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
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