Uninvited Company Now What. Tips for Surviving the Unexpected OSHA PSM and EPA

Transcription

1 Uninvited Cmpany Nw What Tips fr Surviving the Unexpected OSHA PSM and EPA

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8 Uninvited Cmpany Nw What Califrnia Dairies, Inc. Operates 8 cvered prcesses at 6 milk prcessing plants. Artesia, Tiptn C-Gen, Turlck Distributin Prgram 2 Fresn, Ls Bans, Tiptn Prcessing, Turlck Prcessing, Visalia Prgram 3 Multiple cunty jurisdictins PSIG serves as ur cnsultants.

9 Uninvited Cmpany Nw What Since 2009 CDI has been inspected 3 times by Cal-OSHA and nce by EPA. Turlck 2009 Cal-OSHA Visalia 2012 Cal-OSHA Fresn 2014 (EPA) Fresn 2015 Cal-OSHA 2009 was a wake-up call. N PSM Prgram citatins issued since 2009.

10 Uninvited Cmpany Nw What What d yu d when Regulatrs shw up? Usually inspectins are unannunced Cal-OSHA cmes with n warning. EPA prvided ntice. Duratin f their stay can vary. Number f inspectrs can vary. EPA visited with fur participants (plus CUPA). CA-OSHA PSM visited with three participants. Bttm line is this: Thse wh fail t plan, plan t fail.

11 Uninvited Cmpany Nw What 2009 v N plan t receive regulatrs. N plan t cntrl the inspectin. N understanding f the prcess. N cntrl f the prcess. Cmpliance Visit Prcedure Safety Ntificatin Prcedure Inspectin Plan Dcumentatin Management Plan

12 Uninvited Cmpany Nw What Have a plan fr when they arrive: After arriving at the plant, the inspectr is t sign in the visitr s lg and wait fr the apprpriate persnnel t accmpany him/her. Yes yu really can let them wait. (n mre than 1 hur) Have an internal cntact prcedure. VP s, Directr s, Plant Managers, Supervisin, Supprt Staff. Make them feel welcme and treat them with respect. Fllw yur usual Visitr prcess. The inspectr is t review the Visitr Safety and GMP sheet.

13 Uninvited Cmpany Nw What Have a plan t manage the visit. Plant Manager will invite the Maintenance Manager and the Safety Manager int the Cnference t act as a resurce n safety related questins and will be respnsible fr taking ntes during the visit. Have ne persn per inspectr. Ask t see their credentials and make cpy f the infrmatin. If there is any dubt as t the validity f the credentials, call the ffice the persn is frm t verify wh they are. Request what is the reasn fr the visit. Determine what parts f the site they want t see. Determine the dcuments they want t review.

14 Uninvited Cmpany Nw What Plan Yur Rute There is always time t plan the rute. Remember t nly shw them what they ask t see. The fastest rute may nt be the best rute. Dcument what they see.

15 Uninvited Cmpany Nw What Dn t Offer Anything Less is definitely mre. Remember t nly answer the questin they ask. If yu dn t knw, dn t fake it. Say yu dn t knw. Ask fr the requests in writing. (Yes, yu can) Always keep it respectful.

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17 Uninvited Cmpany Nw What Dcuments, Dcuments and mre Dcuments EPA Required t prduce dcumentatin at the time f the inspectin. (They want t see t believe) Recrds requested include: General Dcuments Facility Map, plt plan, rg charts, permits. Full RMP PSI, PHA, SOP, Training, Mechanical Integrity, MOC, PSSR, Emergency Respnse Plan Incidents and Releases (Near misses and crrective actins are seen as gd) HMBP Tw weeks t respnd t the request N news is gd news

18 Uninvited Cmpany Nw What Dcuments, Dcuments and mre Dcuments Cal-OSHA 5-page dcument request. Nt all PSM dcumentatin is requested. If nt requested, dn t send it. Recrds requested include: General Dcuments Facility Map, plt plan, rg charts, permits, Federal Tax I.D., ExMOD PSM dcumentatin is called ut in pieces PSI, SOP, PHA, MI, Ht Wrk Permits, MOC, Emplyee Training/Participatin, Incidents and Releases Other prgrams Cnfined Space, Respiratr, Heat Illness, IIPP, HAZCOM.

19 Uninvited Cmpany Nw What Dcuments, Dcuments and mre Dcuments Cal-OSHA (cntinued) Recrds requested include: Lg 300 (current plus 3 years) Lg 300A (last 4 years) Inspectin and maintenance recrds (12 mnths) Manuals fr Ammnia Detectin Cntractr Training Recrds 56 Punds f paper recrds were shipped Tw weeks t respnd t request (can request mre time) Cal-OSHA has 180 days frm the date f inspectin t issue a citatin.

20 Uninvited Cmpany Nw What Outcmes EPA Citatins They can usually tell yu at the inspectin if they intend t cite. It can take up t 12 mnths t get anything fficial Cal-OSHA Citatins are bund t happen! Recmmend t always file and appeal t preserve yur rights. Use the infrmal cnference t negtiate citatins Citatins stay with yur cmpany Yu can see yur histry at

21 Uninvited Cmpany Nw What Lessns Learned Yu Can never be ready enugh! Knw and walk yur prcess Its called a Prcess fr a reasn. Wrk it. Dcument everything Keep it up t date Get Help PSIG, APSM, ISNetwrd