U.S. Department of Labor Assistant Secretary for

Occupational Safety and Health Washington, DC. 20210

OSHA Instruction CPL 2-2.50 OCT 17, 1990 Directorate of Technical Support

Subject: Information Dissemination System for Chemical Industry Inspections and Consultative Visits Resulting in Significant Benefits

A. Purpose. This instruction establishes procedures for collecting and disseminating information relative to chemical industry inspections and chemical industry consultative visits which have resulted in significant benefits to employers and their employees.

B. Scope. This instruction applies OSHA-wide.

C. Action. Regional Administrators shall ensure that the policy and procedures established in this instruction are adhered to for all chemical industry inspections and visits.

D. Federal Program Change. This instruction describes a Federal program change which affects State Programs. Each Regional Administrator shall:

1. Ensure that this instruction is promptly forwarded to each State designee, using a format consistent with the Plan Change Two-way Memorandum in Appendix P, OSHA Instruction STP 2.22, CH-3.

2. Explain the content of this instruction to the State designee as requested.

3. Notify the State designees that they are encouraged but not required to participate in this program.

4. Ensure that State designees are asked to acknowledge receipt of this Federal program change in writing to the Regional Administrator as soon as the State's intention is known, but not later than 70 calendar days

OSHA Instruction CPL 2-2.50 OCT 17, 1990 Directorate of Technical Support

after the date of issuance (10 days for mailing and 60 days for response). This acknowledgment must include the State's intention to participate in the information dissemination system for chemical industry inspections and consultative visits resulting in significant benefits to employers and their employees.

5. Establish procedures and coordinate with the State designees for submitting written summaries for selected chemical industry cases to the Regional Administrator for transmission to the Directorate of Technical Support. In the development of brief, written summaries, the States shall follow the procedures in Paragraphs F.1.a.(1) through (4) and b. (States with 18(b) consultation programs that opt to participate should follow the same procedures in submitting consultative visit summaries).

6. Inform the State designees that this Federal program change does not require a plan supplement.

E. Background. Accidents in chemical and petrochemical facilities can be catastrophic in nature, claiming many lives and injuring others in addition to property damage and loss in production. Consequently, OSHA has initiated a program in the chemical industry which focuses on reducing the probability and consequences of accidental toxic chemical releases that might harm workers within a process facility and people in the surrounding community. This program includes increasing employer's and employee's awareness of hazards in the chemical industry.

In the past, valuable data relative to hazard identification and control were collected and placed in the case files including engineering solutions for specific operations. This potentially valuable information was rarely shared with employers, employees, and other interested groups. This instruction is intended to provide the mechanism for the collection and dissemination of chemical industry solutions within OSHA and to interested parties and organizations outside of OSHA.

OSHA Instruction CPL 2-2.50 OCT 17, 1990 Directorate of Technical Support

F. Procedures. Each Regional Administrator shall be responsible for the development of brief, written summaries for selected chemical industry cases and chemical industry consultative visits and for their transmission to the Directorate of Technical Support at the National Office. All information WHICH IS A TRADE SECRET OR OTHERWISE CONFIDENTIAL must be removed from the summary report. Specific guidelines to be followed are set forth below:

1. Area Offices and Consultation Project Offices. Area Directors and Consultation Project Managers shall be adequately briefed on the goals of the project.

a. After a chemical industry inspection or visit has been completed, the Area Director or Consultation Project Manager, shall be responsible for writing a summary if it has been determined that this investigation is noteworthy. The summary shall include the following elements:

(1) A short paragraph analyzing the hazard(s) identified, giving the apparent cause and related factors contributing to the existence of the hazard(s). Identify the related occupational safety and health problems. Where appropriate, rough sketches, photographs, with explanatory detail, and/or reference to video tapes taken are encouraged;

(2) A short paragraph describing the corrective action(s) implemented by the employer. The description should include changes made in ventilation and exhaust air systems, process design, physical plant design, operational procedures and practices, personal protective equipment and employee retraining and job rotation. Where appropriate, provide

OSHA Instruction CPL 2-2.50 OCT 17, 1990 Directorate of Technical Support

sketches, photographs and/or videotape of the workplace after the corrective action was taken;

(3) A brief summary of significant benefits realized. Examples of such benefits are cost savings, the identification and successful solution to a unique safety or health hazard, increased awareness of workplace safety and health, and injuries prevented or reduced by the recommended abatement methods. An estimate of cost savings should be determined based on reduced workers' compensation costs, medical services, time lost from work, and increased production, if appropriate; and

(4) The number of employees who may possibly be benefitted from the abatement method(s).

b. The summary shall not be forwarded to the Regional Office until the case has been closed.

2. Regional Offices. Although Area Directors and Consultation Project Managers are responsible for writing the first draft of the summary, the Regional Administrator shall ensure that the summary sent to the National Office meets the project goals.

a. Regional Administrators shall screen the summaries received from the Area Offices and select those to be forwarded to the Director, Directorate of Technical Support for possible publication.

b. At least one summary should be forwarded by each Regional Administrator semi-annually. Those judged to have the widest interest and greatest impact on preventing injuries should be given highest preference in the selection process.

OSHA Instruction CPL 2-2.50 OCT 17, 1990 Directorate of Technical Support

c. Regional Administrators shall begin sending summaries to the Director, Directorate of Technical Support no later than the last day of the first quarter following the publication of this instruction.

d. The Regional Administrator shall transmit the selected summaries within 20 days of receipt from the Area Offices and Consultation Project Offices.

3. National Office. The Directorate of Technical Support shall review and evaluate the summaries received from the Regions. The summaries to be published shall then be selected and forwarded to the Director, Office of Information and Consumer Affairs (OICA).

a. The Director, Directorate of Technical Support will collect, organize, and maintain a file of all summaries submitted. This will be made available to the Director, OICA, and to other OSHA offices.

b. A minimum of one summary will be published and distributed (using an existing mailing list) quarterly by the OICA.

4. A format for the summary page is attached to this instruction.

OSHA Instruction CPL 2-2.50 OCT 17, 1990 Directorate of Technical Support

5. Recipients of the summaries may use them in any way they choose. They are not copyrighted, and permission is not required to reproduce them. Users are requested, however, to credit OSHA, U.S. Department of Labor.

Gerard F. Scannell Assistant Secretary

Distribution: National, Regional and Area Offices State Designees 7(c)(1) Project Managers All Compliance Officers

OSHA Instruction CPL 2-2.50 OCT 17, 1990 Directorate of Technical Support

PROJECT RECORD

Document type:

Type of Business: (SIC)

Size: (# of employees)

Operation and Hazard Description:

Control Method(s):

Summary of Significant Benefits: