Volume 4 :: Issue 1
OSHA Total incident rate (TIR)
In This Issue:
OSHA TOTAL
INCIDENT RATE (tir)
essential physical
functions
ERI Knowledge base
Introducing...
KEY dates
ghg MAJOR source PERMITTING REQUIREMENTS
psm: mECHANICAL
INTEGRITY TESTING AND
INSPECTIONS
BEST SAFETY PRACTICE:
Easy rake silage facer
The ERI Exchange is an
informational exchange of ideas
regarding ethanol, grain, and
biodiesel industry safety and
environmental practices and ERI
Solutions Inc.
ERI Solutions Inc.
125 N. First Street
Colwich, KS 67030
OSHA TIR = Total Incident Rate (Number of Recordable Incidents per 200,000
hours worked)
Example: A facility with 50 employees having one recordable accident during the
year will have an incident rate of 2. A facility with 25 employees having one recordable accident during the year will have an incident rate of 4.
T
he over-80 ethanol plants which are ERI Safety Group members account for
more than 40% of the ethanol plants in the US. Since our group was formed in
2003, ERI has been tracking OSHA incident rates and comparing them with industry rates. Average rates for the ERI group have steadily been improving year after
year, starting with rates near 7 and progressing to rates near 4. Unfortunately, the
Bureau of Labor Statistics stopped collecting and reporting ethanol plant safety statistics in 2008, so comparisons with the industry have not been possible since then.
However, extrapolations from worker compensation statistics verify that our group
remains significantly better than the balance of the industry.
This is good, but how good is good? While getting better year after year is definitely
the right path, an average incident rate of 4 still leaves plenty of room for improvement. How do we know this? If you look at incident rates of refineries and power
stations, industries that are inherently more hazardous than ethanol plants, incident
rates are now consistenly near 1.5. While it’s true that these industries have had
over 100 years to practice getting better, it’s also true that most have unfortunately
learned to get better “by accident”—a method we’d like to avoid. However, knowing
these industries have been able to accomplish these low incident rates, we certainly
know it’s possible for our industry to get there. We don’t want to get there by trial
and error, but rather by design—in part by learning from what others have learned.
Another large part in getting there is by proactively forcing a change to a total safety
culture rather than simply allowing safety to slowly happen over time. The latter
method takes a generation (20-25 years) for change to happen, whereas the former
takes only 5-10 years to effect major change.
Several plants in the ERI Safety Group have logged an enviable “zero” incident rate
several years in a row. While the true goal is always “zero”, a realistic goal for the
group as a whole to achieve is an average TIR of 1.5. In practical terms, this means
we as a group (4000 employees working 8 million hours per year) need to reduce
the number of accidents we have during the year from 175 to 65.
1
ESSENTIAL PHYSICAL FUNCTIONS
ployee, it is the employer’s duty to have eficial for use with “Return-To-Work” proan adequate screening system in place grams, which provide more detailed guidto ensure he/she is “This may result in the injured em- ance to physicians
capable of perform- ployee returning to work within a evaluating the deing the required dugree of work fitness,
more appropriate timeframe, resultties. This will help
rather than relying
ing in reduced worker compensa- on more subjective
eliminate or reduce
MSD injuries due to tion expenses.”
measures. This may
inadequate physical fitness or condition- result in the injured employee returning
ing.
to work within a more appropriate timeframe, resulting in reduced worker comTo meet these obligations and also com- pensation expenses.
ply with the Americans with Disabilities
Act of 1990 (ADA), we must establish In the future, think of essential physical
A review of the “It is the employer’s duty to exam- and document the functions documentation as an extenERI User Group’s
“essential physical sion to the baseline audiometric testing
ine, judge, and test the potential emWorkers’ Compenfunctions” for each of an employee’s hearing to ensure he/
sation Loss Analy- ployee to ensure he/she is capable of job
classification. she does not have a hearing loss, or resis, 11/01/06 to performing the required duties.”
Essential physical spiratory fit testing to ensure he/she is
12/31/11, reveals that 67% of claims are functions consist of a very detailed list of physically fit to wear a respirator. It’s beta result of MSDs which include strains physical requirements for a job classifica- ter for everyone, especially employees, to
or sprains to the back, neck, shoulders, tion as opposed to general statements ensure they are physically fit to perform
arms, wrists, hands, and knees. These of abilities, and typically are validated the job for which they are being hired.
statistics have implications for both the through a process involving input by sevnew-hire screening process as well as the eral incumbents and incumbent super- Essential Physical Function forms are
physical conditioning of existing employ- visors. This documentation should then available on the ERI Knowledge Base.
ees. If your physical screening process is be used by physicians during the pre- For additional information or questions
inadequate, the new employee may not employment physical exam to determine regarding the process of establishing an
be able to meet the true physical require- if the candidate can meet the minimum Essential Physical Functions program;
ments of the job and may be more at risk physical requirements of the job. This contact ERI Solutions at 316-927-4298.
for MSDs. In fairness to the potential em- same documentation can also be benWhat do “Essential Physical Functions”
have to do with the job? The Surgeon
General website reports “Two thirds of
adults are overweight or obese and physically unfit.” The Bureau of Labor Statistics (BLS) reported “that approximately
50% of worker compensation costs
are due to musculoskeletal disorders
(MSDs).” These two reports go hand in
hand; many medical studies have listed
unsafe work behaviors and poor physical
fitness as contributing factors to the majority of MSDs.
The ERI Knowledge Base Website
The ERI Knowledge Base contains ERI’s complete library of
safety manuals in a searchable database, customized for your
operations and for your state. Currently there are complete
safety programs for the federal OSHA-regulated states, six
different safety programs for individual state OSHA-regulated
states (MN, MI, KY, TN, IL, CA), and an all-new safety program
for grain elevators. The Knowledge Base is continuously updated in real time, so you don’t have to wonder if there has
been a revision. The ERI Knowledge Base is our response to
member requests for a fast and easy way to access safety materials as well as the entire collection of published accident
alerts, in a searchable and downloadable format.
Currently there are nearly 7,000 documents in the Knowledge
Base, and the list will continue to grow with new publications
added each day, including “White Paper” publications, videos,
posters and more. Every Safety Group Member plant has access to this data base, so please take some time and explore
this very resourceful tool.
2
INTRODUCING
INTRODUCING INTRODUCING
We are pleased to announce several additions to the ERI Solutions team over the last few months!
Jim Lane –
PSM Program
Specialist
Jim brings
24 years of
engineering
experience
to ERI Solutions, including
over 7 years
in an ethanol plant. Jim has a BS
in Chemical Engineering from the
South Dakota School of Mines and
Technology. His industry experience
also includes work for a contractor to
the US Department of Energy, natural
gas liquids separation processes,
and ammonia manufacturing in addition to the ethanol plant experience.
Jim’s past job duties have included
process engineering, Process Safety
Management (PSM), environmental and regulatory reporting and
policy development, safety, hazardous waste operations, and nuclear
materials and wastes. He has been
involved with PSM processes for over
14 years including leading and participating in Process Hazard Analyses
(PHAs). Jim is married with 2 married
daughters and 2 grandchildren.
Gary Lium PSM Coordinator
Gary brings 25
years of experience to his current position as
PSM Coordinator.
He has several
certifications:
FLIR System Certified Infrared Thermographer Level 1, Emerson Process
Management Category 1 ISO Vibration Analyst, Technical Associates
Certified Vibration Analyst 1, SDT
Level 1 Certified Airborne Ultrasound
Inspector, and ATS Level 1 UT & UTT
Certified Training. Gary has two kids
and a dog and in his spare time he
enjoys spending time with his kids
and participating in competitive
shooting events and hunting.
Andrea Foglesong –
Managing Director
of Environmental
Affairs
Andrea has been
working as consultant in the ethanol
industry since
2002, providing
guidance and technical support to customers on an array
of environmental-related topics. Areas of
focus include air permitting, water permitting, hazardous waste management,
annual reports and audits, to name a
few. Andrea graduated from Colorado
State University in Fort Collins, Colorado
with a degree in Environmental Health
with an emphasis in Industrial Hygiene.
The allure of Fort Collins has kept her
there, where she helped start the Fort
Collins office in 2005. When not at work,
Andrea and her husband of nearly 10
years spend time chasing and caring for
their three young children.
Adrien Kogut –
Environmental Services Coordinator
Adrien’s position at
ERI provides technical and project management support to
the Environmental
Affairs Team from
ERI’s satellite office in Fort Collins, Colorado. With a degree in Technical Journalism from Colorado State University,
Adrien assists with the development of
conference/meeting materials, marketing documents, and ERI publications
associated with environmental products
and services. Adrien’s technical strength
lies in storm water, Spill Prevention
Controls and Countermeasures/Facility
Response Plans, carbon modeling using
the ICM/Econergy Model, and preparation of other environmental permits,
plans, and approvals. Adrien, a Colorado
native, enjoys reading, cooking, and
spending time with her husband and
chocolate lab. Adrien is excited to be
expanding her family; her first child is
due in June.
Lauren Taylor –
Environmental
Compliance
Specialist
As an Environmental
Compliance Specialist for ERI, Lauren
and is responsible for assisting
facilities with their
environmental needs. Lauren graduated
from Colorado State University with a
B.S. in Zoology in 2008 and has over
five years of experience in the ethanol
industry. She has worked on a variety
of permits related to air and water in a
number of states, as well as performed
audits to ensure facility compliance with
regulatory requirements. She also aids
in the preparation of multiple annual
reports and has completed numerous
carbon models and life-cycle assessments necessary for facilities to ship
their ethanol to Europe and California.
In her spare time, Lauren enjoys painting, boating, and spending time with her
husband and puppy.
April Lockwood Administrative
Assistant
April is the Administrative Assistant for
ERI’s Environmental
Affairs team in the
satellite office in Fort
Collins, CO. She
assists in preparation of permit applications, Life-Cycle Assessment Reports,
and provides overall support to the team
as needed – in addition to her many
other office tasks and responsibilities.
April is married to her husband, Ryan, of
9 years and they have one son, Connor,
10 months, two cats, and one black lab
named Jager. Together they enjoy hiking,
running, and traveling when they can.
(“Introducing” continued on page 4)
3
ENVIRONMENTAL KEY DATES
INTRODUCING
(continued)
Bill Roddy Director of
Sustainability and
International
Projects
Bill brings 36 years
of experience from
the private and
public sectors with
ERI Solutions, as the Director of Environmental Sustainability and International
Projects. Bill has extensive experience
in multimedia environmental compliance auditing, permitting, stack testing,
carbon modeling, odor control/management, due diligence (acquisitions and divestments), regulatory analysis and NOV
settlements with interface involving EPA
and state regulators. Bill’s previous professional experience includes positions
as Director of Environmental Compliance
and Director of Air Quality Management
for Koch Industries, Inc. and Corporate
Manager of Environmental Affairs at
ICM, Inc. He earned a master’s degree
in engineering from California State
University, and his bachelor’s degree in
aeronautical engineering comes from
California Polytechnic University. Bill
enjoys spending his spare time with his
wife, two daughters, and three granddaughters.
From an environmental standpoint, the first quarter of the year is typically spent
gearing up for (and even submitting some) annual reports. The following annual
reports are applicable to most ethanol plants:
•
•
•
•
•
•
•
Alcohol Fuel Producer Report – due January 31
Tier II Report – due March 1
Fuel Additive Manufacturer Report – due March 31
EPA Greenhouse Gas Report – due March 31*
TSCA (Form U) Report – due no later than June 30**
TRI (Form R) Report – due July 1
Emissions Inventory/Annual Compliance Certification – State dependent
(check air permit/State Agency Website for due date)
*For reporting year 2011, GHG Reporters only applicable to Subparts A, C, and PP will have
reports due March 31. EPA has deferred Subpart II reports until September 28; subsequent
year’s data will be due on March 31.
**TSCA reports are only due once every five (5) years. The 2010 reporting year was deferred
until between February 1 and June 30, 2012 in order for EPA to finalize reporting requirements in CDX.
SAFETY KEY DATES
• NLRB “Employee Rights” posting date - April 30
• Spring Safety Rankings - April
• Global Harmonization - Office of Management & Budget (OMB) completed
review of the rule Feburary 21. OSHA will likely publish final rule in the next
few months.
GHG Major Source Permitting Requirements
In 2010 EPA finalized the GHG Tailoring Rule, making it mandatory for facilities that emit more than 100,000 tons per year of GHG
emissions to obtain major source permits (PSD for construction of new sources, Title V for operating sources). On July 1, 2011
EPA finalized a deferral of biogenic (fermentation) emissions for a period of three (3) years. As a result, only facilities that have the
potential to emit 100,000 tpy or greater of GHG emissions from combustion will be required to obtain major source permits. Most
States have adopted the rule in line with the federal requirements. Facilities that trigger the requirements of this regulation will
be required to apply for a Title V permit no later than July 1, 2012. Title V permit applications are extremely time consuming; ERI’s
Environmental Team recommends that you contact your environmental consultant to get a determination of applicability as soon
as possible so the application process can be started sooner rather than later. If your facility is interested in a quote from ERI’s
Environmental Team for applicability/Title V application preparation, please contact Adrien Kogut at (316) 927-4261, or via email
at [email protected].
“We now have unshakable conviction that accident causes are manmade and that a manmade problem can be solved by men and women.”
W.H. Cameron
4
Process Safety Management
Mechanical Integrity Testing and Inspections
O
ne of the most daunting tasks within
Process Safety Management (PSM)
seems to be Mechanical Integrity (MI)
testing and inspections. Making this even
more important to most of the members
of the ERI Solutions Safety program is
the fact that their plants are at or nearing their fifth year of operation. That fifth
year seems to be a point of realization
for most facilities that they need to start
taking interest in the condition of their
larger equipment and piping—and for
good reason! The OSHA regulations don’t
necessarily specify that everyone must
follow the API standards; however, they
are the most widely accepted standards
for inspecting tanks, pressure vessels,
and piping. These standards, API 653,
API 510, and API 570 respectively, state
that visual external and thickness testing should be conducted on all PSM covered tanks, pressure vessels, and piping
beginning at that five year mark. Some
members may have other specific regulations that require doing internal tank
inspections at that same five year mark
as well. If you’ve already done your five
year external inspections, it’s a good idea
to start planning for your 10 year internal inspections sooner than later. These
inspections typically take longer and require each vessel or tank to be taken out
of service in most instances. The logistics of notifying your air permit regulators,
drawing your tanks down, finding a home
for the residual contents, degassing the
tank, performing the inspection, and restarting operations can be cumbersome
at best. The good news is ERI can now
help with all these issues. ERI Solutions
currently has a certified API 510 inspector and will soon have all three API certifications in-house and ready to serve
your needs along with certified ultrasonic
thickness testing (UT). We can also assist in helping you plan the internal inspections with the assistance of a third
party cleaning and temporary storage
solution. We are very excited to expand
our PSM offerings and look forward to
working with you! Contact Nathan Vander
Griend at 316.927.4294 or Jay Beckel
at 712.542.0003 to discuss how ERI can
help you stay ahead of the curve with respect to PSM, especially MI testing and
inspections.
Best Safety Practice
Easy Rake Silage Facer
Although an alert has already been sent out about this great device identified by one of our members, we still continue to see
incidents through our Accident Alert system such as broken windshields and even personnel injuries while moving DDG piles in
your storage buildings. We wanted to take this opportunity to share this information again so we can hopefully eliminate these
minor incidents and also prevent anything more serious from happening! You can find more information on the Easy Rake device,
and even see a video of how easy it is to use and the various lengths available at this web site: http://www.easyrakefacer.com/
the-easy-rake/. We know time is tight and it may take a few extra minutes to change out your loader bucket for the Easy Rake, but
remember, prevention is the key to success. If you eliminate the hazard beforehand, you eliminate the injury potential, the repair
costs, the doctor visits, the down time, and retraining efforts that can follow even minor incidents!
If you have Best Practices (Environmental, Health, or Safety related) you would like us to share with the rest of our members,
please don’t hesitate to send them in, and we’ll pass them along via our email alerts, ERI Exchange, or even the ERI Knowledge
Base. You can send Best Practice information directly to Jay Beckel at [email protected].
5