a range of accidental release and determination of the worst-case scenario.

A ___________________________ release means the loss of all of the regulated substance from the process in an accidental release that leads to the worst off-site consequences.

Worst-Case Scenario accidental release

The employer must ensure that any maintenance materials, spare parts, and equipment are suitable for the process application for which they will be used. You can think in terms of the fact that all replacement/modification materials must be ___________________________the same as the original parts.

form, fit and function

OSHA introduced HAZCOM standard (29CFR1910.1200) to require employers to:

inform employees about the presence of hazardous substances in the workplace.

Clean Air Act Amendments of 1990 enacted?

law that OSHA enact the PSM Standard

What types of items are covered under the management of change requirements in the PSM standard?

(1) They help facilities evaluate changes and prevent accidents caused by unintended effects from alterations of equipment, procedures, and chemicals; and (2) they ensure that the process safety information and process hazard analyses are kept up-to-date.

PSM applies to (EXCEPT)

(a) consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling), if such fuels are not a part of a process containing another highly hazardous chemical covered by the standard. (b) flammable liquids stored in atmospheric tank or transferred which are kept below their normal boiling point without benefit of chilling or refrigeration.

Code Reg 1910 - two standards

1910.38 - Fire 1910.120 - Safety HAZOP

What are the five areas of consideration that must be addressed prior to any change in a covered process?

----

Consider the statement, "If a change to the process results in a change in the required process safety information, then ........" Now, what are the actions that would be required relative to the PSM program information?

Chemical process are integrated systems; changes in one part of the process can have unintended effects in other parts of the systems. It is, therefore, important that all changes in process , chemical, and procedures be reviewed prior to their implementation to identify any potential hazards that may be created by the modification. Although most changes at facilities are intended to improve safety and efficiency, any modification can have unintended effects and requires a specific review of the safety implication of the change.

What are the civil penalties associated with violation of the EPA's Part 68 of 40 CFR?

Civil penalties of up to $25,000 per day per violation, as well as criminal sanctions (58 Fed. Reg. 54190).

Assurance of ___________________________provides the opportunity to improve the reliability of emergency control and process equipment.

Compliance

DHS

Department of Home Security

Why is a team approach considered to be the best approach to use when conducting the process hazard analysis?

Groups can help each other see the big picture more clearly.

ECN

Engineer Change Notice

ECP

Engineer Change Proposal

EPA

Environmental Protection Agency

OSHA introduced

HAZCOM standard (29CFR1910.1200)

When did the list of substances and threshold quantities for the EPA's RMP became effective?

January 31, 1994 under the section 112(r) of the Clean Air Act

Under what circumstances would all of the provisions of the PSM standard apply to a contract employer?

Paragraph (g) (1)

Inspection and testing must be performed on process equipment, using procedures that follow recognized and generally accepted good engineering practices. The frequency of inspections and tests of process equipment must conform to ___________________________and good ___________________________.

Manufacturers' recommendations & Good engineering practices

OSHA

Occupational Safety and Health Administration

The off-site consequence analyses for the EPA's RMP must be updated every _________ with the RMP update, or sooner if changes at the facility or its surroundings might be expected to make the results inaccurate i.e., a substantial increase or decrease in the quantity of a regulated substance or major changes in housing or land use patterns.

Periodically

The ___________________________ confirms that the equipment is in accordance with design specifications, appropriate procedures are in place, and necessary training has been given.

Pre-Startup Safety Review

Consider the Preliminary Hazard Analysis and the HAZOP, how are they different and how does this affect the application of their use?

Preliminary hazard analyses focuses on conducting and identifying potential hazards and prioritize them according to the likelihood of an accident or injury being caused by the hazard. It also measures the severity of the injury, illness, or property damage. HAZOP process is used to identify potential hazards and operational problems in terms of plant design and human error.

What types of equipment are included in the PSM mechanical integrity requiremet?

Pressure vessels and storage tanks; Piping systems (including piping components such as valves); Relief and vent systems and devices; Emergency shutdown systems; Controls (including monitoring devices and sensors, alarms, and interlocks); and Pumps.

What is process Safety Management?

Process Safety Management is the proactive identification, evaluation and mitigation or prevention of chemical releases that could occur as a result of failure in process, procedures or equipment.

What is the purpose for having operating procedures?

Provides specific instructions or details on what steps are to be taken or followed in carry out the stated procedures.

With regards to the EPA's concerns, what is meant by a "primary line of defense"?

an employer has available is to operate and maintain the process as designed, and to keep the chemicals contained. This line of defense is backed up by the next line of defense which is the controlled release of chemicals through venting to scrubbers or flares, or to surge or overflow tanks which are designed to receive such chemicals, etc. These lines of defense are the primary lines of defense or means to prevent unwanted releases.

How often must the employer certify that operating procedures are current and accurate?

annually

How often must the PHA be updated and re-validated?

each year, starting with the second year after the effective date of the standard.

What is the purpose of the Preliminary Hazard Analysis?

effectively identify, evaluate and central hazardous associated with process facilities.

Who is responsible for ensuring that contract employees adhere to the safety rules of the facility?

employer are responsible for selecting a contractor, shall obtain evaluate information regulating performance and program.

Process:

means any activity involving a highly hazardous chemical including any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or combination of these activities. For purposes of this definition, any group of vessels which are interconnected and separate vessels which are located such that a highly hazardous chemical could be involved in a potential release shall be considered a single process.

Trade secret:

means any confidential formula, pattern process, device, information or compilation of information that is used in an employer's business, and that gives the employer an opportunity to obtain an advantage over competitors who do not know or use it. Appendix D contained in 29 CFR 1910.1200 set out the criteria to be used in evaluating trade secrets

Facility:

means the buildings, containers or equipment which contains a process

Hot work:

means work involving electric or gas welding. Cutting, brazing, or similar flame or spark-producing operations.

What are the recognized types of accident investigation and analysis discussed in the text and in class?

operator's mistake poor training inappropriate SOPs poor design of control systems equipment failure from improper maintenance misuse of equipment (operating at too high a temperature use of incompatible materials

A ___________________________ must be conducted for new facilities, restart of suspended operations, and extensive modifications that required shutdown of existing facilities, modification and restart.

owners and operators

What is the purpose of OSHA's PSM standard?

preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals.

refer to the operational time between failures as the ___________or as the ______both are sometimes represented with the Greek character_________________.

refer to the operational time between failures as the _____MTBF______or as the ___mean time between failure___both are sometimes represented with the Greek character __________λ_________________.

How often is Refresher Training required?

three years

OSHA wants employees

to be aware of the hazards associated with he chemicals that they are working with.

PSM standard applies

to those companies with processes involving any of more than 130 listed toxic and reactive chemicals above threshold quantities. And who are not excluded based on the "applicable" section at the front of the standard.

Human Error and inadequate management systems

were the most significant contributing factors to major plant accidents.

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The employer must develop and implement safe work practices to provide for the control of hazards during work activities such as lockout/tagout, confined space entry, opening process equipment or piping, and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. What are the three objectives of this requirement?

1. Able to recognize 2. Able to identify 3. Able to prevent

List five items that should be included in a set of operating procedures.

1. Data to be recorded 2. Operating conditions to be maintained 3. Samples to be collected 4. Safety & Health precaution 5. Understandable to employees

List three sources of objective information that employers can use to evaluate the safety performance of outside contractors.

1. EMRs letter from the insurance carrier, they must have one Insurance carrier says they are a 5 or 10 or high not good. 2. what is your OSHA (IR) incidence rate. 3. copy of your written safety program current.

OJT is widely used because it allows the worker to produce during the training period. However, what are the three things the training manager must ensure?

1. Ensure enough time to train the worker 2. Ensure that the training is understood and practiced 3. Ensure to provide a lesson plan including, JHA and JSA

What are the two distinct areas that hazard analysis is concerned with?

1. Hazards 2. Risks

It is important to analyze the problems and assess training needs before making decisions about solutions. Job aids may be all that is required or, may be needed to supplement the training materials. List three examples of job aids.

1. Inspection checklist 2. Trobleshooting flowcharts 3. Computerized Maintenance Cards

When determining the priority order to assign to various process elements with regards to performing the process hazard analysis, what are four areas that one might want to evaluate?

1. Number of potentially affected employees, 2. Age of the process 3. Operating history of the process+ 4. Extent of the process hazards

A variation OJT is known as job instruction training (JIT) also referred to as the four-point method. What are the four points in JIT?

1. Prepare the worker 2. Present the operation 3. Try out performance 4. Follow-up

The training that employees receive relative to the hazards of the chemicals used in the process is only part of the training that the PSM standard requires. What are three other areas where training is mandatory?

1. The application of this provision (to whom the training applies 2. OSHA's approach (including the amount and method of training, and the content of the training program. 3. Grandfathering of training (the recognition of training received by employees prior to promulgation of this standard).

The employer must document that each employee involved in operating a process has received and understood the training required by the PSM standard. What three items does OSHA insist be included in this documentation?

1. identify the employee 2. date of the training 3. signature of the person doing the training

Employers are required to compile written process safety information before conducting mandatory Process Hazard Analyses. The compilation of data is necessary so that they can first identify and then understand the hazards. What are the three main categories of information that are required?

1. identify the employee 2. the data of the training 3. signature of the person

PSM applies to

A process which involves a chemical at or above the specified threshold quantities listed in Appendix A of the Standard.

PSM applies to

A process which involves a flammable liquid or gas (as defined in 1910.1200(c) on site in one location, in a quantity of 10,000 pounds.

Does the PSM standard mandate that the employer document the resolutions and corrective actions that result from the required accident investigations?

A system must be established to promptly address and resolve the incident report findings and recommendations. Resolutions and corrective actions must be documented and report reviewed by all affected personal whose job tasks are relevant to the incident findings (including contract employees when applicable). The employer must retain these incident investigation reports for at least five years.

With regards to obtaining information on the equipment used in the process, list three sources from which you could obtain reliable data.

ASTM - American Society Test & Materials ANSI - American National Standard Institute NFPA - National Fire Protection Association

How would you determine if the chemicals used in processes at your facility were governed by the OSHA PSM Standard?

Appendix A if the chemical is listed match the quantities in hand, when so than the chemical would be governed.

A business That falls under the requirements of OSHA's PSM Standard has certain responsibilities to contractor employees. What type of contractor employee are they relative to?

Applies to contractors performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process. It does not apply to contractors providing incidental services which do not influence process safety, such as janitorial work, food and drink services, laundry, delivery or other supply services.

Contrast and compare a block flow diagram with a process flow diagram.

Block flow diagram: simplified diagram Process flow diagram: more complex

When should an employer consider using the "Checklist" method for a process hazard analysis and when should they not use it?

Checklist should only be used by someone with great knowledge and experience and the process has been operated safely for many years subjected to periodic safely inspections and audits.

Understand the EPA's definition of a Worst-case Release Scenario and what is meant by both active and passive mitigation systems and which are applicable to the worst-case release scenario.

Define the worst-case release as the instantaneous loss of all of the regulated substance in a process, with failure of all mitigation systems (active and passive). EPA considered defining worst case as the instantaneous loss of the regulated substance form the largest containment vessel or pipeline on-site.

Know how legitimate confidential business information is treated under CAA section 114(c) when developing a RMPs.

EPA also believes that the RMPs should not include information that facilities can legitimately claim as confidential business information under CAA section 114(c). The RMP should provide local and state agencies and the public with sufficient information to determine if additional information is needed.

Low or mid-literacy may result in workers having trouble understanding large amounts of information that is presented in complex textbooks, manuals, and lectures. This must be taken into consideration when designing and delivering safety and health training programs. How might a low-level of literacy among process safety employees affect the employer's ability to comply with the PSM standard?

Employees who have low ability of literacy are incapable of understanding safe practices in a hazardous situation. An amount of reading is required to understand the hazardous material and safety instruction. Material Safety Data Sheets are among a few that would require reading and understanding. Others would be safety instruction that would need to be carried out by instruction manuals or even non-verbal communication device like computers.

What does the abbreviation ECP stand for and briefly describe what it is.

Exposure Control Plan - is provided to eliminate or minimize occupational exposure to bloodborne pathogens in accordance with OSHA standard 29 CFR 1910.1300, "occupational exposure to bloodborne pathogens".

Describe what is meant by "exposure" relative to hazard assessment and how it might affect the probability of occurrence for a given hazard.

Exposure occurs through contact with a chemical. Such contact can occur by inhaling air, drinking water, eating food, or touching a variety of products that contain the chemical. The concentration of the chemical and the extent of the contact are important components of exposure assessment.

True or False: If either of the two properties of a hazard has no value, the hazard is intrinsically safe or is simply not a hazard.

False, cause the combination of both could create a risk.

What must an employer do when existing equipment was designed and constructed in accordance with codes, standards, or practices that are no longer in general use in order to meet the intent of the PSM?

For existing equipment designed and constructed in accordance with codes, standards, or practices that are no longer in general use, the employer shall determine and document that the equipment is designed, maintained, inspected, tested, and operating in a safe manner.

When should an employer consider using the "What-If " method for a process hazard analysis?

For relatively uncomplicated processes, the process is reviewed from raw material to product

What method did OSHA specify for employers to use to ensure that the employees understood the training they were given

Grandfathering method an employer may certify in writing that the employee has the required knowledge, skills, and abilities to safely carry out the duties and responsibility as specified in the operating procedures

What are the activities for which an employer is required to implement safe work practice.

Lock Out, Tag Out, confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. These safe work practices shall apply to employees and contractor employees.

What would the EPA call a release that occurred, but did not affect the public or the environment because of favorable weather conditions at the time of the release to be?

Near miss investigation of such incidents may provide facilities with important information on problems that should be addressed before a significant accidental release occurs. EPA considers this incident a significant accidental release and, therefore, it need to be investigated.

What would the EPA call a mishap that did not result in a release because of employee actions or luck?

Near miss, EPA is considering whether facilities should be required to investigate near misses and on how near miss should be defined.

Are employers forbidden by OSHA to hire contractors whose safety records are less than perfect?

No, you can hire a less and perfect contractor. However the employer is completely responsible for the action the contractor has made. Therefore the use of proper written safety program (current) is provided for employer. Also an incident rate from OSHA, as well as EMR letter from insurance carrier stating the contractor is a 5 or 10 but not higher.

What is a Hazard and Operability Study (a.k.a. Operating and Support Hazard Analysis)?

O&SHA is an analysis technique for identifying hazards in system operational tasks, along with the hazard causal factors, effects, risk, and mitigating methods. The techniques is also specifically assessing the safety of operations by integrally evaluating operational procedures, the system design, and the human system integration interface.

In order to fully understand the safety and health hazards of the chemicals they work with, employees are to receive training that is conducted in compliance with.

OSHA Hazard CFR1910.1200 paragraph H (IME)

Where do the hazards delineated in a Preliminary Hazard Analysis come from?

OSHA PSM standard, process hazardous analysis is equated with a hazard and operability study (HAZOP)

What is the most typical type of citation that one will receive for a violation of the OSHA PSM Standard?

OSHA has five types of violation that implicates the hazardous conditions that could either inflect serious physical injuries or cause death to employee or employees. These serious violations are Willful, Serious, Other than Serious, Repeated, De Minimus and Failure to abate. Those violation conditions listed above either knew or knows about from the employer.

What is OSHA's position relative to the type of analysis employers must use to complete the process safety hazard analysis?

OSHA instructs the use of preliminary hazard analysis to assist an employer in determining which process should be of the highest priority for hazard analysis resulting in the greatest improvement in safety at the facility occurring first.

How much detail is required, or how much information should one compile in preparation for conducting the process hazard analysis?

OSHA requires that employers determine & document the priority order for conducting process hazard analysis based on such considerations as the extent of the process hazard, number of potentially affected employers, age of the process, and operating history of the process.

When compiling process safety information, what must an employer do when the process technology requires a design that departs from the applicable codes and standards?

The employer must document which codes and standards were used and that the design and construction along with the testing, inspection and operation are still suitable for the intended use. Where the process technology requires a design which departs from the applicable codes and standards, the employer must document that the design and construction is suitable for the intended purpose.

When an employer documents PSM training, what are the three items that OSHA requires to be contained in the documentation?

The employer shall prepare a record which contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training.

Understand the relationship between the Clean Air Act (CAA), the PSM Standard, and the RMP relative to facilities that have more than the threshold quantity of a regulated substance based on the final list promulgated by EPA.

The list is composed of three categories: A list of 77 toxic substances, a list of 63 flammable substances, and explosive substances with a mass explosion hazaard as listed by the United States Department of Transportation (DOT). Threshold quantities are establisted for toxic substances ranging from 500 to 20,000 pounds. For all listed flammable substances the threshold quantity is established at 10,000 pounds. For explosive substances the threshold quantity is established at 5,000 pounds.

What is the purpose of compiling information concerning process chemicals, technology, and equipment?

This function as a safety measure for all employees working under a process chemicals, technology, and equipment for their safety system or functions. The operation procedures information compiled should be readily accessible to employees who work in or maintain a process.

If you are the contractor employer, do you still have to fill out the OSHA 300 log even though the host employer is required by OSHA to maintain a log on your employees? Please explain your answer.

Yes, as a contractor employer it will be my responsibility for recording the injury or illness, according to OSHA 29 CFR 1910.31 (b) (3)

Using the elements of practice and repetition, this method of instruction is valuable for developing worker skill in fundamental tasks and for performing under pressure. Workers required to perform in crisis situations should be trained under conditions that resemble the crisis as closely as possible. The trainer/employer should therefore consider using the ____________ method of training.

individual

Normally unoccupied remote facility:

means a facility which is operated, maintained or serviced by employee who visits the facility only periodically to check its operation and to perform necessary operating or maintenance tasks. No employees are permanently stationed at the facility. Facilities meeting this definition are not contiguous with, and must be geographically remote from all other buildings, processes or persons.

Catastrophic release:

means a major uncontrolled emission, fire, or explosion, involving one or more highly hazardous chemicals, that presents serious danger to employees in the workplace.

Replacement in kind:

means a replacement which satisfies the design specification.

Atmospheric tank:

means a storage tank which as been designed to operate at pressures from atmospheric through 0.5 p.s.i.g. (pounds per square inch gauge, 3.45 kPa).

Highly hazardous chemical:

means a substance possessing toxic, reactive, flammable, or explosive properties and specified by paragraph (a) (1) of this section.

Boiling point:

means the boiling point of a liquid at a pressure of 14.7 p.s.i.a. (pounds per square inch absolute). For the purpose of this section, where an accurate boiling point is unavailable for the material in question, or for mixtures which do not have a constant boiling point, the 10 percent point of a distillation performed in according with the Standard Method of Test for Distillation of Petroleum Products, ASTM D-86-62, may be used as the boiling point of the liquid.

HAZCOM standard

requires each company to obtain information (MSDS) for all the hazardous chemicals on the promises. Also, labels written HAZCOM, inventory and training are required.

PSM does not apply to

retail facilities,oil or gas well drilling or servicing operations or, normally unoccupied remote facilities.

A hazard may be defined as _______, while risk is _______.

source of potential damage, probability that a person will be harmed.

Are employers allowed to keep training records on computer if they so desire? ___________

yes

OSHA's PSM requires emergency planning and response. What are the two sections of the CFR that govern these activities?

• 29 CFR 1910.38 • 29 CFR 1910.120 (a), (p) and (q)

What types of incidents regarding covered processes must be investigated and how much time does the employer have in which to initiate the investigation?

• Catastrophic release of highly hazardous chemical in the workplace • An incident investigation shall be initiated as promptly as possible, but not later than 48 hours following the incident.

What are the five items that OSHA requires to be included in the incident investigation report?

• Date of incident • Date investigation began • A description of the incident • The factors that contributed to the incident • Any recommendations resulting from the investigation

Under what conditions does OSHA require a pre-startup safety review?

• New facilities and for modified facilities when the modification is significant enough to require a change in the process safety information.

What are the five things that an employer must include in the documentation for each inspection or test performed on process equipment?

• The documentation shall identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test.

The areas that the CAA specified for coverage included:

• Written safety information - workplace chemical and process hazards, equipment, & technology • Hazard assessment - potential for catastrophic consequences (range of release, exposure group, etc. • Consultation with employees on development of the hazard analysis and associated plans. This also included access to the developed plans • Employers had to do something about the findings from the hazard assessment - they couldn't just put it on a shelf to collect dust • Employers had to periodically review (audit & update) the original assessment • Employers had to develop and implement written operating procedures • Employers had to make the written operational and safety information available to employees and train them • Employers were required to ensure that contractors and contract employees are given the information and trained on it. NOTE: It is of interest that this is the only place in OSHA that this requirement is actually written. • Emergency response training for both the employees and contractors • QA Programs • Maintenance Programs • Pre-startup Safety reviews • Change Management • Incident investigation

What are four things that a process owner intent on hiring a contractor with a less-than-perfect safety record, should do to help prevent safety problems on the job?

• scope of the safety and what needs to be done • put the safety requirement in a contract, written safety plan • safety orientation • safety record keeping: every day or week, month reports and what had happened • dollar values taken for fines for rewards for compliance