Supervisors at all work locations are responsible for conducting safety meetings with assigned personnel, including contractors and sub-contractors.
These meetings may be brief 15-20 minute sessions or as long as 30-60 minutes.
Meetings held for training purposes may require additional time.
Meetings shall be held at a frequency established by the Facility or Site but at least monthly.
ALL safety meetings shall be fully documented on a general form. The record shall indicate the time, date, and location of meeting, topics covered, duration, name of instructor (person presenting material), and all personnel attending. Records shall be kept for one year.
In addition to the regular frequency of safety meetings, a safety meeting shall be conducted following an injury or near-miss to warn assigned personnel in an effort to prevent duplicate accidents or injuries.
4 Training
All Employees shall be trained on the guidelines of this procedure initially, prior to work at the Facility or Site. Refresher training is required any time there is a change to the Site’s general rules.
5 Auditing / Inspections
This procedure and policy shall be reviewed annually. Safety meeting records may be reviewed as part of this audit or inspection. The procedure / policy will be updated, as necessary.
Environmental Health and Safety Manual
Policy No. EHS-104 Policy Title: EHS Management of Change Date: 3/30/2006 Revision: 1 Approval: Richard Wolf Table of Contents
1 Purpose and Scope... 2 2 Definitions ... 3 2.1 Change ... 3 2.2 Change Management Record (CMR) ... 3 2.3 Controlled Document ... 3 2.4 Design Review ... 3 2.5 Piping and Instrumentation Diagrams (P&ID) ... 3 2.6 Replacement-in-Kind ... 3 2.7 RFC ... 3 2.8 Temporary Change ... 4 3 Training ... 4 4 Auditing / Inspections ... 4 5 References... 4 6 See Appendix C ... 4
Policy No:EHS-104 EHS Management of Change
1 Purpose and Scope
The purpose of this policy is to introduce the need to manage changes (normal,
permanent, and/or temporary changes) to ensure that environmental, health and safety (EHS) factors has been included as part of the evaluation process. Facility or Site process, equipment, or operational changes must have appropriate review and
authorization prior to implementation to ensure they do not introduce unacceptable risk or hazards. The EHS review portion of the Management of Change process is
implemented at Facilities and Sites so as not to compromise the safety and health of employees (and the community) and to safeguard the surrounding areas from
environmental catastrophes. Management of Change applies to all changes other than those classified as “replacement-in-kind”.
Although maintenance crews typically conduct changes, all personnel must be aware of this policy as changes can be proposed by all employees. Everyone must understand the process and review required to implement a change and understand what
constitutes a change. Many times what may appear to be a minor revision may have much larger implications. It may lead to injuries, accidents, permitting violations, etc., costing companies large sums of money and penalties, not to mention seriously injuring employees if not handled appropriately. Therefore, proper authorization and analysis is needed.
A Facility or Site is required to have an overall Management of Change Procedure.
EHS is only one part of the review and analysis of that process. This policy is not meant to replace any existing Management of Change procedure or process but to re-emphasize the need for review of all changes and to ensure EHS is included as part of that review. Definitions and sample Request Forms are included with this policy as a tool to assist Facilities or Sites with implementing Management of Change procedures.
It is NOT intended as a stand-alone procedure. The EHS Management of Change Policy should be incorporated into the Facility or Site’s overall Management of Change procedures.
Prior to implementing ANY change, the proper analyses must be conducted and approved and the appropriate authorizations, most importantly for this policy EHS authorization, obtained (and all documented). NO CHANGE SHALL BE MADE OR IMPLEMENTED WITHOUT THESE REQUIREMENTS BEING MET.
All Facilities or Sites must have a formal system for identifying, assessing, authorizing, and implementing changes. Management of Change includes documentation and reviews that manage change by addressing the technical
basis of the change, the impact on the environment, safety, and health, modification to operating procedures, necessary time periods involved, authorizations required, training of affected personnel, and updating process
safety information.
Policy No:EHS-104 EHS Management of Change
2 Definitions
2.1 Change
All modifications to Facilities or Sites (buildings, structures, etc.), equipment,
procedures, processes, operations, raw materials, and processing conditions other than “replacement in kind” are considered a change. Changes may include
modifications of operation outside previously approved operating limits (EHS Procedure or Permit), process technology changes (rates, raw material,
experiments, catalysts, etc.), or equipment changes (materials of construction, equipment specifications, piping arrangements, etc.). A list of typical modifications classified as changes (and subject to Management of Change) is included as a reference in the Attachment section of this policy document.
2.2 Change Management Record (CMR)
A form used to document and control the progress of a modification from initiation through completion of the change. This is also referenced as a Change Request Form. Reference the Attachment section for an example form.
2.3 Controlled Document
A document whose contents and distribution are “controlled” through the Management of Change process. Typically these documents include P&ID's, operational procedures, training manuals, permits, etc.
2.4 Design Review
A review conducted by the appropriate personnel authorized to ensure the change has been engineered with the appropriate safety, health, and environmental
considerations. This includes one of the authorizations required to implement a change.
2.5 Piping and Instrumentation Diagrams (P&ID)
Flow charts or system diagrams of operational units that indicate specific information that can be used in training, troubleshooting, and safe operation auditing.
2.6 Replacement-in-Kind
Replacement of an instrument, electrical, piping, equipment, apparatus or other component with an identical part or an equivalent approved and specified by the applicable Engineering standard. It also includes replacement of procedures or processes that are the same (i.e., updates). A list of typical modifications classified as Replacement-in-Kind (and NOT subject to Management of Change) is included as a reference in the Attachment section of this policy document.
2.7 RFC
Request for Change.
Policy No:EHS-104 EHS Management of Change
2.8 Temporary Change
A change in piping or procedures for the purpose of accomplishing something not covered by typical operations will be considered a temporary change. It is
removed as soon as the operation is completed.
3 Training
All S&W Energy employees (at a Facility or Site or Field personnel) shall be trained on the guidelines of this policy.
Facility (or Site) Managers, technical staff, and supervisors must be trained in the
overall Facility or Site Management of Change Procedure or process and in the detailed step-by-step procedures through which change is implemented. Training on this policy is included.
Operators, craftsmen, and other personnel whose job function could involve them in implementing a change must be trained in the Facility or Site Management of Change Procedure or process, which includes this policy.
Initial training is required and refresher training required every three years.
4 Auditing / Inspections
The EHS Management of Change Policy shall be reviewed every three years. The procedure will be updated as necessary.
All documentation (Controlled Documents and Change Request Forms with supplemental information) shall be retained for the duration of the Policy. These records and documents may be reviewed during an audit or inspection.
5 References
A. 29 CFR 1910.119, Process Safety Management
B. Plant Guidelines for Technical Management of Chemical Process Safety
6 See Appendix C
C.1 Examples of Changes and Replacement-in-Kind (2 Pages) C.2 Example Change Request Form (2 Pages)
Environmental Health and Safety Manual
Policy No. EHS-201 Policy Title: OSHA Inspection Process
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf Table of Contents
1 Scope... 2 2 General Guidelines ... 2
Policy No:EHS-201 OSHA Inspection Process
1 Scope
Workplace inspections by OSHA compliance officers may occur at any time. Ensuring full compliance with all applicable standards at all times will minimize any impact that an inspection may have. This policy outlines the basic OSHA inspection process and criteria.
2 General Guidelines
Under laws established by the Department of Labor, OSHA inspections proceed as follows:
1. Inspections can be initiated either by an employee complaint or the Labor Department's initiative.
2. Advance notice of a safety and health inspection without Labor Department authorization is prohibited.
3. Compliance officers must present credentials to the owner, operator, or agent in charge. If the inspection was the result of a complaint, the compliance officer must present a copy of the complaint prior to the conclusion of the inspection.
4. Compliance officers are entitled to enter without unreasonable delay.
5. A compliance officer may gain entrance by presenting credentials to any employee if minimum delay fails to produce the manager in charge.
6. Investigations and inspections must be conducted during regular working hours or at other reasonable times.
7. An authorized employee representative(s), as well as employer representatives, may accompany the compliance officer during the inspection.
8. In the absence of an authorized employee representative, the compliance officer may consult with a reasonable number of employees.
9. The compliance officer checks the place of employment, and all pertinent conditions, structures, machines, apparatus, devices, equipment and materials.
10. The inspection may include possible hazards reported before or during the inspection.
11. A citation will be issued for any violation.
12. If a condition poses imminent danger, the inspector has the authority to request that it be corrected immediately. If the situation is not abated, he/she can secure an injunction through the U.S. District Court, requiring immediate correction or suspension of the work until it is corrected.
13. The citation will detail the violation and the standard, which has been violated. A definite length of time for correction (abatement) will be set.
14. A copy of the citation must be posted at or near the place where the violation occurred. For our purposes, the bulletin board shall be acceptable.
15. An employee or his/her representative may appeal the time given for correction or the penalty and ask for more severe treatment.
Policy No:EHS-201 OSHA Inspection Process
16. The employer may appeal the citation and proposed penalty providing it is appealed within 15 working days of the date of the citation or the right to appeal is lost.
17. When appealed, the “violations” is referred to the Solicitor’s office for review prior to legal action being taken or appeal to the Review Commission (Federal, not State programs).
18. The Review Commission is a three-person body independent of the Labor
Department established for the specific purpose of hearing appeals. It should be noted that if the employee representative feels that the inspector was too easy on the contractor, he/she could also appeal the proposed penalty or the time of the abatement, asking for more severe treatment. If the employer does not file the Appeal within the stipulated fifteen days it loses the right of appeal.
19. When the Review Commission receives the Appeal from the Department of Labor, a notification of receipt will be sent to the Department of Labor, the employer, and the employee representatives setting time and place for hearing and appointing a hearing examiner. At all hearings there will be three parties--The Department of Labor, the employer, and the employee representatives. The hearing examiner will act as presiding officer and will issue a ruling. The examiner has the authority to subpoena records. It is optional at these hearings as to whether or not the parties are represented by legal counsel, and the President will make this decision.
20. The hearing examiner's ruling will be forwarded to the Review Commission which can concur in the rulings, modify, or vacate the rulings and can even increase the proposed penalty, based on the testimony at the hearing.
21. If the company wishes to contest the Review Commission's determination, our legal counsel will take the matter to the U.S. Court of Appeals.
Environmental Health and Safety Manual
Policy No. EHS-202 Policy Title: OSHA Inspection Procedure Date: 3/30/2006 Revision: 1 Approval: Richard Wolf Table of Contents
1 Scope... 2 2 General ... 2 3 Procedure ... 2 3.1 Procedures Prior to Arrival of a Compliance Officer... 2 3.2 Upon Arrival of a Compliance Officer... 3 3.3 At the Opening Conference... 3 3.4 Employee Representation... 4 3.5 Company Records ... 4 3.6 During the Inspection ... 5 3.7 Employee Interviews ... 5 3.8 Closing Conference ... 6 3.9 After the Inspection ... 6 3.10 Upon Receiving a Citation... 6 3.11 Citation Process... 6 4 See Appendix D ... 7
Policy No:EHS-202 OSHA Inspection Procedure
1 Scope
This policy is an outline of the procedures required prior to, during, and after an inspection by OSHA compliance officers.
2 General
The Occupational Safety and Health Act was enacted in 1970, with its purpose being "to assure so far as possible every man and woman in the nation safe and healthful
working conditions and to preserve our human resources." The management of S&W Energy is in complete agreement with the purpose of the act and expects each project to comply with all regulations of the act.
Administration and enforcement of OSHA are vested in the Secretary of Labor and Occupational Safety & Health Review Commission or with the State Labor Department in those states with approved programs. The act is enforced by job site inspections by OSHA Compliance Officers to determine if the regulations provided in the act are being complied with by employers. Violations of the act as determined by the compliance officers (COSH) during their inspections will result in financial penalties, up to
$10,000.00 per violation. S&W Energy accepts the enforcement procedures as provided in the act, but realizes that if certain procedures are followed by the projects before, during, and after the inspections, the results of the inspections will be much more favorable to the Company. For this reason, the following procedures to be followed during an OSHA inspection have been established.