1. Developing a Chemical Risk Management Program
SAND No. SAND No C
Sandia National Laboratories is a multi-program laboratory managed and operated by Sandia Corporation, a wholly owned subsidiary of Lockheed Martin Corporation, for the U.S. Department of Energy's National Nuclear Security Administration under contract DE-AC04- 94AL85000

2. Overview of Presentation
Hierarchy of regulatory controls/industry standards for chemical risk management programs,
Roles in a chemical risk management program,
Purpose of a chemical risk management program,
Elements of a chemical risk management program,
Examples of site assessment checklists.

3. Hierarchy of Controls
International Fertilizer association. Best management practices.

4. Chemical Management Program Organizational Roles
Executive Officer or
President
Senior Manager
Supervisor
e.g. Project manager
Employee
Corporate Safety Officer
and
Corporate Security Officer
Plant Safety and Security Manager
Designated by the functional area
Culture of chemical risk management should exist at all levels of the organization
Top management sets policy, provides resources
Workers must understand and implement
Many organizational interactions are important for an effective chemical risk management program

5. Purpose of a Chemical Risk Management Program
Prevent and/or mitigate release of hazardous substances within the facility and in the nearby community
Protect people
Protect the environment
Prevent theft of chemicals or process information
Prevent chemical exposure to workers
Comply with laws and regulations
Provides for incident management response
Health & Safety Incidents
Fire
Explosion
Chemical release
Evacuation
Remediation
Security Incidents
Theft
Insiders
Former workers
Contractors
Plant sabotage
Demonstrations, protests
Natural disaster
Earthquakes
Hurricane/typhoon
Tsunami

6. Elements of a Chemical Management Program
The written program should include a policy statement endorsed by the plant’s management.
“It is the policy of our company to protect our workers and the public, prevent incidents, protect the environment through integration of environmental stewardship and sustainability throughout the life-cycle of its activities, and ensure regulatory compliance.”
has the responsibility to teach, model and encourage good Chemical Safety and Security practices

7. Elements of a Chemical Risk Management Program
Chemical inventory/Material Accountability
Describe the process for tracking chemical inventory:
“All chemicals will be procured through Corporate Process XXX,
All chemical containers, process units, & piping will be labeled,
All chemical containers/process units will be bar-coded,
All chemicals will have safety data sheets,
Safety data sheets will be accessible to all employees and regulatory authorities,
Chemicals of concern will be secured and access limited, and
Chemical quantities will be tracked from procurement to disposal.”

8. Elements of a Chemical Risk Management Program
Worker health and safety
Describe the process for identifying, evaluating, and controlling worker exposure:
"All chemicals associated with processes will be identified,
Potential worker airborne or dermal exposure to identified chemicals will be evaluated,
All workers exposed to hazardous chemicals will be subject to medical surveillance, and
All documented exposures will be controlled by
Engineering controls, personal protective equipment or administrative controls, in that order.”

9. Elements of a Chemical Risk Management Program
Example of Personal Protective Equipment Assessment Form

10. Elements of a Chemical Risk Management Program
Example of Job Hazard Analysis Form:
Date: ____________
JHA Number: _________
Location of Task:
_______________________________________
Task # 1 Description:
Hazards:
Preventive Measure(s):
Safe Job Procedures:
Retrieved February 27, 2012 from, U.S. Occupational Safety and Health Administration.
Will discuss JHAs in more detail on day 4

11. Elements of a Chemical Risk Management Program
Exercise:
Describe one of your processes
List all chemicals and their hazards,
List all possible ways a worker might be exposed,
List how the exposure will be controlled,
List current procedures to protect the worker

12. Elements of a Chemical Risk Management Program
Process Hazard and Threat Risk Assessment
Describe the process for identifying, evaluating, and controlling chemical hazards from catastrophic incidents and security threats:
“All processes will undergo an initial and periodic hazard analysis to include, identification of process chemicals, process conditions (pressure, temperature), fire, explosive and reactivity hazards, process equipment, and measures to control unplanned releases.”
All changes to process chemicals, processes, equipment, or facility modifications will be subject to evaluation through a management of change procedure.”
Note: Indicate industry codes and standards that will be followed; for example, National Fire Protection Association (NFPA), American Society for Testing and Materials (ASTM)

13. Elements of a Chemical Risk Management Program
Hazard Analysis of Fertilizer Process
Process Flow Diagram

14. Elements of a Chemical Risk Management Program
Hazard and Threat Risk Assessment, continued
Describe the process for identifying, evaluating, and controlling security threats from theft and sabotage:
“All processes will undergo an initial and periodic security vulnerability assessment to include, identification of chemicals of concern and their properties, and measures to control their theft or unplanned release.”
All employees procuring, storing, processing, or disposing of chemicals of concern will be subject to a personnel reliability program.
All chemicals of concern will be managed under a material accountability program which will include access control as well as inventory tracking.“
Computer security

15. Elements of a Chemical Risk Management Program
Training program
Describe the process for developing, auditing, and maintaining a safety and security training program:
“All employees handling or disposing of chemicals will take training in hazard communication and if applicable, respiratory protection, confined space, hazardous waste operations, and emergency response.
All employees procuring, storing, handling or disposing of chemicals of concern will take Security 100 training.”

16. Training Documentation: Sample
Employee name: ___________________________
Department: _________________________
Date: ______
Training Subject: ______________________________
Training Date: ___________
Re-instruction date: _________
Employee Signature: ______________________________
Date Signed: __________
Supervisor’s signature: _____________________________
Date: __________

17. Elements of a Chemical Risk Management Program
Emergency and Incident Management Plan
Pre-emergency planning with outside authorities
Personnel roles, lines of authority, communication
Site security and control
Evacuation routes and procedures
Personnel protective and emergency equipment
Decontamination procedures
Emergency medical treatment and first aid
Emergency response and alerting procedures
Critique of response
Reference: U. S. 29 Code of Federal Regulations, HAZWOPER Standard

18. Elements of a Chemical Risk Management Program
Incident Investigations
All incidents, regardless of severity, must be investigated – and lessons learned used for prevention in the future
Formal investigation of serious incidents
Accountability at all levels
Management, employees, and the investigation team.

19. Elements of a Chemical Risk Management Program
Facility site inspections:
“The chemical shipping and receiving warehouse will be physically inspected quarterly for potential safety hazards and security threats. The inspection will include a walk-down of the warehouse. The following will be reviewed.
Access control,
Chemical inventory records,
Chemical container labels and SDSs,
Chemical storage containment and chemical compatibility,
Emergency procedures and signage,
Worker PPE,
Local exhaust ventilation flow rates and maintenance records,
Training records.”

20. Elements of a Chemical Management Program
Example: Facility Site Inspection

21. Elements of a Chemical Management Program
Example: Facility Site Inspection

22. Elements of a Chemical Risk Management Program
Inspection Checklist:
Date of Inspection:_______
Conducted by:_______
Location (building/process unit):_______
Supervisor:_______
Work Practices
Work conducted under ventilation if airborne hazard
Housekeeping
Work instructions present and used

23. Elements of a Chemical Risk Management Program
Inspection Checklist:
General Facility Condition
Egress/aisles/passageways
Exit signs
Housekeeping
Access controls
Hazardous areas
Chemicals of concern
Hazard Communication
Training documented
SDS available for all chemicals
All chemical containers/tanks/piping labeled
Personal Protective Equipment (PPE)
Available for each exposure identified
Respirators and other PPE stored properly and appropriate for identified hazard

24. Elements of a Chemical Risk Management Program
Inspection Checklist:
Fire Safety
Evacuation maps
Fire pull stations & telephones appropriately placed and posted
Adequate number of fire detection and sprinkler equipment
Fire extinguishers tested, inspected, and appropriate type
Flammable chemical storage: quantities and containment
Process Safety
Mechanical integrity program
Emergency shut-down equipment present and routinely tested
Emergency chemical release equipment available, maintained and posted
Management of change procedures

25. Summary of Presentation
Described the hierarchy of regulatory controls/industry standards for chemical risk management programs,
Identified the roles in a chemical risk management program,
Listed the purpose of a chemical risk management program,
Described the elements of a chemical risk management program,
Provided examples of site assessment checklists.