USL Continual Improvement Assesment

• Audit Title

• Document No.

• Client / Site

• Conducted on

  Date

• Prepared by

• Location
  Address

• Personnel

General Facility

• Is the facility properly secured when unoccupied?

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• Does the facility utilize adequate lighting to deter vandalism, and to illuminate loading and unloading areas.

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• Does the facility adequately control contractor and visitor access through signage, monitored entry, or visitor/contractor logs?

• Are work areas, ground and secondary containment clean, orderly and free of product or spills?

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• Section Notes

• Points Earned for Section:

Spill PreventionControl and Countermeasures (SPCC) and Emergency Response (ER)

• Has the facility specific Emergency Response (ER) plan been updated in the past 12 months?

• Has the facility evaluated their oil based material storage and inventory and do they have an SPCC plan if required?

• Does the facility have an up to date SPCC PLan?

• Is the SPCC self certified or PE certified according to regulatory requirement ts?

• Do facility personnel attend and document the required annual SPCC training?

• Have all facility employees received annual ( site specific) emergency response plan training?

• Has a emergency response drill been conducted and evaluated in the past 12 months?

• Has the Emergency Response Plan been submitted to the local fire department on a annual basis ( verified by documentation)?

• Does the facility have appropriate types of emergency response materials in adequate quantities which are staged appropriately at strategic locations within the facility?

• Are eyewash and safety shower stations provided at appropriate locations and are in good working condition?

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• Points Earned for Section:

Fire Safety

• A all fire extinguishers mounted safely, accessible and free from obstacles?

• Does the facility conduct documented monthly inspections of fire fighting and safety equipment?

• Are flammable storage tanks grounded?

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• Points Earned for Section:

Personal Protective Equipment

• Are employees wearing proper PPE for the task and specified by the MSDS?

• Do employees understand and use appropriate eye protection for chemical transfers? ( I.e. googles and face shield or mono goggles)

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• Section Notes:

• Points Earned for Section:

Hazard Information

• Are updated risks assessments available and accessible?

• Are JSA's completed for safety critical tasks?

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• Points Earned for Section

Life Critical Safety

• Have personnel been informed of the existence of confined spaces through warning systems?

• Is a confined space entry program that includes a permitting system in place?

• Does this facility have a site specific lockout/ragout (control of hazardous energy) program implemented and is it effective?

• Are hot work permits issued by authorized personnel for cutting, welding, and other applicable tasks that occur outside of delegated areas?

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• Points Earned for Section:

Electrical Safety

• Is electrical equipment appropriate for the area? (e.g. Proper electrical classification where flammable chemicals are used)

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• Is Ground Fault Circuit Interrupter protection provided at electrical outlets ( or on associated panels) in outdoor wet areas and within six feet of indoor wet areas such as sinks, safety showers, etc.

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• Are electrical systems in good condition (e.g. Wiring, outlets, electric panels closed and clear of possible obstructions, etc.)

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• Are flexible cords (e.g. Extension cords) restricted from use to operate electrical equipment in a permanent installation (temporary equals 3 months max) ?

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• Section Notes:

• Points Earned for Section:

Lifting and Hoisting Equipment

• Do personnel perform documented inspections of powered industrial trucks such as fork trucks, tractors, platform lift trucks, and/or motorized hand trucks before each shift?

• Are operators certified for forklift option every third year?

• Are slings, wire ropes, and other lifting equipment properly inspected before use, and are they certified according to regulatory requirements and the Lifting and Rigging Enterprise Operational Control?

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• Section Notes:

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Inspections, Training, Safety Meetings, and Reporting

• Do facility personnel attend documented Monthly or periodic Safety Meetings?

• Do facility personnel conduct and document periodic Facility Inspections?

• Do Short Service employees receive New Employee Orientation and assigned mentor within 30 days of employment?

• Have Short Service employees completed competency assessments (i.e. completion of Roadmap book)

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• Points Earned for Section.

Material Storage and Handling

• If the facility has underground storage tanks (USTs) containing hazardous materials, does the facility implement a UST management plan? Are the USTs continuously monitored?

• For above ground storage tanks (ASTs) ( >660 gallons) containing hazardous materials as defined by 1910.1200 must be periodically tested based on a generally accepted good engineering practice(e.g. hydrostatic, ultrasonic) and industry standard (i.e. API, STI).

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• Ensure that all chemicals with a flashpoint below 200°F in tanks greater than 60 gallons are stored in steel, unless it's a small location (total storage volume <3000 gallons) or wellhead with tanks smaller than 660 gallons. Review Chemical Management Enterprise Operational Control for requirements.

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• Are all product containers stored in an area(s) with an impermeable surface?

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• Are containers stored in an area(s) with secondary containment? See Chemical Management Enterprise Operational Control for specific secondary containment requirements.

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• Are steel drum containers stacked no more than 3 high?

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• Are poly drum containers stacked no more than 2 high?

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• Are all containers properly labeled?

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• Are containers storing products in good condition (I.e. no severe damage or corrosion)

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• Section Notes:

• Points Earned for Section:

Chemical Transfer

• Are containers bonded during the transfer of flammable materials from one container to another, and grounded when appropriate?

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• Are chemical contaminated rags stored in covered containers?

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• Is the manifold and/or bulk tank line capped at the completion of the loading process?

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• Are all loading manifolds clearly identified to prevent mixing of chemicals?

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• Is at least one BPC employee present during the loading/unloading of chemical from/to bulk transports at BPC locations and elsewhere as required by customers?

• Section Notes:

• Points Earned for Section

Air Emissions

• Have facility personnel evaluated local regulations and on-site activities to determine if an air emissions permit / license or exemption is required? (If facility has not been evaluated for air emissions, information must be gathered during visit to complete an evaluation for corrective action)

• Has the facility documented insignificant activities (exempt or de minimis sources or sources below emission thresholds for registration?

• For any air permits, (e.g. construction or operating), are all facility activities and equipment included and accurately represented?

• Are compliance tasks completed for each each permit condition, including monitoring, inspection, recordkeeping and reporting? (e.g., maintain a 12 month rolling log for usage, hours of operation, emission control devices, emission monitoring, etc.)

• Are product change-outs being evaluated and determined when agency notification is required or permit modifications?

• Does the facility track and document all emission data required by the permit/license or exemption?

• Section Notes:

• Points Earned for Section

Storm Water Management

• If the facility does not require a storm water plan ( provide 2 for each answer and document in section notes)

• Does the facility have a stormwater permit if required or no exposure certification?

• Has the facility specific storm water pollution prevention plan ( I.e. SWPPP) been reviewed and updated ( if necessary)in the past year? ( Iff facility does not have a SWPPP, information must be bathed during visit to complete plan for corrective action

• Does the facility have all required monitoring records? (e.g. quarterly visual monitoring, effleunt testing, annual compliance monitoring).

• Has visual monitoring and discharges from containment areas been documented if required by the permit?

• Do facility personnel attend and document the required Stormwater training?

• Is housekeeping adequate enough to meet the Best Management Practices (BMP's)

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• SectionNotes:

• Points Earned for Section:

Waste water Disharges

• If stormwater or wastewater is recycled as flush water, is a current client approval letter on file? See Waste Management and Minimization EOC.

• If wastewater is discharged to local wastewater treatment authority, has the facility properly notified and/or registered with this authority?

• Does the facility perform periodic monitoring/testing of the wastewater discharge after treatment?

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• Points Earned for Section:

Water Quality

• Are annual visual inspections for sumps being met according to the water quality EOC?

• Is Integrity Testing for sumps being met every 5 years according to the Water Quality EOC?

• Section notes

• Points earned for section

Waste disposal

• Does the facility maintain a designated / posted waste storage area?

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• Are periodic, documented inspections of the waste storage area conducted?

• Do personnel working with or maintaining hazardous waste storage areas receive annual training?

• Does the site have a waste minimization plan which has been updated annually?

• Are waste profiles / characterizations available for each waste disposed of reviewed/updated annually?

• Are generator's copies of manifests / transport documents on file for at least the past 5 years?

• Have third party disposal sites used by the facility been audited?

• Are waste stored on site appropriately characterized using analytical, process knowledge or MSDS methods?

• Are hazardous waste containers meeting proper storage practices (50 feet from fenceline and labeled, secondary containment)?

• Section notes:

• Points earned for section

Empty Containers

• Are small containers (< 5 gallons) free of residue before being placed in the dumpster or refuse bin?

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• Are empty drums properly stored?

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• Have drum reconditioners/disposal vendors been audited?

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Acrolein Safety

• If Acrolein is NOT stored ( provide highest score and document no storage in notes)

• Is there available a written Acrolein Safety Management Plan (ASMP)?

• Does the facility currently store more than 5000 lbs of Acrolein onsite? If so, does the facility have an RMP?

• Has the ASMP been implemented and communicated to employees?

• Are all employees being properly trained?

• Are full faced respirators available and assigned to individual employees?

• Are proper storage practices occuring on site?

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• Are slings, wire ropes, and other lifting equipment properly inspected before use, and are they certified according to regulatory requirements and the Lifting and Rigging Enterprise Operational Control? (marked with name of manufacturer, safe working load and grade of chain).

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• Are proper lifting practies occuring while using and moving cylinders? For cylinders - attach one lifting chain / strap to each handle of the conttainer. For skids - use lifting bracket under skid with forklift (no chains).

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• Is there adequate emergency response equipment to meet an emergency situation? (enough water and soda ash)

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• Section notes:

• Points earned for section

Environmental Reporting

• Does the facility meet the requirements to submit annual EPCRA Tier II Reports to the LEPC, SERC and local fire department? If so was a Tier II completed and submitted for current reporting year?

• Are copies of the Tier II Report available for the last 3 years?

• Does the facility meet the requirements to report under the Toxic Release Inventory (TRI)? Typically includes the use of more than 10,000 lbs of a listed chemical per year and facility has more than 10 full-time employees. If so, has the report been completed and is documentation available to show support determination and reported quantities?

• Does the facility submit an Annual Hazardous Waste Summary Report each year to the regulatory agency, if required?This is a regulatory requirement for Large Quantity Generators (LQG). Individual States may impose additional reporting requirements.

• Are Agency Inspections, Spills and Notice of Violations recorded in Odyssey? - For any deficiences and violations have corrective actions been addressed?

• Section notes:

• Points earned for section

Driver and Vehicle Safety

• Are drivers & professional drivers assessed "in-vehicle" annually (or every 5 years if having 3 or more years seniority).

• Are walk-around "Circle for Safety" inspections conducted prior to operating any vehicle on company business?

• Are packages of dangerous goods secured in vehicles so they cannot move in transit?

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• Is a preventive maintenance plan in place and followed for any vehicle used on company business?

• Are contractor drivers and transportation companies being evaluated and managed to BHI requirements?

• Section notes:

• Points earned for section

Assessment scoring

• Assessment total points

• Manager signature

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• Assessor signature

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